I have the pleasure of doing a lot of traveling conducting voluntary “mock” inspections of radio and television stations. I’m not an attorney and I don’t claim to be. I’m a broadcast engineer, former station owner, and now a FCC Compliance Specialist. I’ve had the joy of a long career in broadcasting and after such a long time, still enjoy the industry.
Earlier this year, I was contracted to inspect 20 stations owned by a group, located in California, Oregon, Washington, Idaho, Utah and Colorado. It was quite a trip, and I’ll tell you more about it in the weeks ahead.
If you are a broadcaster, you have many things to be concerned about, no doubt about that. This latest trip, reminded me of why I started Orchard Media Services as an FCC Compliance specialist, helping stations with the often complex and cumbersome task of maintaining all the requirements to maintain their license and not be subject to violations or fines.
I’ve written dozens of articles about what I’ve found out there in my travels, and without reiterating every single one of them, you can find them on my website, www.orchardmediaservices.com. However, this is my ongoing concern.
With all the turnover of staff, management, and ownership, the Public Files and other documentation is seriously neglected. I found myself wondering if anything had improved over the last ten years since consolidation became the norm and large groups emerged from the ashes. After reading this article I wrote back in 2001, just ten years ago, I almost hate to acknowledge that the answer to the question, “has there been any improvement?” would be a resounding, NO. You can read this article here:
Here’s what I found on my latest trip; Public Files that had been neglected for years and no one knowing what to do about them. One station even ran out and bought a filing cabinet and spent hours into the evening prior to my visit trying to organize their Public File. When I inspected the file, I felt sympathy for their staff that stayed late, because documentation was missing, numerous quarterly reports were missing and no matter how much they tried, it will result in a fine from the FCC. That’s just a fact. Believe me or don’t, but the FCC recently served a Notice of Liability and Forfeiture for a station issuing a fine for $10000, for missing nine quarterly reports during their license period. I wonder what the fine would be for the station I just visited, who was missing 20?
Cumulus Station in PA Hit With $10,000 NAL.
Ever sit quietly in your GM chair wondering if an FCC inspector would ever walk through the front door and ask the receptionist to see the public file? You may ask yourself, “ It's so rare that a listener or community member ever asks for a peek at the files, why would the FCC care about us? Especially the little guys in a small town, off a beaten path”.
Well, this story may make you get up out of your chair and make sure things are up to date and ready for a look see.
Here’s what happened in Philly:
On November 17,2009, an agent from the Enforcement Bureau's Philadelphia Office conducted an inspection with Station WWIZ's chief operator and station market manager at the station's main studio in Youngstown, Ohio. The agent reviewed the materials in the public inspection file and found that the station was missing nine quarterly issues/programs lists, i.e., all quarterly issues/programs lists since the Commission granted Station WWIZ's renewal application on June 22, 2007.
Stations must maintain, for public inspection, a file containing quarterly issues materials. The file needs to be available for public inspection at any time during regular business hours. The list of programs outlines the station's most significant treatment of community issues during the preceding three-month period.
Cumulus has 30 days to pay or appeal
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Remember your station license is for 8 years. Quarterly reports are required. Let’s do the math: 4 quarters per year would add up to 32 reports that should be in your public file.
Not only has the broadcast industry declined over the past ten years due to new media technologies and competition for audience. Nobody is ignorant to that. But, has it become “standard operating procedure” to just not be overly concerned with “protecting the license”, and maintaining the minimal requirements for having the right to hold a license to broadcast.
I’d think I was the only one who cares, but I know that’s not true, because believe it or not, my consulting services appear to be in high demand in 2011.
More stories from the road coming soon…..
Until then, if you need some help at your station, don’t hesitate to call me for a confidential conversation!
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