To the Federal Communications commission,
Hello my name is James Allen Wilson Jr. I am a broadcast engineer for both radio and television. I submit the following comments in response to the Localism Notice of Proposed Rulemaking (the â€œNPRMâ€), released Jan. 24, 2008, in MB Docket No. 04-233.
The area that strikes my interest the most is part 28. Remote Station Operation.
I do not recommend the FCC return to 24 hour staffing of the control point or studio. The studio should be manned during office hours but you already have rules to cover that. What I do recommend is that you totally revise unattended operation rules `into the 21st century.
Assign an unattended operator for when no one is home, in writing daily in station log. This person must have a phone and or pager and be able to be contacted after hours, If not it rolls to next unattended operator. At all times someone must be available or fines. This person must be able to make contact through phone or computer to studio and transmitter. Also the studio phone must have an auto attendant to page or call unattended operator in an emergency. Many stations are doing this type of thing now but spell it out.
Put it this way, at anytime 24 hours a day some person must be able to control station within a reasonable time say 5-15 min this person also must be able to be contacted.
These changes will allow unattended operation with accountability in essence covering a lot of your staffing requirements.
Eliminate or revise the 3 min off air rule for unattended operation for FM and TV or extend to 10 min make it clear in regards to modern unattended operations. Revise the failsafe rule and make it clear also in regards to modern unattended operations per station type AM/FM/TV.
In regards to station log spell out exactly what the FCC is interested in and mandate it more so then you do now, itâ€™s not clear itâ€™s vague.
Bring back station log time intervals to at least once every 8 hours this can be done automatically.
The EAS on remote operation needs a lot of work. When there is a local emergency hardly anyone knows how to activate a local alert. Therefore they call and itâ€™s after hours and no one is home. (And the station does not have a number posted for unattended operator!) And even if they are home they donâ€™t know how to create a local alert. Each community should have a station like â€œLP1â€ that can issue local alerts not just tests or relays of alerts. Make this a rule and let all police and emergency know that station can transmit a local alert.
Make the EAS equipment remote controllable through phone and or computer, that way in unattended operation a local originated alert can be transmitted (not just relayed like it is now). Another option is to assign local alert permission t police and or fire so they can indicate a local alert (much the way the tornado sirens go off ) They have staffing at all hours and know most emergencies.
In radio stations running unattended operations, have a system where remotely a phone call can be put to air over riding automation and stating emergency.
If there is still a problem make one station in market preferably EAS LP1 have staffing after hours so they can transmit local EAS alerts. Or have local agreementsâ€™ between stations so all shifts are covered to transmit a local alert.
In conclusion I believe by adopting some of these ideas I have discussed it would not be necessary to have 24 hour studio control point staffing.
James Allen Wilson Jr.