LPFM Checklist: Station Records and Inspection Availability
Accessibility for Inspection
Unless the station is subject to a pledge made in the 2013 LPFM filing window, LPFM stations are not required to staff a main studio. Even for stations that are subject to the pledge, there is no requirement for a meaningful management presence like there is in the full power rules. Even without a main studio requirement, you must make a station available for inspection during the station’s business hours or at any time the station is in operation.
LPFM stations are allowed to be operated “unattended”. This consists of either automatic transmission monitoring or self-monitoring equipment that can automatically shut down the station within 3 hours if an out of tolerance condition arises or by operating equipment designed to operate for prolonged periods of time which virtually all LPFM transmission equipment is. In cases where there is no automatic monitoring, the station should be monitored frequently throughout the day and may need to be shut down within 3 hours of detecting operation out of tolerance.
If an LPFM station plans to operate unattended, notification should be provided to the FCC’s Media Bureau to advise them of the address and/or telephone number where a responsible party can be reached during unattended operation. A copy of this letter should be retained in the station records during the entire time the station is operating unattended.
(11/2017) The FCC LPFM Checklist publication states that notification is required. Research conducted by REC and others have confirmed that this is an informal process within the Enforcement Bureau (the authors of the FCC Checklist) to assure they have contact names and numbers for the local broadcast stations in the area where the field offices cover. There is no specific rule that codifies a requirement for notification. REC strongly suggests notification to either the Media Bureau or to your local field office. See 10 FCC Rcd 11479 at paragraph 33.
Every station should have a designated control point. This is the location where the operation of the station takes place such as where the studio is located. At that control point, certain documents need to be made available for inspection.
Authorizations Just like when you have to show your driver’s license when you get pulled over by a police officer, you have to show your license when inspected by the FCC. The station’s license and any pending construction permits that have not been covered need to be readily available and easily accessible at the station’s control point. They do not need to hang on the wall but they can if you want. NOTE: Posting of the station license is recommended but is no longer required as a result in a change made in the Report and Order of MB Docket 18-121.
Station Logs and Records
While LPFM does not have a public file requirement, they are still required to keep specific logs and records. These logs and records include:
In this log, you need to record various events that take place including turning on and off the transmitter as well as entries related to any discovered non-compliant operation that is pending or has been resolved especially related to the status of Emergency Alert System (EAS) equipment as well as any maintenance to the other station equipment. Logs should note the date and time of the entry and the person making that entry. It’s always a good idea to log when nothing is wrong but was checked just in case.
LPFM stations are required to keep a complete record of all requests for broadcast time made by or on behalf of candidates for public office (at any level) together with the appropriate notation showing the decision made by the station of such requests and if the request was granted, any charges made, if any.
In most cases, the EAS log will be generated by your EAS equipment. It’s always a good idea to periodically print a paper log for your station records. The EAS log will track messages received including required weekly and monthly tests as well as actual activations. There will be more on EAS later on.
Antenna Structure Lighting
This does not apply to a large majority of LPFM stations but for LPFM stations that own their own tower that is subject to lighting and painting requirements, you must keep a log that tracks the extinguishment or malfunction of required lighting as well as repairs, adjustments or replacement of the lighting system and any related notifications to the FAA. We will expand on this later on in this training.
All of these items must be maintained in your station records for a minimum of two years and must be made available to FCC staff and representatives upon request for review and/or duplication.
Items with an asterisk * may not necessarily apply to all stations.
Are current station authorizations readily available at the principal control point for this station?(This requirement was discontinued in early 2019)
- Are required logs being retained for a period of 2 years?
- Are station logs/records readily available for inspection and/or duplication at the request of the FCC or its representatives?
- Do the logs clearly and accurately document all repairs, changes and other maintenance performed on the station equipment?
- Do the logs contain the time and date of each observation and the name of the person making the entry?
- Is the station maintaining a political file in accordance with §73.1943(a)~(c)?*
- Is the political file being retained for a minimum of 2 years?*
- If the station is operating attended, does the licensee maintain a person on duty at a fixed location, during all periods that the station is on the air where they can either monitor or control the station themselves or be contacted by automated transmitter monitoring equipment within 3 hours after an out-of-tolerance condition arises?*
- If the station is operating unattended, does the licensee maintain either automated equipment or periodic human monitoring that enables the station operation to be corrected or terminated within 3 hours if an out-of-tolerance condition arises?*
- For unattended operation, did the licensee inform the FCC Media Bureau, in writing, of the address and telephone number of a responsible party?*
- §73.845 – Transmission system operation
- §73.877 – Station logs for FM stations
- §73.878 – Station inspections by FCC; availability to FCC of station logs and records
- §73.1212 – Sponsorship identification; list retention; related requirements
§73.1230 – Posting of station license
- §73.1300 – Unattended station operation
- §73.1400(a) – Transmission system monitoring and control
- §73.1943 – Political file
- §73.3533(a)(7) – Application for construction permit or modification of construction permit
- §73.3536 – Application for license to cover construction permit
- §73.3539 – Application for renewal of license
- FCC 00-19 The original LPFM Report and Order (15 FCC Rcd 2205)
- See paragraph 119 for 2-year record retention policy.
- See paragraph 117 for notifying the FCC about unattended operation.
Related REC Knowledge Base Questions and Answers
- Are LPFM stations required to maintain a public file?
- What information must LPFM stations keep in the station log?
- Are LPFM stations required to have a “chief operator”?
- Can an LPFM station operate unattended?
- What do I do if a political candidate wants air time?
- Is my station subject to the point pledges such as local programming and main studio?
- Where can I find the rule that requires LPFM stations to operate a certified transmitter?
Let's now move on to Your Broadcast Day.
Information in this document is current as of February 25, 2019.
Information provided by REC Networks is for educational purposes only and should not be construed as legal advice. For legal advice, please obtain the services of a qualified attorney that specializes in FCC law, especially where it comes to LPFM.