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Stranger than Fiction!

| April 3, 2013

By Thomas R. Ray, III CPBE, AMD, DRB
Tom Ray Consulting
Technical Editor

NEW YORK — March was a bizarre month.  I don’t know if it was the full moon last week, the expectation of a spring that wasn’t quite here yet or what.  Here are two examples:

I would have asked that this be published on April 1, but too many people would think this was an April Fools gag.  I swear, I couldn’t make this one up!

Where’s the Proof?

I have a client station that I’m working for on a submission to the FCC.  It involves a directional AM antenna, and we need to submit the results of a Partial Proof of Performance on the antenna system – one done before a modification, one done after.  Only problem is, the station cannot locate the full Proof of Performance of record on the antenna system.

For those not familiar with AM directional antenna systems, each one has a Proof of Performance.  Newer arrays utilize what is known as a MoM, or Moment of Methods Proof.  In this proof, stated basically, which must be recertified every two years, you electrically measure the sampling (monitoring) system, then measure the base impedances of the towers and compare them with a computer generated model.  If all agrees, you adjust the antenna according to the computer model and you’re good to go.  While there are three “reference” measurements made along critical radials, you do not need to measure these points periodically.

That being said, most Proofs are of the old fashioned variety where you need to go out and measure points in specific directions at specified distances from the antenna.  In years past, you needed to run a “Partial Proof” every third year, and a “Skeletal Proof” every year.  These days, you generally only run a Partial if you suspect something is wrong or if you make changes in the system.  The Full Proof of Performance that was completed on the antenna and submitted to the FCC at the time the antenna was constructed (or the last time a major modification was done) is used to compare the “now” readings to those obtained when the system was licensed.  In this case, we cannot locate the Full Proof, so we have nothing to compare to.

So I contacted a large consulting firm in the Washington, DC area and requested, through them, a copy of the last Full Proof of record of the antenna.  Well, this was in February.  I had them on my call list about 30 days after my request.  They beat me to the call.  The call went this way:

“You may be wondering where your copy of the Proof is.”

“Yeah – I was.  I’m assuming it has to do with the weather-related closings of government offices in the DC area over the past couple of weeks?”

“You’re not going to believe this.”

“Try me.”

“One of our staff engineers almost got arrested yesterday for screaming at people in the AM branch.”


“Yes.  She wanted to know where the damn copy of the Proof was.  The Commission has a room full of lateral file cabinets.  This station’s Proof is located in the top drawer of one of the cabinets – and they can’t get the drawer open.”


“They can’t get the drawer open.  It’s stuck.  It’s been this way for three weeks.  She told them, or actually yelled at them, to get a [expletive] office supply company in and get the [expletive] thing open!”

Yeah.  I haven’t been able to get my Proof copy because the filing cabinet is broken!  They eventually have gotten into the cabinet and the Proof is presently being copied.  I told you – you can’t make this stuff up.

Our Buttons Don’t Work

On another note, I have a client station that decided to change engineers, and asked that I come in to evaluate the transmitter facility.  It’s a nice facility, a smaller, non commercial station.  The racks at the transmitter site need to be gutted, as the wiring, which is not documented, is a disaster, but otherwise, it is in good shape.

While we’re going over things at the transmitter and I’m logging into the remote control system to change passwords, they ask, “can you tell us why our buttons don’t work?”


“Our buttons on the other end of the remote control system at the studio.  We can see the transmitter readings – but the buttons don’t do anything.”

“You mean, you can’t turn the transmitter on and off or adjust power??”

“That’s what we mean.”

“What did you do if the transmitter tripped off?”

“We called the engineer.  He told us we didn’t need to control the transmitter – just call him.”

Um, OK.  So what if he is not available?  And what if there is a problem that requires the station to terminate operation and he is not available??  While FCC regulation 73.1350 seems to allow the off-site engineer to be in control of the transmitter, what is the problem with having the station and the air staff be in control?

Needless to say, since their system had IP connectivity, I installed the application on a computer at their studio location and they now have full control of the site via IP.  They are now 100% legal, can control the transmitter, and can call me with questions/problems until they find a replacement engineer.

The problem stemmed from a studio move.  When the studios were moved, the station switched to a digital STL link.  The control system was configured to use a subcarrier on the STL (probably 152 kHz) to allow control of the transmitter, and uses the 92 kHz subcarrier on the main FM signal to get readings back to the studio location.  Digital STL’s don’t allow the use of subcarriers.  The control system needed to be changed to an RS-232 data link that the STL will accept, or IP.  Neither was done.

I am not of the school that the air staff should be “hands off” with the transmitter.  This is their portal to the outside world – they should know how to tell if the transmitter is operating correctly and what to do if it isn’t.  You used to have to pass a test and obtain a license to do this, and what the air staff needs to know is not rocket science.  They also should have a book that lists, in step by step instructions, what to do under various circumstances, like, if the transmitter goes off the air and doesn’t come back on.  Having step by step instructions will prevent an “oops” from happening and causing damage at the site.  Proper engineering at the site will also prevent an “oops” from damaging equipment.  Don’t forget – the Commission’s rules require that the licensee know how the station is operating.  I don’t know about you, but I don’t pawn that responsibility off on one person without at least having a clue as to what is going on.  If the FCC knocks on the door, I would prefer to at least be able to answer their questions, even if something requires a clarification, rather than saying, “I don’t know.”

I’m off to NAB and Lost Wages, er, Las Vegas – and my mission to look at what technologies are out there besides IP codecs to replace ISDN.  I’ll let you know what I find.

tbugkThomas R. Ray, III CPBE, AMD, DRB is president of Tom Ray Consulting and Technical Editor of TALKERS. He can be phoned at 845-418-5065 or emailed at  His website is  Meet Tom Ray at TALKERS New York 2013 on Thursday June 6.  





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Category: Technical