Here Comes Summer!
Maybe it’s a product of how busy I have been of late, but wow, summer sure got here fast! It’s amazing how quickly time goes by when there are deadlines to meet and other time pressures.
With the warm weather months upon us, we also have all the usual site maintenance issues to deal with. Formerly barren ground quickly turns to a jungle of weeds with the least amount of rain. Miller moths multiply at an exponential rate and get through the tiniest openings to lose their lives in high-voltage arcs within our transmitters. And the cooling season also begins, along with all the maintenance and repairs that such calls for (including occasionally unclogging condensate drains of all those dead miller moths!).
As licensee of four local AM stations, we have a lot of Colorado real estate to maintain, and this time of year that means mowing, and lots of it. Several years ago we purchased a 1970s-vintage Massey-Ferguson 180 tractor, brush hog and several other blades and implements to assist us in keeping up with all the work. We had previously contracted out everything, but when you’re talking about over 100 acres to mow several times during the growing season, you’re looking at some serious money. It made financial sense for us to purchase the equipment and have our local engineering crew take care of the mowing chores.
That has worked out pretty well so far. We have had our share of maintenance issues with that old tractor, but all in all we are ahead of the game financially. We have also been able to stay out of dutch with the Weld County authorities. Those folks, with a lot of South Platte River frontage in their county, take an aggressive stance on any Canada thistle growth anywhere near the river or any drainage leading to the river.
So if you’re out and about and see a big red tractor operating in one of our antenna fields, that’s no landscape maintenance contractor driving it… it’s either Amanda or Keith. Honk and wave as you drive by!
What’s That Rule Again?
Over the past few years, I have run into one issue several times with FCC Enforcement Bureau (EB) personnel. This has never occurred in Colorado – our local EB folks are first-rate and they really know their stuff. But that is not the case in every district.
The specific issue that I always seem to run into concerns the posting of antenna structure registration numbers (ASRNs) at tower sites. The rule, 47 C.F.R. §17.4(g), states: “Except as described in paragraph (h) of this section, the Antenna Structure Registration Number must be displayed in a conspicuous place so that it is readily visible near the base of the antenna structure. Materials used to display the Antenna Structure Registration Number must be weather-resistant and of sufficient size to be easily seen at the base of the antenna structure.”
For the umpteenth time, one of our outlying stations got a Notice of Violation (NOV) that stated: “The antenna structures are surrounded by a perimeter property fence. The Antenna Structure Registration numbers were not posted at the gate of the perimeter property fence, and any signs posted at the base of the antenna were not visible from the gate.”
The NOV clearly called this a “violation” and required a response and remedial action. The problem for the EB folks is that posting additional signage at the property gate, or even insuring that the signs at the tower bases are readable from the perimeter gate, is not required by any rule!
While I certainly would not argue that having ASRNs posted at the perimeter fence is a good idea, it is not required and it really amounts to a needless expense for already cash-strapped broadcasters.
In every case where I have had to answer one of these NOVs to date, I have respectfully replied that I completely concur with the agent’s observations, which themselves bear out that the facility is in full compliance with 17.4(g), and in every case to date, I have not heard another word.
So where does this come from, this calling a non-violation a violation? It’s hard to say without some insider knowledge, but I suspect that the requirement for perimeter signage is contained in some policy or guide book that is used by EB personnel in the field. But policy and guidelines are not law.
Interestingly, Denver EB personnel contacted me in recent years about a tower light that was not flashing properly that they had observed on a drive-by of one of our local sites. In that contact, the agent gave me the ASRN of the tower. It wasn’t posted at the gate or anywhere except the tower base as required, and no mention was made of the need to do so. As I mentioned above, the local EB folks really seem to know their stuff.
Whatever the case, I guess we can all consider this a word to the wise. If the budget will stand it, posting your ASRNs at the entry gate to the property as well as at the tower bases is probably a good way to avoid the issue altogether.
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