Hefty fine serves warning: be sure your auxiliaries are properly licensed or be prepared to pay.
It’s important not to lose sight of the Little Things. Your primary operating license? That’s a Big Thing. You know where that stands, and you make sure that everything about it is in good order. But how about your auxiliary licenses – studio-transmitter links (STLs), remote pickups, that sort of thing? Those Little Things may seem like unimportant incidentals in the greater scheme of your operation, but heads up: the FCC doesn’t share that perception.
One broadcaster found that out the hard way: it got spanked to the tune of $68,000 in fines arising from four STLs whose licenses turned out not to be in proper order. You can find the four separate orders here, here, here and here.
This might be a good time to check up on your STLs, just to be sure.
For the uninitiated, STLs are RF devices that take a station’s signal from the studio to the transmitter. All broadcast auxiliary authorizations (STL, remote pickup, intercity relay, etc.) tend to be inexpensive and low maintenance. They renew automatically with the main station license, so you don’t need to file a separate renewal application for them. In the hierarchy of FCC authorizations, they rank low on a couple of scales: the filing fee for a new or modified STL is a scant $150, and the annual regulatory fee for each STL has been a paltry $10 for several years now. While the process of obtaining a new STL may entail some additional fees (for frequency coordination, engineering services, legal services, etc.), STLs are obviously not a high end investment.
But that doesn’t mean you can simply forget about them.
Last August, an Enforcement Bureau agent inspected a four-station group operation in Casper, Wyoming. All four stations were using STLs, but the licensee could produce only one license for any of them – and that license specified a location different from the address where that particular STL had been operating for more than a decade. Oops.
As to the other three STLs, the answer was . . . well, there wasn’t any answer. No licenses could be found for any of them, even though the licensee confirmed that one of the three had been in continuous operation since 2000, and the other two since 1995. The licensee did come up with a call sign for one of the 1995-vintage STLs, but it turned out that, according to the Commission, that particular call sign belongs to an STL in Georgia, not Wyoming.
The bottom line was that this licensee had apparently not bothered to take a close look at its four STLs in recent memory, and that lapse proved costly.
The standard fine for operating a transmitter (even a cute little STL transmitter) without a license is $10,000. The base fine for operating from an unauthorized location is $4,000. Taking into account the fact that these violations had been ongoing for more than 10 years, the Enforcement Bureau figured that it would be appropriate to double the standard fines, bringing the total to $68,000. It didn’t help that the licensee had been on the wrong end of another $10K fine in 2003. In that case, which did not involve any of the stations targeted in the latest inspection, the licensee was operating with (you guessed it) an unauthorized STL. (You might have thought that the 2003 fine would have prodded the licensee to check its other stations for similar problems. Apparently the licensee didn’t think that way.) Each of the orders refers to that previous forfeiture (which the licensee apparently paid) in a footnote, but the doubling of the base fines appears to be the result of the extended length of the violations, and not the licensee’s recidivism.
Anyone interested in checking the FCC’s database to confirm STL-related information can, and probably should, do so. A good place to start is the FCC’s General Menu (GENMEN) Reports page. There the Commission denotes each auxiliary broadcast authorization as a “child” to the “parent” full-power station it’s associated with. So if you want to know what STLs the FCC thinks are associated with your main station, click on the “Parent Child” link, enter the call sign or Facility ID Number of your main station (don’t forget to indicate which type of search – call sign or ID Number – you’re using) and click on “Submit Query”. The search results should provide you with a listing of all auxiliary licenses associated with the main station in question, as well as technical information about the auxiliaries.
If you have an auxiliary call sign and want to know what main station it’s associated with, the “Parent Child” option won’t help. Instead, you can go to the “Callsign” link in GENMEN and search for the auxiliary call sign. That should get you to a screen with information identifying the associated main station.
And remember, even where the “child” is associated with the proper main station, that does not necessarily mean that you can rest easy. For example, when a main studio is relocated to a new address, so too is the transmit site of the STL. But the change in STL site won’t automatically be entered into the FCC’s database even though appropriate notice of main studio change is filed. Think of it in terms of the “Parent Child” analogy: when a family relocates, the child stays with the family, of course. But the parent is still expected to follow up with necessary paperwork to reflect the relocation – for example, the parent must take steps to transfer the child to a new school. So, too, must the “parent” station’s licensee follow up to insure that any necessary modifications to the “child’s” authorization are made in the Commission’s records.
Now is an excellent time to doublecheck that all your auxiliary license information is accurate and up-to-date. We say this because, as previously reported, regulatory fees will soon need to be paid. Since reg fees are required for auxiliary licenses, it’s always a good idea to make sure that you and the FCC are on the same page with respect to precisely what auxiliary licenses you’re responsible for. A quick look-see at GENMEN should take care of that. And while you’re checking your auxiliaries, it’s also a good idea to confirm that the technical information in the FCC’s database is consistent with the station’s actual facilities. If there are any discrepancies, it’s best that you find out sooner rather than later, so that you can ideally get things straightened out before the inspectors arrive.
