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 “NPRM”), 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.

In Brief,
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, it’s not clear it’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 it’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 don’t know how to create a local alert. Each community should have a station like “LP1” 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 agreements’ 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.
Broadcast Engineer
engineering@wtjr.org

Huston we have a problem!

(picture from India)

FCC Activities on the Localism Front
Subsequent to release of its recent Report & Order and NPRM on
Broadcast Localism, the Commission is taking steps to increase
the availability of broadcast information to the public. First, as
directed in the Localism R&O, the FCC’s Media Bureau revised
and released an updated version of “The Public and
Broadcasting.” This publication contains information about FCC
rules and policies, including those related to broadcasters’
responsibilities to their local communities. FCC rules require the
most recent version of this publication to be placed in the
broadcaster’s public inspection file. Licensees must also provide
a copy to any member of the public who requests one. If you
have not already placed the new version in your public file, you
should do so immediately. This publication may be accessed via
calling the FCC at 1-888-225-5322 or on its website:
www.fcc.gov/mb/audio/decdoc/public_and_broadcasting.html

1. Congress has mandated that after February 17, 2009, full-power television broadcast
stations must transmit only digital signals and may no longer transmit analog signals.1 With this
Report and Order in our third periodic review, we resolve issues necessary to complete the
conversion of the nation’s broadcast television system from analog to digital television (“DTV”).

http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-07-228A1.pdf

FCC Releases Specifics of Localism Rulemaking - Proposing Lots of New Rules For Broadcasters

At its December meeting, the FCC adopted a Notice of Proposed Rulemaking on Localism. At that meeting, while the Commissioners discussed the generalities of the proposals being made, the specifics of the proposals were unknown. The full text of the NPRM has now been released, and it sets out the areas in which the Commission proposes to re-regulate broadcast stations.

http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-07-218A1.pdf

http://www.broadcastlawblog.com/archives/public-interest-obligationslocalism-fcc-releases-rules-for-enhanced-tv-disclosure-requirements.html

The FCC has released the full text of its Order adopting enhanced disclosure requirements for broadcast television stations - requiring that they post their public files on their websites and that they quarterly file a new form, FCC Form 355, detailing their programming in minute detail, breaking it down by specific program categories, and certifying that the station has complied with a number of FCC programming rules.

Full text of FCC order
http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-07-205A1.pdf

First, the provisions governing the on-line maintenance of the public file include the following (with our observations in parentheses):

The Rules will become effective 60 days after the notice of their approval by the Office of Management and Budget (as required by the Paperwork Reduction Act - this is paperwork reduction?) is published in the Federal Register.
Stations can either post the public file contents on their own website, or on the website of their State Broadcast Association (why would the Association volunteer to do that?). Even if the State Association agrees to host the website, the station must have a link on its website to the report.
If a station has no website, it does not need to create one to comply with these rules (and it has no obligation to place the file on the State Association site). But if it later develops a website, it must have the public file contents posted within 30 days.
The contents of the political file do not need to be posted on the website
Letters from the public do not need to be posted on the site - though emails from the public should be posted
Documents that are posted on other sites, including the FCC site, need not also be stored on the station site, if a link to the documents is placed on the station’s site
The file must be accessible to the disabled, complying with Conformance Level A of the World Wide Web consortium’s Web Content Accessibility (W3C/WAI) guidelines. (Information may be found here). http://www.w3.org/TR/WCAG10/

This may preclude some files being stored solely in a PDF format (and will no doubt cause some consternation among those at stations, who we would expect to be most people, not familiar with these standards).
Twice each day, the station must publicize on the air, with its station identification, the availability of the file on the website. At least one of those mentions must be between the hours of 6 PM and midnight.
The FCC Form 355 requires information including the following:

A list of the station’s programming streams (i.e. the analog channel and any digital multicast program streams) and “their main programming focus”
A list of the parent company and affiliates of the company which owns the station (isn’t this what Ownership Reports are for?)
For each programming stream, the average number of weekly programming hours devoted to the following:
High Definition programming
National news
Local news produced by the station
Local news produced by some other entity (who must be identified)
Programming devoted to “local civic affairs,” defined as programming designed to provide the public with information about local issues, including statements or interviews with local officials, discussions of local issues, and coverage of local legislative meetings. This programming must be subtracted from the “news” programming reported above.
Coverage of local electoral affairs - basically coverage of local elections - which must also be subtracted from the news coverage numbers reported above
Independently produced programming, i.e programming not produced by a national network (presumably each local station will have to determine if a network has as little as a one-third interest in all programming that is being aired)
“Other” local programming - which is not defined but presumably would include sports, religious, and entertainment programming produced within the station’s service area
Public service announcements
Paid public service announcements (a PSA-type announcement for which the station or any group that the station is affiliated with - presumably including state broadcast associations - receives something of value)
Closed captioned programming
A list of each national news story that includes significant treatment of community issues, listing for each such program:
title, length and date and time of airing
whether it was aired on the primary channel of the station
whether it was locally produced
whether it previously aired on this station or any other station (how is a station supposed to figure out what other stations a national news program aired on?)
if it was part of a regularly scheduled news program
whether any consideration was received for the broadcast of the segment
A list of all local news program segments dealing with community issues, providing the same information for each such segment as listed above for national news segments
A list of all local civic affairs program segments that provides significant treatment of a community issue, with all the same details as listed above for news segments
A list of all electoral affairs programs that includes significant treatment of community issues, with the same details as provided for news segments
The title, length and date and time of the airing of all independently produced programming
A list of all local programming not otherwise listed above, with title, length,and date and time of airing, and whether the station received consideration for airing the program
For each PSA, the name of the sponsoring organization, the number of times the PSA ran, the length, and the percentage of times that were during prime time hours
For each paid PSA, the same information as for unpaid PSAs
Details of programming directed to “undeserved communities,” defined as demographic segments of the community to which little or no programming is directed (query - if no programming is directed to a particular demographic segment, how can a station have anything to report in this category?)
Details of religious services or other local religious broadcasts aired at no change
A description of how the station determined that its programming met community needs
Details on the amount of closed captioned programming broadcast by the station, and a list of exempt programs that were aired, with details as to the exemptions
Whether the station voluntarily provided video description of any of its programs and, if so, how much
Information about broadcasts about community emergencies, including a statement as to whether or not the station complied with the rules that require such programs to be accessible to the disabled
Whether or not more than 3 hours per day of programming is provided pursuant to an LMA or JSA.

Caption Mic Broadcast

How it works

During a program, a voice captioner respeaks (echoes) the dialog/narrative into a microphone that is connected to the Caption Mic PC. The Caption Mic software converts the voice captioner’s speech into words that are sent to a closed caption encoder. The encoder inserts the closed caption data into the program video.

Features
Real-time captions by voice
Significant cost savings over traditional methods
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Live Event is ideally suited for
Local news
Locally produced shows
Emergency announcements
http://www.ultech.com/products/prodinfo.asp?prodID=72&CatID=12

The rules updated
http://www.nhab.org/images/CBA_dec2007_2.pdf

http://www.fcc.gov/cgb/dro/ccrules.html

FOR IMMEDIATE RELEASE NEWS MEDIA CONTACT: November 27, 2007 Mary Diamond (202) 418-2388 FCC Requires Television Broadcasters to Provide More Local
Programming Information to the Public Washington, DC – The Federal Communications Commission (FCC) today adopted a Report and Order (Order) which requires television broadcasters to provide more information on the local programming they are broadcasting and facilitate the public’s access to that information. The Commission is committed to establishing and maintaining a system of local broadcasting that is responsive to the unique interests and needs of individual communities. Today’s action ensures the public is well informed about how well television stations are serving their local communities and will make broadcasters more accountable to their viewers.

Under today’s Order, television broadcasters must file a standardized programming form on a quarterly basis. This form will provide the public with easily accessible information in a standardized format on each television station’s efforts to serve its community. The form requires broadcasters to list various types of programming, including local civic programming,
local electoral affairs programming, public service announcements, and independently produced programming, and also includes information about efforts that have been made to ascertain the
programming needs of various segments of the community, and information regarding closed captioning and video described content. This form will replace the current issues/programs list,
which required broadcasters to place in their public file on a quarterly basis a list of programs that have provided the station’s most significant treatment of community issues during the preceding three-month period. The standardized programming form will be available online and filed with FCC. In this Order, the Commission also specifically requires television licensees to make their public inspection file (with the exception of their political file) available online if they have Internet websites and notify their audiences twice daily about the location of the station’s publicfile.

Action by the Commission November 27, 2007, by Report and Order (FCC 07-205). Chairman Martin, Commissioners Copps, Adelstein, and Tate with Commissioner McDowell
concurring in part and dissenting in part. Separate statements issued by Chairman Martin, Commissioners Copps, Adelstein, Tate, and McDowell.
Media Bureau contact: Holly Saurer (202) 418-7283 -FCCNews
Media Information 202 / 418-0500
Internet: http://www.fcc.gov
TTY: 1-888-835-5322

FCC Looks at Changes to Rules Covering Unattended Operation

by Leslie Stimson, 7.04.2007
Leslie Stimson is the News Editor and Washington Bureau Chief for Radio World.

Surprising many observers, the FCC used the IBOC proceeding to review some basic regulations for all stations when it published new digital rules.

The commission is revisiting the appropriateness of unattended operations for all stations and how that affects the transmission of EAS alerts in connection with its review of public interest requirements for IBOC.

While the FCC now has published basic service rules and fundamental public interest obligations for digital channels, it seeks comment on additional public service obligations in a Second Further Notice of Proposed Rulemaking. These new obligations could extend beyond the digital channels to affect main analog channels.

If the FCC were to cut back on the number of hours a station may operate unattended — and possibly require 24/7 staffing — the change would apparently affect all stations and could have a large impact on facilities, especially those with undersized staffs in small markets.

In 1987, the commission eliminated a provision of the main studio rule in which stations were required to originate a majority of non-network programming from the main studio. It did so in part based on technical advances in program production and distribution, it said.

In 1995, in response to improvements to monitoring equipment for stations and transmission facilities, the agency authorized unattended operations and expanded the ability of stations to control and monitor station technical operations from remote locations.

Now, the agency is asking whether “changes in remote operation impacted the requirements that the commission should adopt in this area.”

The FCC has an open EAS proceeding and believes asking EAS questions in the digital proceeding is appropriate, although the issues it seeks comment on would apply to all stations.

The commission is taking comment on whether it should revisit the rules allowing unattended operations, and specifically, whether the “widespread reliance on automated operations” limits the ability to distribute EAS alerts effectively.

The commission didn’t mention other possible reasons for opening this topic, such as loss of localism, which some critics say resulted from allowing “automated” stations.

“Although EAS equipment can be programmed to operate automatically in certain circumstances, when a state or local alert is initiated by designated local authorities, initial input of the alert and activation of the originating EAS ENDEC must be done manually. In some emergencies, this initial input does not occur,” the FCC stated.

In a footnote, the FCC referred to two incidents where it states EAS alerts were not activated: the widely reported 2002 train derailment near Minot, N.D., and a train collision in Macdona, Texas, 10 miles from San Antonio.

In the Minot case, Clear Channel has said state emergency personnel did not know how to operate the EAS and did not send the initial message to the primary station to pass on. Clear Channel says it has since trained state personnel on how to operate its EAS equipment.

The question of unattended operation and whether it affects a station’s ability to transmit an alert is separate from the EAS Common Alerting Protocol order the agency announced in May.

The commission will require EAS participants to accept CAP messages after FEMA adopts standards. CAP involves the transmission of EAS alerts as text, audio and video via broadcast, cable, satellite and other networks.

And finally, the commission, which is examining whether requirements for the public inspection file for TV stations are adequate to ensure the public has easy access to the material, is asking the same questions about digital and analog radio stations.

The agency has proposed that TV stations make the contents of their public inspection files available on the Web. The FCC asks whether radio should do the same or if radio rules should be different.

Comments on the Second Further Notice of Proposed Rulemaking, FCC 07-33, are due 60 days after Federal Register publication.