[BC] Sign of the times?

[Mike McCarthy]

There is still the main studio rule which requires that a station have:

1) A physical point of presence located within 25 miles of the community of 
license or the city grade contour of any Part 73 license with that 
community of license, including a TV station. (loophole...being done 
here...) which can place live programming on the station

2) A local phone number which either rings at the main studio or forwards 
to the control point of the station. The rule is ambiguous as it relates to 
the type of phone line being fixed or cellular. So long as the call is 
considered a local call to those in the community of license.

3) A full time employee considered a manager who staffs that point of 
presence on a regular basis during business hours, plus one other 
employee--full or part time.

4) The Public File available for inspection during regular business hours.

A station which doesn't meet <all> of the above conditions is in violation 
of the Main Studio rule. However. there is no requirement which states all 
business be transacted from the main studio location. A truly mobile sales 
force is not in violation and is actually becoming more common with 
portable equipment and very diverse/dispersed field staff's which don't 
require hard office space.  It's not that uncommon these days for companies 
with large field staffs to have 2 or 3 people for every desk/cube and that 
many cubes are pooled.  Their private files and such are either in 
"lockers" or cabinets issued to the employee, and the phones programmed to 
react to a password which the employee enters when "claiming" that cube for 
the day.

None the less, the owners of this station are extending their necks out 
pretty far into the guillotine if they are in violation of the main studio 
rule.  That is one rule violation which the licensee has a hard time 
proving their actions weren't "willful". And willful action that frequently 
places licensee's candor in question.

MM


At 12:01 PM 10/4/2005 -0400, Mark Bulla wrote
> From the DCRTV (www.dcrtv.org/mailbag.html) website:
>-------------------------------------------------------
>Is it now possible to run a radio station without any studio or offices? 
>The reason I ask is because the offices for WDMV seemed to have 
>disappeared from Random Hills Road in Fairfax. Their phone (703) 934-6300 
>has been disconnected and all of the numbers listed now are cell phone 
>numbers. When I tried to buy time, the person I talked to said they would 
>come to my office, but wouldn't meet me at the studio. It appears that all 
>shows now come from remote locations (including Greaseman from his house) 
>and go right to the transmitter in Frederick , MD. The sales staff seem to 
>all have offices in their cars and are dispatched when someone calls them 
>to inquire about commercial rates. I wonder if any other stations do this. 
>(10/3/05)
>--------------------------------------------------------
>--
>Mark D. Bulla - Chief Engineer
>WNUV WB-54
>2000 W 41st Street
>Baltimore, MD  21211
>t: 410-467-8854
>f: 410-662-4886