[BC] EAS Logs

[Cowboy]

On Thursday 19 April 2007 09:53 am, Bailey, Scott wrote:
> 
> So, I'm taking this now as we keep a weekly "station log" to sign off on
> each week. EAS Logs are can be maintained separate in electronic form.
> 
> Since I'm the Chief Operator, and I was to maintain an electronic log on
> my pc, this is acceptable to the commission?

 Interpretations vary, but the rules are quite specific.
 The station log has specific requirements as to what must be there.
 It's my opinion that one puts ONLY those things required in the
 "station log" and nothing else, the "station log" being the only
 required legal document.

 Maintaining that log on your PC is fine, PROVIDED you have no disk crash,
 and do not "lose" the data during the retention period required by the
 rules elsewhere.

 Other things, transmitter readings and such, may be logged, and that's
 generally a good idea, but NOT as a part of the "station log" !!
 Why ?
 Because those other logs are not required at all, and therefore not
 subject to inspection, and therefore can't be used against you !
 Unless you enter those things into the station log !!
 Once entered, they can not be removed, and may well be used
 against you. Removing them would be its own violation.

 Therefore, there is no EAS log per 'se.
 EAS is a required part of the station log.

 My feelings about the Public File are much the same.

 Remember, the Commission is over populated by lawyers !
 What makes sense, is ethical and prudent, is irrelevant.
 What is technically jot and tittle the "letter of the law" is all that matters,
 except for "advice of counsel" which is about always an acceptable defense.
 ( because that, too, is a lawyer thing )

-- 
Cowboy