[BC] How A Station Can Stay Afloat...

Harold Hallikainen harold
Fri Mar 30 10:17:35 CDT 2007


> On Friday 30 March 2007 09:40 am, Gary Peterson wrote:
>> " There are several rules that affect station staffing. They are:...
>> Harold "
>>
>> Unless it was deleted when I wasn't looking, there *was* a requirement
>> that
>> the designated chief operator of a directional AM be an employee, rather
>> than a contractor.
>
>  73.1870
>  I *was* the CO for which that rule was clarified, eons ago.
>
>>   I don't recall that the rule
>> required the DCO to be a full-time employee...just that the DCO was an
>> employee, rather than a contract engineer.
>
>  There's no requirement that the DCO be an engineer !
>  That wasn't the point. It was about enforceable authority, and the
> ability
>  to fire other employees.
>
>  At the time, before the attack of the lawyer hoards, there were
> reasonable
>  folks at the Commish.
>  It was felt that an actual employee could have authority over other
> employees,
>  while a contractor could not have immediate personal authority over
> employees.
>  "YOU'RE not the boss of me ! YOU can't fire me !" mentality.
>  Since the designation of "Chief" operator was intended to be the operator
>  ( among many ) that was chiefly responsible for technical compliance, the
>  Commish wanted that person to have unquestionable legal authority to
> actually
>  enforce station policy.
>  It was not felt that the Chief needed to be full time to be liable, or to
> carry
>  authority, but it was felt that he/she at least needed to be on the
> employee payroll.
>  At that time, the DCO could be personally held liable for violations as
> well, so
>  it made sense.
>  It wasn't believed that the Chief needed to personally be an engineer to
> make
>  certain engineering got done. He could hire, and fire an engineer as
> necessary.
>
>  The times, they are a-changin.
>
> --
> Cowboy

I agree! The chief operator requirements are at
http://www.hallikainen.com/FccRules/2007/73/1870/ . For FCC website
documents citing this rule, see
http://www.hallikainen.org/FCC/FccRules/CiteFind/0731870.htm . For a
history of operator requirements, see
http://sujan.hallikainen.org/nab/unattended/RegHistory.pdf .

Harold

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