[BC] Minimum staffing

[Mike McCarthy]

Mark,

The full time employee MUST be paid directly by the licensee.  Their 
salary can't subsidize someone else at the hosting facility or be 
indirectly applied.  They MUST be 100% licensee. The reason is to 
resolve/avoid any conflicts of interest.  Who is the employee truly 
beholden to for their salary? The licensee or the hosting facility.

As for the EAS...any point which has direct access to the program 
chain MUST have the ability to perform the requisite EAS functions 
under normal conditions.  Operation of the main studio is considered 
normal conditions.

And yes, the main studio does need to be a control point if for no 
other reason it has EAS equipment there and content can originate from there.

MM

At 09:52 AM 3/2/2009 -0500, Mark Humphrey wrote
>On Mon, Mar 2, 2009 at 1:07 AM, Broadcast List USER
><Broadcast at fetrow.org> wrote:
>
> > What you are writing about is illegal.
> >
> > You CANNOT "loan" out employees, and stations have been dinged 
> for it.  "For
> > a monthly fee" is NOT legal.  They must be employees as I read the rules.
>
>OK, so the written agreement between the big corporate owner and
>mom-and-pop host must use the term "employee", and each employee would
>be compensated in some way by the corporate owner.   Isn't that all it
>takes to make this legal?
>
> > You really don't need to originate any programming from there, but you need
> > to be able to, have EAS, and have it manned during normal business hours.
>
>Is there any reason why EAS gear must be located at the legal main
>studio in addition to the primary control point?  For that matter,
>does the main studio even need to be designated as a control point?