[BC] Studio Staffing

Harold Hallikainen harold at hallikainen.com
Mon Mar 2 11:40:33 CST 2009


 > 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.

Note that the main studio location rule does not impose a staffing
requirement (see http://sujan.hallikainen.org/FCC/FccRules/2009/73/1125/).
The staffing requirement was imposed in the Jones Eastern case. See

http://sujan.hallikainen.org/FCC/FccRecord/6/6FccRcd3615.htm
http://sujan.hallikainen.org/FCC/FccRecord/10/10FccRcd3759.htm

In this case, a station had two studios and the question was which one was
the main studio, and was it compliant with the main studio location rule.

Footnote 11 of 7 FCC Rcd 6800 (1992) (Jones Eastern) states, "We are fully
aware, as NAB demonstrates, that a significant body of stations have only
a limited number of employees. For example, 5.8% (approximately 640) of
all radio stations are said to have two or fewer employees, while 18.7%
approximately 2060) have four or fewer. Unlike WRSF, stations of this size
will generally not have more than one studio. In such circumstances, where
the employees report to work to the main studio, we have no intention of
limiting their ability to leave the studio to conduct station business."

For a history of the main studio location rule, see
http://www.hallikainen.org/rw/insite/insite95.html .

Harold




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