[BC] BDR Article--"Does the FCC Know Where Your Station Is?"

[Michael Patton]

I ran into this with a small-town AM/FM combo in a nearby state just 
recently: they hired me to prepare and file an STL app for their FM, 
which has been running on a T1.  They had all the gear, STL unit, 
coaxes, and antennas, all in place, but for some reason they never 
licensed it, til now.  Standard downtown studios with short (80')  
tower, one shot, path less than 8 miles, rural area.  Seems simple, 
right?  Wrong!

As I got to digging in the databases, I found that the studios had been 
moved without notifying the FCC some years back.  Then I found that the 
AM, which is now a 5 KW ND day, 57W ND night, used to be a 1 KW 3-tower 
DA at night, but they had cut two towers down and accepted the 
flea-power at nighttime.  They got the FCC to approve the change to ND 
nights and did indeed drop the other 2 towers but never updated the ASR 
database or the FAA itself.  Google earth showed that the databases were 
wrong for the remaining AM tower and the FM tower, and the studio tower 
failed TOWAIR due to the local airport being 100' lower in elevation 
than downtown nowhere, where the studios were.  The AM and FM towers 
were so old that modern file-# aeronautical study numbers; so I had to 
file for new Determinations of No Hazard for every tower the station owed.

Before it was over we had to get all towers surveyed and file for new 
FAA aero studies and updated ASRs for all towers, studio and 
transmitter, and file a Form 302 for the AM (less than three seconds 
off), and a Form 301 for the FM (6 seconds off).

Oh, and only after all that, was I finally able to file the damn FM STL 
app!  Since I had to update the STL studio location due to the 
unreported move, I went ahead and filed a coordinate update for it, too.

When it was all over, I had filed on top of everything they had listed 
in all three database, plus the new STL app. What an epic!  Cost the 
poor guy an arm and a leg to get his numbers straight.

The only good thing was that we were able to use the 3-second USGS topo 
database, instead of the less-accurate 30-second database used in the 
original filing, and therefore we got the guy a 14% increase in TPO 
(derated due to use of an over-height tower).  We spent thousands of 
dollars of the guy's money just to clear up a few sets of coordinates.  
Oh well--at least I'm not expensive, as consultants go.  What a struggle!

Mike Patton, owner, Michael Peeeesatton&  Assoc.
12231 Industriplex Blvd, Ste C, Baton Rouge, LA  70809
225-752-4189 ofc     225-266-9745 cell     www.michaelpatton.com

On 2/4/2012 11:17 AM, Tom Taggart wrote:
> Interesting article in the BDR...
>
> Many older installations may be off a by few seconds, simply
> because it was not that crucial at the time the station was
> built.  Not sure even if it is today, where the error may
> only be 1 or 2 hundred feet (except in the case of an AM
> directional array); but we've developed the accuracy of
> measurement beyond the ability to comprehend what the
> measurements mean.
>
> Can be an interesting problem where an antenna is mounted on
> a tower used for other services...tower registration or
> those other licenses might not correspond exactly to where
> the broadcast antenna is licensed.
>
> Interesting side light on this--couple of years ago friend
> bought an old AT&T microwave tower, which he then sought to
> have registered (short tower, didn't need to be
> registered--but he was looking for cellular rentals&  they
> would only look at registered towers).  FAA 7460 sent
> in--using AT&T's coordinates for the tower.  FAA office
> called back--coordinates were wrong--they were using
> TopoZone to check! Just a minor error, but the coordinates
> put the tower in the center of the county highway. (TopoZone
> still available--at Trails.com).
>
> Another interesting aspect to this is many folks do not know
> how to read the coordinates shown on a GPS. Back when we
> owned the local AM, a nearby church was a client. Later,
> when the low-power window opened, they asked me to do their
> application, pointing to a site about a mile&  quarter from
> that AM (which we had since sold). A site due south of the
> AM. No problem, we figured out the coordinates from a topo,
> filed that application, and a c.p. was issued.
>
> Minister comes in--complains the CP was all wrong--that the
> coordinates listed in the CP were on that AM tower...and his
> GPS proved it. As you've guessed, the longitude was right,
> but he had misread the decimal display of the GPS for the
> latitude.
>
> One important record that may be somewhere at the FCC--but I
> can't find on-line, is the studio address of the station.
> Our mail goes to a P.O. box, when we built our station in
> 1983, the rural mail delivery was unreliable.  Besides, the
> rural route address would have been "route X, Box Y;" there
> were no street numbers on our road at that time.  Now we
> have a "911" address, which we had to get because a lot of
> UPS shipping locations have software that demands a street
> number be entered. Never bothered the local UPS drivers,
> they just parked in front of the building with the big tower
> next to it.  Of course, since we have a combined site, it
> would be easy for the FCC to find--just type in the tower
> coordinates.
>
> However, when we bought a third station, we had to move the
> studios in 2 months.
> The station had been in a JSA with the local Clear Channel
> Cluster, CC did not renew the JSA so the absentee owners
> sold to us. CC wanted their closet studio vacated. So we
> bought a house, threw up a 60' STL tower&  built a studio,
> all in the two months from the October 15th signing to the
> late December closing. One of the things we did is send a
> letter to the Commission alerting them to the address change
> for the studio. (We're still trying to get all the agencies
> to correct their databases--just this week we've been
> tracking down a missing check that probably got sent to a CC
> lock box).
>
> Interestingly, the field inspector went through town 6
> months later, stopping at the two local clusters but not at
> this station. Would have had to drive right by the studio
> going from one cluster to the other. Maybe we just weren't
> on the list.
>
> However, I can't find anywhere on FCC.Gov which lists studio
> addresses. Mailing address--yes. Not the actual studio
> address.  Again, could be inferred from the STL license
> coordinates--but if the station uses a wired data link or
> unlicensed 5.7 ghz link there's no licensed site to track
> down.
>
>