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454 © Federal Communications Commission Reports
BEFORE THE
FEDERAL COMMUNICATIONS COMMISSION
Wasnineton 25, D. ©.
In the Matter of
AMENDMENT OF SECTIONS 3.66, 3.274, AND 3.572
or THE Commisston’s RULES AND REGULA-
TIONS RELATING TO Remors CoNTROL OrrRA- } Docket No. 11677
TION OF CERTAIN STANDARD, FM, And NoN-
Commercia, Epucarroxar FM Broapcast
STATIONS
REPORT AND ORDER
(Adopted: September 19, 1957)
By tHe Commission : Comusstonrrs Mack and Foro abstaining from
voting
1. The Commission has before it for consideration its notice of pro-
posed rulemaking released April 12, 1956 (FCC 56-323), and pub-
lished in the Federal Register on April 18, 1956 (21 F. R. 25384), in
‘response to a petition filed by the National Association of Radio -and
Television Broadcasters (NARTB) proposing amendments of the
Commission’s rules to authorize the remote control operation of all
standard and FM broadcast stations.
2. Present regulations permit remote operation, subject to certain
conditions, only by standard nondirectional and FM broadcast sta-
tions operating with powers not in excess of 10 kw. In our report
and order adopting the present rules we recognized that the most
important consideration was whether remote control operation would
result in any degradation of the Commission’s technical standards
and concluded that,,in light of the.status of the equipment needed
for remote control operation, the experimental demonstration of the
feasibility of such operations, the conditions imposed upon remote
control operation, and the salutary purposes to be accomplished by
its use in appropriate situations, the authorization of remote con-
trol, if limited to standard nondirectional and FM stations, operating
with power of 10 kw. or less, would not result in any degradation of
our technical standards.
3. Approximately 500 comments on the proposal were received from
various individuals and operators, broadcast stations, regional asso-
ciations of broadeasters, the national networks, and several national
labor unions. All of the comments submitted have been carefully
evaluated and considered. However, in view of the large number of
comments filed and the duplication of the contentions of the various
“parties, we shall limit our discussion thereof to the contentions..ad-
23 FCC.
Amend. Broadcast Rules Re Remote Control Operations 455
vanced by the principal advocates and opponents of the proposal.
4. In support of the amendments, the NARTB urges that the Com-
mission considered and disposed of all objections to remote control
operations in adopting the present rules; that the Commission’s con-
clusions are equally applicable to the association’s present proposal;
and that the only issue to be decided is whether a further relaxation of
the rules would result in a degradation of the Commission’s technical
standards. NARTB claims that the limitations in the present rules
were adopted solely because of the lack of technical proof that equip-
ment of a higher power could operate without a degradation of the
technical standards and urges that the data furnished with its peti-
tion demonstrates that present remote control operations indicate a
high degree of reliability and that remote control operation may be
extended to stations utilizing directional antenna systems and high
power with the assurance that equal reliability will be achieved. The
association alleges that the outage time of 198 stations now authorized
for remote contro] operations amounted to only 0.04 percent of a total
on-air figure of 630,790.5 hours, less than one-third the amount for
stations operating without remote control prior to 1953; that this
figure confirms the Commission’s original conclusion that remote con-
trcl operations would not result in excess outages and demonstrates
that transmitting equipment and remote control equipment have
reached a high state of development. It urges that remote operation
of stations, utilizing directional antenna systems and operating with
powers up to 50 kw., is feasible; that this opinion is confirmed by the
ata obtained from experimenta] remote operation of American,
British, and Canadian stations and unattended operation of radio
range stations.
5. The association recognizes the possibility that its proposals for
relaxing the rules might affect the CONELRAD stations not now
authorized for remote control, and proposes, that in order to insure
the continued effectiveness of CONELRAD, any future remote con-
trol authorizations to a standard broadcast station, be conditioned
upon the station’s being equipped to operate in the system either by
remote switching of the transmitter or, by using a separate trans-
mitter. While the proposed rule would require the installation of
certain equipment actual participation in the CONELRAD system
would remain on a voluntary basis.
8. In opposition the American Communications Association (ACA),
the International Brotherhood of Electrical Workers (IBEW) and
the National Association of Broadcast Employers and Techni-
cians (NABET) argue that the data submitted with the NARTB
petition does not support the conclusion that the successful remote
operation of stations utilizing directional antenna systems and higher
power is feasible. ACA contends that the unattended operation of
CAA low and medium frequency radio wave stations is not evidence
of the reliability of transmitting equipment since the statistics fur-
nished by NARTB indicate that during the 3-month period in 1955
the average outage per station per month was 3.28 hours. IBEW
contends that the CAA operations are in no way comparable with
broadcast operations nor has. there been a showing of a clear and con-
23 F. C.C.
456 Federal Communications Commission Reports
vincing record of stability; that the range stations operate with less
than 400 w.; that from July 1954 through June 1955, the CAA oper-
ated an average of 309.6 facilities for a total of 2,712,096 hours, with
a total number of outage hours of 9,420, an average of 30.42 hours per
station; that from January through December of 1955, 32 broadcast.
stations (19 of which have a power of 50 kw.) operated for a total of
254,931.2 hours with only 25.4 outage hours, an average of slightly
more than 47 mirutes per station and that in the CAA operation more
time was lost due to transmitter trouble than was lost due to remote
control failure. NABET contends that there is no evidence of the
conditions under which such stations operate, the special reasons for
unattended operation, and the special compensations made to maintain
reliability. ACA argues that the contention of NARTB, that the
unattended operation of stations by the British Broadcasting Corp.
indicate the high degree of reliability of both broadcast transmitters
and associated remote control equipment, is misleading in that many
of the stations were semiattended and thus there are some serious
questions as to the accuracy of the figures. NABET contends that
the British experience with unattended operation does not show the
direct relevance of this experience to the totally dissimilar American
operation ; that conditions are different in England than in the United
States, in that what is satisfactory service in England, where the
audience is small, would not be acceptable to the great urban audiences
in this country and that the British use multiple unit transmitters te
assure reliability. It is alleged that CONELRAD has become ineffec-
tive for those stations currently on remote control because of the time
factor, that studio technicians are completely occupied with innumer-
able program operations and to expect them to perform additional
full-time duties of keeping transmitter logs and to maintain the high
standards of broadcast transmitter operation is unrealistic; that the
reason for regular readings on transmitters is to anticipate abnor-
malities in operation and to take immediate action to correct such
occurrences, and that the inevitable logic of remote control is to
dispense with these readings completely.
T. Opponents contend that the issues in this proceeding are not
confined to the purely technical question of whether a further relax-
ing of the rules would result in degradation of the standards and that
unless the petition is dismissed on the basis of comments alone, the
Commission must conduct full. public hearings to obtain evidence
on the operation of station transmitters from all persons concerned
with their day-to-day operation, and to have the benefit of experienced
judgments of independent engineers who are not partisan and de-
pendent on the industry’s good will and, if after full public hearings,
it appears that there may ‘be substance to the industries’ demand for
rules relaxation, then the Commission must conduct investigations
into all phases of the status of present equipment, including direct
studies and surveys by independent technical professional personnel
of the hazards of unattended operation, the experience of all stations
presently authorized to operate by remote control, and the number
and cause of outages.
23 F. C.C.
Amend. Broadcast Rules Re Remote Control O perations 457
8. IBEW argues that exhibit 1 of the petition purports merely to
explain the contents and significance of other exhibits and thus cannot
be considered evidence in support of the petition; that exhibit 2 pur-
ports to show reliability of remote control operations with power not
exceeding 10 kw. and nondirectional antennae and has no bearing on
the present petition since the reliability of low-power, nondirectional
operation was the subject of the 1952-53 proceedings.
9. With respect to the material in the petition with regard to
stations with power in excess of 10 kw. and directional antenna IBEW
contends that in the case of WIRO, the exhibit reveals the unrelia-
bility of remote operation as it describes the problems of obtaining
suitable control circuits; that, although the period of remote opera-
tion covered approximately 79 days, readings were given for only 8
days, and during these § days the common point readings at the
remote point exceeded the 2` percent tolerance which indicate the
complete unreliability of the system as a whole; that in the case of
WOWO the transmitter was operated by remote control from within
the building using an artificial line to simulate each connection line
and that readings made during the 571 hours of operation show that
for 114 of these hours the readings were outside the 2 percent toler-
ance. It alleges that with respect to the material relating to stations
with power in excess of 10 kw. and nondirectional antenna, the ex-
perimental operation at KDKA and WSB were attended operations
and thus the material is not sufficient to permit any inference with
respect to the technical feasibility of unattended Operations; that in
the case of KDKA the remote meters were in accord only for a small
portion of the hours shown and a substantial number of readings fell
outside the 2 percent tolerance; that there was no indication as to
the number of outages that may have occurred and their nature and
duration and that in the case of WSB a substantial number of read-
ings were beyond the 2 percent tolerance, the operator on duty at the
transmitter performed duties that would be done by remote control
such as turning the transmitter on and off, taking frequency readings,
resetting overloaded relays, etc. Ta
10. IBEW states that in the case of the stations with power of 10
kw. or less with directional antenna referred to in the petition a first-
class operator was present at the transmitters and maintained the
operating log and kept the transmitter under supervision at all times,
and therefore the experiments were not conducted on the same terms
as the relaxation proposed and thus cannot be evidence as to the tech.
nical feasibility thereof; that with respect to the operation of certain
Canadian stations the power of the stations was 10 kw. or less, there
was no statement as to the accuracy of the telemetered readings; the
claim of reliability of remote operation is difficult to evaluate because
the telemetered information, recorded every 2 hours, is compared with
actual readings, recorded only once a week, the telemetered reading
of currents varied only slightly, while there were many excursions of
the actual meter and that while the disparities were not large in all
cases, their existence does-reveal that the system is not to be relied
upen.
a. NABET contends that the statistical survey of the experience
of 198 telemetered stations submitted by NARTB is devoid of the
23 F.C. C.
458 Federal Communications Commission Reports
minimal controls required to assure reliability of such surveys, and is
entirely devoid of discussion concerning the manner in which the
`- survey was conducted and that the tabulation showing the average
outage experience of 38 50 kw. stations is lacking details as to the
number of outages, the causes of outages or even as to the number
of hours of air-time operation. NABET notes that one of the grounds
for the decision in docket 10214 which authorized remote control for
stations with less than 10 kw. power and nondirectiona] antenna was
the claim of NARTB that relaxation of the rules was necessary so
that the small stations could survive in their competitive struggle
with the larger stations and argues that the same small station’s eco-
nomic base will be undercut by granting their powerful competitors
the same concessions. NABET states that the principal evidence of-
fered by NARTB is a comparison of the loss of air time made between.
the NARTB’s small-station survey and the average broadcast station,
which indicated that, for 198 small nondirectional stations, the aver-
age outage time was 0.04 percent, while the corresponding figure for
the average broadcast station in 1953 was 0.14 percent. They note
that the proportion of reported outage time increases as the station
power increases, and that the average outage for the 89 stations
reporting outages was. 0.09. percent.:
12. With respect to the outage time of 50 kw. stations, NA BET notes
that the survey shows that under conditions of attended operation,
large power stations are more reliable than small stations under re-
mote control. They state that skilled transmitter operators on the
spot can anticipate and prevent, or reduce to negligible quantities the
number of outages and that the number of transmitter lapses is of
infinitely greater importance than the loss of time with re, ard to the
test data on directional stations. NABET alleges that the stations
were not actually remote controlled, that the test was too brief, that
the experiments were too small in number and that NARTB acknowl-
edged several faulty results. ‘They further note that in some instances
the remote readings fell outside the 2 percent tolerance, and others
show such exact correspondence that there is a reasonable question as
to whether the readings were authentic,
13. With regard to CONELRAD, NABET states that CONEL-
RAD is not the principal issue; that what NARTB offers in exchange
for CONELRAD will not insure its success and that in fact; the added
expense will cause many of the small stations to withdraw from
CONELRAD. They suggest that CONELRAD participation either
be made compulsory, without any industry attached conditions, or be
taken over by the Federal Government.
14. One of the parties notes that the present rules do not appear
to permit sampling loop meters with different scales than the base
meters to be used as remote meters, although this is common practice ;
that the present practice is to mount the sampling loops above the
base meters, whereas the rules require that remote meters be installed
below the base meters and urges that section 3.39 (d) be modified
to reflect current practice. Another party suggests that section 3.93
(b) be amended to permit lesser grade operators to be in control of
directional antenna stations. It is also suggested that proposed section
23 F.C. C.
Amend. Broadcast Rules Re Remote Control Operations 459
8.66 (b) (1) be amended to permit the reading and logging of phase
monitor sample currents in lieu of base currents provided base cur-
rents are ready and logged once weekly.
15. In its reply comments NARTB notes that the oppositions to
the proposal are primarily directed to the adequacy of the technical
showing. It maintains that many of these technical objections concern
such matters as minor deviations in meter readings, and have no sig-
nificance; other comments show a lack of knowledge of Commission
procedures, or a misunderstanding of engineering matters; and the
technical points that would have been significant, if valid, have been
answered by supplemental exhibits filed with reply comments.
NAR'TB asserts that these supplementary exhibits which contain addi-
ional data on existing remote controlled stations and experimental re-
mote controlled stations using directional antenna and power in excess
of 10 kw., establish that the reliability of remote equipment and trans-
mitters is not changed because the equipment is used in connection
with a directional antenna; that the CAA directional antennas achieve
a reliability of 99.65 percent even though the standards for such an-
ennas are stricter than those governing broadcast stations; that Cana-
dian stations are successfully operating with remote control; that
KDKA-and WOWO have been successfully operated by remote con:
rol, and that the stations have experienced no serious malfunction of
he transmitters during the experimental period. NARTB submits
that with regard to station WSB recent data indicates that the trans-
mitter, in its,present condition, has not demonstrated sufficient relia-
bility to justify remote control but contends that the transmitter could
e modified so as to permit satisfactory remote control operation.
16. NARTB notes that the proposal to treat applications for remote
control authorizations from stations with directional antenna systems
on a case-to-case basis will eliminate any possibility of a station with
a nonstable array receiving such an authorization, as each applicant
will be required to make a showing of the stability of its array and,
since it has been shown that directional antennas are stable and can op-
erate by remote control, their use with higher power transmitters cre-
ates no additional problems and that the remaining issue is the relia-
bility of transmitters with power in excess of 10 kw. It suggests that
authorizations for remote control operation of stations, operating with
power in excess of 10 kw., be granted on a case-to-case basis and only
upon the following conditions:
(a) That an auxiliary transmitter, with power of 5 kw. or greater be installed
which can be activated from the remote point; and
(b) That the station be required to make a reasonable showing of the relia-
bility of the main transmitter. ` 7
It also suggests that in order to determine what transmitters are ac-
ceptable for remote contro] authorization, a yardstick should be
adopted which would be rigid enough to exclude those stations whose
equipment would be considered unreliable but flexible enough to in-
clude those stations whose equipment, by virtue of past maintenance
practices, has shown a satisfactory performance record. To achieve
this purpose NARTB suggests that the following information be sub-
mitted with the remote control application. i
23 T.C. C:
460 Federal Communications Commission Reports
(a) An analysis of the transinitter logs for the 12-month period immediately
prior to the application. This analysis to include such items as:
(1) Number of outages, cause, and duration.
(2) Consistency of Specific outages and whether corrective measures can be
or were taken to remedy further difficulties, and z
(3) Effect of outages on program service.
{b) An analysis of the maintenance logs and records for the 12-month period
immediately prior to the application. This analysis to include such items as:
(1) Type and consistency of maintenance performed; and
(2) Maintenance practices and policies adopted.
17. In reply to NABET’s allegation that a grant of the instant pro-
posal would destroy the basis of the 1953 decision—economic assistance
to low-power stations -NARBA states that many stations which now
utilize remote control only for their daytime nondirectional operation
are subject to same economic difficulties as the nondirectional stations
now authorized to operate with remote control both day and night and
accordingly need this relief ; that the major portion of the competition
to the small station does not come from the larger station but from
other competing media such as hewspapers and television and therefore
authorization of remote control operations for high-power stations
will not materially affect the economic status of the low-power station,
and eet it is the larger stations that are now feeling the economie
pinch,
18. In reply to the opponents contention that outages will materiall
inerease if remote control of higher power transmitters is authorized,
NARTB maintains that such authorization would tend to reduce the
number of outages as broadcasters wi ll have an incentive to modernize
their equipment; that the existence of an auxiliary transmitter will
eliminate the outages caused by malfunctions that cannot be immedi-
ately repaired by the attending first-class operator and that the broad-
caster will be encouraged to increase preventive maintenance.
19. Other parties filing reply comments note that the objections
to the proposed amendments were based upon contentions that insta-
bility in the transmitting equipment or directional antenna systems
would result in loss of air time or in operation not in accordance with
license specifications. They maintain that these contentions ignore
the fact that stability of operation depends upon the qual ity of trans-
mitting equipment and its installation and that the addition of remote
control and metering equipment to any standard broadcast station
cannot in itself make the installation more susceptible to failure or
maladjustment.
20. IBEW filed a motion to strike the reply comments of the
NARTB on the ground that they constitute an amendment to the pe-
tition and the submission of new evidence in an attempt to meet. the
deficiencies of the original presentation. The IBEW also states that
inasmuch as the petition, considered with or without the reply com-
ments, fails to make out a case, it must be dismissed and, in view of
the fact that the reply comments contain a petition for totally differ-
ent relief than that in the original petition, it would be improper and
a denial of due process of law to proceed further with this case.
NARTB filed. an opposition to the motion to strike filed by IBEW.
NARTB states that the reply comments are entirely proper and con-
23 FLO. C.
Amend. Broadcast Rules Re Remote Control Operations: 461
tain only information that is relevant to the issues in this proceeding
and rebuts the objections raised by the IBEW, NABET, and AC JA,
and that the change in the proposal for high-power stations is merely
a suggestion of a different method by which the objective of this pro-
ceeding can be achieved. NARTB contends that the IBEW’s inter-
pretation of the scope of reply comments would deprive the Com-
mission of basic information it needs in a rulemaking proceeding and
that the sole limitation on such comments is that they must be rele-
vant to the points raised in the comments. With regard to IBEW's
contention that the acceptance of NARTB's reply comments would
deprive it (IBEW) of due process of law, NARTB points out that
this is a rulemaking proceeding and not a comparative hearing in
which private rights only are concerned. We believe the material
contained in the NARTB reply comments was proper rebuttal of the
material contained in the original comments and relevant to the is-
sues in this proceeding. Accordingly the motion to strike filed by
IBEW is denied.
21. The IBEW filed a petition for institution of rulemaking to
amend the remote control rules so that:
Auy station, irrespective of power, heretofore or hereafter authorized to oper-
ate by remote control may be so operated only if equipped so that it can be
operated on the CONELRAD frequency assigned and the necessary switching
from the stations assigned frequency to the CONELRAD frequency can be
accomplished.
The NARTB petition proposed that ali future remote control anthor-
izations, whether or not now participating in the CONELRAD oper-
ating yoten, be conditioned upon the stations being equipped to satis-
factorily operate in the system and, by remote switching of the
transmitter or by using a separate transmitter, change from its normal
frequency to a CONELRAD frequency. Therefore, we are treating
the petition of IBEW as a counterproposal in this proceeding.
22. We have carefully considered the many comments filed in this
proceeding, and on the basis of these comments and our own knowledge
and experience in the field, obtained through reports and records, we
have determined that standard and FM broadcast stations with powers
in excess of 10 kw. and standard broadcast stations utilizing directional
antenna should be authorized to operate by remote control under cer-
tain conditions. The most important consideration is whether such
operation would result in any degradation of the Commission’s techni-
cal standards and requirements, or more specifically, would increase
the possibility of outages and improper transmitter operation. The
record indicates that the present remote control operation of broadcast
stations with powers up to 10 kw. has been satisfactory and no serious
degradation of the technical standards has resulted from such opera-
tion. With respect to the effect of remote contro] equipment upon the
operation of a directional antenna we find that the addition of such
equipment in itself would not introduce any instability in such an
array. While the addition of a directional antenna system would
modify slightly the functions which are now performed by remote con-
trol it would not add any new type of function. The stability of a
directional array is the function of the design of a passive network
23 F. C.C.
462 . Federal Communications Commission Reports
designed to produce a predetermined pattern of radiation and has no
relation to the means employed to monitor its operation. With respect
to the effect of remote control upon the operation of transmitters with
powers in excess of 10 kw., we find that the remote control equipment.
acting as it does merely to repeat back certain information, will repeat
back this information without regard to the power of the transmitter.
On the basis of the record and our experience we have concluded that
the addition of remote control equipment itself has no effect upon the
stability of a directional antenna or upon the transmitter itself.
23. A question remains as to the reliability of high-power transmit-
ters themselves. The record indicates that some high-power trans-
mitters in the experimental tests were run by remote control practically
without loss of time and with only a few malfunctions. Two other
transmitters were found to have insufficient reliability to justify un-
attended remote control operation in their present condition. How-
ever, it appears that these transmitters could be modified or certain
other steps could be taken to correct the malfunctions. In this connec-
tion, we note that NARTB proposed that remote control operations of
stations, operating with power in excess of 10 kw., be granted ou a case-
to-case basis and upon condition that the station install an auxiliary
transmitter, and submit a reasonable showing as to the reliability of the
main transmitter. We do not believe that the installation of an auxil-
iary transmitter should be a requirement for remote control authoriza-
tion. We believe that station management realizes that broadcast time
is important and that loss of on-air time results in loss of revenue and
therefore they will seek methods to insure that remote controlled trans-
mitters operate efficiently. However, we are of the opinion that a
reasonable showing should be made of the past operation of the trans-
mitter before remote control is authorized for a particular station. In
order to demonstrate that a presently authorized transmitter, regard-
less of its power rating is reliable and capable of being operated by
remote control, the following information should be submitted with
the application (FCC Form 301-4):
(a) An analysis of the transmitter operating logs, maintenance logs and records
for the 12-month period immediately prior to the application. This analysis is
to include the following items :
(1) The number of outages, their cause and duration together with what cor-
rective measures were taken to remedy the malfunction and to prevent such a
recurrence.
(2) The nature and consistency of past maintenance performed and a statement
as the maintenance practice und policy to be followed after remote control
authorization.
24. We wish to point out that the instant proposal does not contem-
plate that stations with high power and/or directional antenna be
operated by lesser grade operators. Many comments stressed the im-
portance of preventive maintenance, the necessity for observation by
an experienced technician, and the reliance on a first-class operator for
any significant repair. We believe that it is important that qualified
technicians be responsible for the operation of directional antennae
and/or high-power transmitters even though such stations may operate
by remote control. Therefore we are not changing the present rules
which require that stations operating with directional antenna and/or
23 F. C.C.
Amend. Broadcast Rules Re Remote Control Operations 463
power in excess of 10 kw. have on duty either at the remote control
point or transmitter location an operator holding a valid radio-
telephone first-class operator license.
25. In response to the request contained in the notice of proposed
rulemaking, many parties submitted comments concerning the infor-
mation to be supplied with the application for remote control of direc-
tional antenna stations as well as to what data should be supplied after
remote control was authorized. We have carefully reviewed the com-
ments filed and have concluded that applications for remote control
will be considered upon a case-by-case basis and granted upon a satis-
factory showing that the directional antenna system is stable and is in
proper adjustment. On the basis of the comments filed and our expe-
rience with the problems of directional antenna systems, we have deter-
mined that the basic information necessary to establish the stability
and proper adjustment of a directional antenna system, and hence, the
information which we will require as part of an application to operate
a directional antenna by remote control is as follows: 3
(a} A statement describing the stability of the system for the preceding one
year period. This statement shall include, but shall not be limited to, such
information as the nature and degree of adjustment required, the maintenance
procedures followed and the adequacy of the present monitoring system to indi-
cate changes in the operation of the array.
(b) Weekly readings of field intensity at each monitoring point specified in
the station license for the preceding 1-year period. {Monthly readings will be
acceptabie for those stations which are presently authorized to measure moni-
toring points field intensities on a monthly basis.)
fe) Readings once each day of antenna base currents (for each pattern) and
readings taken at approximately the same time of common point current, phase
monitor loop sample currents or remote base currents, und phase indications
for the preceding 30 days.
(d} A redetermination of the common point impedance of the directional
system.
: tial proof-performance consisting of at least 9 or 10 measure-
taken at a distance of from 2 to 10 miles from the antenna on each radial
‘ed in connection with the last complete adjustment of the directional
antenna system, properly analysed in accordance with section 3.186.
26. In its petition, NARTB proposed that a station authorized to
operate with a directional antenna and/or with a power in excess of
10 kw. may operate by remote control only if equipped so that it can
be operated on a CONELRAD frequency and the necessary switching
from the station frequency to the CONELRAD frequency can be ac-
complished from the remote control position. We are of the opinion
that the adoption of such a proposal would not necessarily be a de-
parture from the concept that CONELRAD participation is on a
vol ‘y basis. It should be noted that all stations whether or not
opera by remote control must be so equipped so as to be able to
foliow the prescribed CONELRAD alerting procedure set forth in
the CONELRAD Mannal for Broadcast Stations. Therefore,
CONELEAD operation is both mandatory and voluntary, i. e., partici-
pation of all broadcasting stations is mandatory to the extent that
regular operation of the station must cease after the transmission of
the required radio alert message, whereas stations may, upon a volun-
tary basis and after approval of the Commission, operate during a
2A re
‘ised Form 301—A will be provided in the near future.
23 F.C. C.
464 Federal Communications Commission Reports
CONELRAD alert to maintain contact with and disseminate infor-
mation to the public. Such stations participate in the CONELRAD-
system and operate in accordance with the CONELRAD rules. Sta-
tions licensed to operate with higher power and/or directional antenna
form the hard core of the CONELRAD system. We realize that in
some cases a moderate expenditure might be required to enable these
stations to continue in the CONELRAD system with remote control
switching. While it is believed that no material number of stations
would drop out of the plan because of the necessity of these expendi-
tures, we feel that the public and national interest requires the con-
tinued success of the CONELRAD plan and the Emergency Broad-
casting System. Therefore, we believe that we are justified
in conditioning an authorization for remote control of a station op-
erating with a directional antenna and/or a power im excess of 10 kw,
upon the installation of equipment that would permit the changeover
from the licensed operation to CONELRAD operation to be made
from the remote control point. Accordingly, the request of NARTB
is being adopted and therefore the counterproposal submitted by
IBEW must be denied.
27. We realize that some existing stations are not required to make
field intensity measurements at their monitoring points even though
their licenses specify monitoring points at which the field intensity
is not to exceed a specified value. Several parties commented that in
such instances we should not make these stations take monitoring
point readings for a year before authorizing their operation by remote
control. We believe that the use of monitoring pomt readings is one
method of determining if an array is stable. Furthermore, we do
not see how a licensee could determine whether the field intensity at
the monitoring points was exceeded unless measurements were taken at
various intervals. We are therefore requiring stations to submit moni-
toring point readings for the year previous to their application for
remote control.
98. Some directional antenna stations authorized prior to 1940
were not required to install phase monitors although some stations
have installed phase monitors since that time. The remainder of such
stations, if they desire to operate by remote control, must. install a
phase monitor in order to submit the required 30-day readings.
29. In order to insure that the operation, by remote control, of a
station utilizing a directional antenna will not result in deviations
from our technical rules or from the station license we have concluded
that stations authorized to operate a directional antenna by remote
control must: (a) make a proof of performance of the directional
antenna system, consisting of from three to four measurements on:
each radial, once each year as part of the presently required equip-
ment performance measurements and must submit the results of these:
measurements, plus the monitoring point readings, with each license
renewal application, (b) read and log each half hour, at the remote
control point, the common point current and the remote indications
of base current for each tower of the directional system. (c) Read
and log, at the transmitter location, once each day for each pattern
(within 2 hours of operation with that pattern) common point cur-
23 F.C. C.
Amend. Broadcast Rules Re Remote Control Operations 465
‘rent, base currents, phase monitor loop sample currents, or remote
base curents, and phase indications. .
30. With further reference to the questions raised in its notice of
proposed rulemaking, and in consideration of the comments received,
we have determined that:
(a) No change is required in section 3.39 (h) with respect to automatic
logging devices,
(b) Section 8.89 (d) (8) is being amended to permit the use of semiconductor
devices in addition to vacuum tube rectifiers.
(c) Present rules which require the jogging of. antenna current and fre-
quency are adequate to insure maintenance of power and frequency within the
limits preseribed. It is deemed desirable. however, to amend the rules to
provide that stations operating by remote control shall continuously monitor
the percent of modulation or shall be equipped with an automatic device to
limit the percent of modulation to 100.
(d) It is not necessary to require the installation of equipment to turn off
the transmitter when it fails to function within the tolerances prescribed but
the present remote control rules are being clarified to provide that defective
operation of the remote-control equipment and associated line circuits resulting
in improper control or inaccurate meter readings will require the immediate
cessation of operation by remote control.
(e) Remote meters must be calibrated once each week as required by the
present rules and the results thereof entered in the operating log. Meters
installed at the remote control point to imdicate antenna base current and
common point current may utilize arbitrary scale divisions provided a calibra-
tion curve showing the relationship between the arbitrary scale and the scale
-of the base and common point meters is maintained at the remote control point.
31. Although we are not requiring that the tower currents as indi-
cated by a phase monitor be read and logged at the remote control
point, we do agree with the suggestion that the present rule with
respect to the use of a phase monitor at the transmitter to determine
the ratio of antenna currents should be revised to reflect current prac-
tice and are so amending section 3.39. We do not agree with the
suggestion that a rule should be adopted which would permit the
reading and logging of phase monitor sample currents in lieu of
base currents provided base currents are read and logged once weekly.
Section 3.39 (d) (1) (v) provides for the use of a phase monitor in
obtaining remote indications of the tower currents but does not state
how often the base currents must be read and logged. The station
license in most cases specifies that the sample loop currents may’ be
used provided base currents are read once a day. Upon a showing,
this condition has been changed, on a case-by-case basis, to using base
currents once a week. No evidence was submitted to convince us that
our present practice in this regard should be changed. S
32. Both the ACA and NABET urge that the Commission. order
an evidentiary hearing to determine the facts and also to conduct
investigations to determine whether or not the malfunction of equip-
ment has increased or decreased under remote control, whether or
not CONELRAD is operating properly and that further considera-
tion be given to doing away with the existing remote control authori-
zations, The Commission may in its discretion, grant the subject
request for further proceedings if sufficient reason therefor be made
to appear (section 405). We do not believe, however, that such
sufficient reason has been demonstrated. All interested parties have
23 F. C.C.
466 Federal Communications Commission Reports
been afforded ample opportunity to file written conunents and numer-
ous comments have been received. It does not appear that an eviden-
tiary hearing would serve any useful purpose nor would it be of
material assistance to us. Accordingly, the requests for an eviden-
tiary hearing are denied.
38. Authority for the adoption of the amendments herein is con-
tained in sections 4 (i), 303 (b), (e), (g), and (r) of the Communi-
cations Act of 1934, as amended.
34. In view of the foregoing, Z¢ is ordered, That effective October
25, 1957, part 3 of the rules and regulations /s amended as set forth
in the attached appendix.
APPENDIX
1. Section 3.39 is amended as follows:
A. That portion of paragraph (Bb) preceding subparagraph (1) is changed to
read as follows:
(b) Instruments indicating antenna current, common point current, and base
currents shall meet the following specifications :
B. Paragraph (c) is changed to read as follows:
(c) A thermocouple type ammeter meeting the requirements of paragraph
(b) of this section shall be installed in the antenna circuit so as to indicate the
antenna current. In the case of directional antennas the same type of am-
meters shall be installed to indicate the common point current and the base
current of each tower. (The ammeter may be so connected that it is short cir-
enited or open circuited when not actually being read. If open circuited. a
make-before-break switch must be employed. }
C. Paragraph (d) is changed to read as follows:
(d) Remote reading antenna ammeter (s) may be employed and the indications
logged as the antenna current, or in the of directional antenna, the com-
mon point current and base currents, in accordance with the following :
(1) Remote reading antenna, common point or base ammeters may be pro-
vided by :
(i) Inserting second thermocouple directly in the antenna circuit with remote
leads to the indicating instrument.
(ii) Inductive coupling to thermocouple or other device for providing direct
current to indicating instrument.
(iti) Capacity coupling to thermocouple or other device for providing direct
current to indicating instrument.
(iv) Current transformer connected to second thermocouple or other device
for providing direct current to indicating instrument.
(v) Using transmission line current meter at transmitter as remote reading
ammeter. See subparagraph (7) of this paragraph.
(vi) Using indications of phase monitor for determining the antenna base
currents or their ratio in the case of directional antennas, provided that the
base current readings are read and logged in accordance with the provision of
the station license, and provided further that the indicating instruments in the
unit are connected directly in the current sampling circuits with no other shunt
circuits of any nature. The meters in the phase monitor may utilize arbitrary
scale divisions provided a calibration curve showing the relatiouship between
the arbitrary scale and the scale of the base meters is maintained at the trans-
mitter location.
(vii) Using indications of remote control equipment provided that the indi-
eating instruments are capable of being connected directly into the antenna
circuit at the same point as, but after, the antenna ammeter. The meter (s)
in the remote control equipment may utilize an arbitrary scale division pro-
vided a calibration curve showing the relationship between the arbitrary seale
and the scale of the antenna ammeter is maintained at the remote control point.
The meter(s) in the remote control equipment must be calibrated once a week
against the regular meter and the results theréof entered in the operating log:
(2) Remote ammeters shall be connected into the antenna cirenit at the same
point as, but after, the antenna ammeter (s), and shall be calibrated to indicate
23 F.C. C.
Amend. Broadcast Rules Re Remote Control Operations 467
within 2 percent of the regular meter over the entire range above one-third or
one-fifth full scale. See paragraphs (b) (1) (i), (iii) and (b) (2) (i), (iii) of
this section.
(3) The regular antenna ammeter, common point ammeter, or base current
ammeters shall be above the coupling to the remote meters in the antenna
circuit-so- they do not read the current to ground through the remote meter (s).
(4) All remote meters shall meet the same requirements as the regular an-
tenna ammeter with respect to scale accuracy, etc.
(5) Calibration shall be checked against the regular meter at least once a
week.
(6) All remote meters shall be provided with shielding or filters as necessary
to prevent any feed-back from the antenna to the transmitter.
(7) In the case of shunt excited antennas, the transmission line eurrent meter
at the transmitter may be considered as the remote antenna ammeter provided
the transmission line is terminated directly into the excitation circuit feed
line, which shali employ series tuning only (no shunt circuits of any type shall
be employed} and insofar as practicable, the type and scale of the transmission
line meter should be the same as those of the excitation circuit feed line meter
(meter in slant wire feed line or equivalent).
(8), Remote reading antenna ammeters employing vacuum tube rectifiers or
semiconductor devices are acceptable, provided :
(i) The indicating instruments shall meet all the above requirements for
linear scale instruments.
Gi) Data are submitted under oath showing the unit has an overall accuracy
of at least 2 percent of the full scale reading.
(iii) Tbe installation, calibration, and checking are in accordance with the
requirements of this paragraph.
2. Section 3.56 is amended by adding the following new paragraph (d):
(a) Each station operated by remote control shall continuously, except when
other readings are being taken, monitor percent of modulation or shall be
equipped with an automatic device to limit percent of modulation on negative
peaks to 100.
3. Add following sec. 3.65 a new undesignated center heading to read as
follows :
REMOTE CONTROL
4. Delete §3.66 and substitute the following:
§8.66 Remote control authorization. (a) Application to operate a station
by xemote control way be made as a part of the application for construction
permit for a new station, provided that the proposal is for nondirectional oper-
ation with a power of 10 kw. or less.
(b) Application to operate an authorized station by remote control shall be
made on FCC Form 301—A.
(c) An authorization for remote control will be issued only after a satisfac-
tory showing has been made in regard to the following, among others :
(1) the location of the remote control point(s) ;
(2) the directional antenna system, if such is authorized, is in proper ad-
justment and is stable;
(3) the transmitter, if the power rating is in excess of 10 kw. is reliable and
capable of being operated by remote control.
(4) the station, if authorized to operate with a directional antenna and/or
with power in excess of 10 kw. will be equipped so that it can be satisfactorily
operated, in accordance with subpart G of this part, on a CONELRAD frequency
with a power of 5 kw. or not less than 50 percent of the maximum licensed power
whichever is the lesser and that the necessary switching from the licensed fre-
quency to the CONELRAD frequency can be accomplished from the remote con-
trol position.
5. Add the following new section 3.67 which is derived from old sec. 3.66:
Sec. 3.67 Remote control operation, (a) Operation by remote control sball
be subject to the following conditions:
(1) The equipment at the operating and transmitting positions shall be so
installed and protected that it is not accessible to or capable of operation by
persons other than those duly authorized by the licensee.
23 F.C. C.
468 Federal Communications Commission Reports
(2) The control circuits from the operating position to the transmitter shall
provide positive on and off control and shall be such that open circuits, short
circuits, grounds or other line faults will not actuate the transmitter and any
fault causing less of such control will automatically place the transmitter in
an inoperative position.
(3) A malfunction of any part of the remote control equipment and asso-
ciated tine circuits resulting in improper control or inaccurate meter readings
shall be cause for the immediate cessation of operation by remote control.
(4) Control and monitoring equipment shall be installed so as to allow the
licensed operator at the remote control point to perform all the functions in a
manner required by the Commission's rules.
(5) The indications at the remote control point of the antenna current meter
or, for directional antennas, the common point current meter and remote base
current meters shall be read and entered in the operating log each half hour.
(6) The indications at the transmitter, if a directional antenna station, of
the common point current, base currents, phase monitor sample loop currents
and phase indications shall be read and entered in the operating log once each
day for each pattern, These readings must be made within 2 hours after the
commencement of operation for each pattern.
(b) All stations, whether operating by remote control or direct control, shall
be so equipped, in accordance with sec. 3.932, so as to be able to follow the
prescribed CONELRAD alerting procedure set forth in the CONELRAD Manual
for Broadcast Stations.
(c) A station, operating with a directional antenna and/or with power in
excess of 10 kw. shall be so equipped that a shift from the licensed operation to
an operation in the CONELRAD system can be accomplished from the remote
control position.
6. Add the following new sec, 3.68:
Sec. 3.68 Remote control renewal application. (a) An application for re-
newal of a remote control authorization may be made on the application for
renewal of station license.
(b) Stations employing directional antenna and operated by remote control
shail make a skeleton proof of performance each year, consisting of three or
four measurements on each radial used in the original application and must
submit the results of these measurements, plus the monitoring point readings,
with the renewal application.
T. Section 3.111 is amended by adding the following new» subparagraph (5) to
paragraph (b) and renumbering the present subparagraph (5) as subparagraph
(6). As amended, subparagraphs (5) and (6) read as follows:
(5) Any other entries required by the instrument of authorization.
(6) Log of experimental operation during experimental period. (If regular
operation is maintained during this period, the above logs shall be kept.)
(i) A log must be kept of all operation during the experimental period.
If the entries required above are not applicable thereto, then the entires shall
be made so as to describe the operation.
8. Delete sec. 3.274 and substitute the following :
Src. 3.274 Remote control authorization. (a) Application to operate a sta-
tion by remote control may be made as a part of the application for construc-
tion permit for a new station. Application to operate an authorized station
shall be made on FCC Form 301-A.
(b) An authorization for remote control will be issued only after a satisfac-
tory showing has been made in regard to the following, among others:
(1) The location of the remote control point(s) ;
(2) The transmitter, if the power rating is in excess of 10 kw., is reliable
and capable of being operated by remote control.
9. Add the following new section which is derived from old sec. 3.274:
Seo. 3.275 Remote control operation. (a) Operation by remote control shall
be subject to the following condition
(1) The equipment at the operating and transmitting positions shall be so
installed and protected that it is not accessible to or capable of operation by
persons other than those duly authorized by the licensee.
(2) The control circuits from the operating position to the transmitter shall
provide positive on and off control and shall be such that open circuits, short
23 F.C. C.
Amend. Broadcast Rules Re Remote Control Operations 469
circuits, grounds or other line faults will not actuate the transmitter and any
fault causing loss of such contrel will automatically place the transmitter in
an inoperative position.
(8) A malfunction of any part of the remote control equipment and associated
line circuits resulting in improper contro! or inaccurate meter readings shall be
the cause for the immediate cessation of operation by remote control.
(4) Control and monitoring equipment shall be installed so as to allow the
licensed operator at the remote control point to perform all the functions in a
manner required by the Commission’s rules.
(b) All stations, whether operating by remote control or direct control, shall
be so equipped, in accordance with sec. 3.932, so as to be able to follow the
prescribed CONELRAD alerting procedure set forth in the CONELRAD Manual
for Broadcast Stations.
10, Delete sec. 3.572 and substitute the following:
Sec. 3.572 Remote control authorization. (a) Application to operate a sta-
tion by remote control may be made as a part of the application for construction
permit for a new station. Application to operate an authorized station shall
be made on FCO Form 301-A.
(b) An authorization for remote control will be issued only after a satisfac-
tory showing has been made in regard to the following, among others:
(1) The location of the remote control point(s) ;
(2) The transmitter, if the power rating is in excess of 10 kw., is reliable and
capable of being operated by remote control.
11. Add the following new section which is derived from old sec. 3.572:
Src. 3.573 Remote control operation. (a) Operation by remote contro] shall
be subject to the following conditions:
(1) The equipment at the operating and transmitting positions shall be so
installed and protected that it is not accessible to or capable of operation by
persons other than those duly authorized by the licensee.
(2) The control circuits from the operating position to the transmitter shail
provide positive on and off control and shall be such that open circuits, short
circuits, grounds or other line faults will not actuate the transmitter and any
fault causing loss of such control will automatically place the transmitter in
an inoperative position.
(3) A malfunction of any part of the remote control equipment and asso-
ciated line circuits resulting in improper control or inaccurate meter readings
shall be cause for the immediate cessation of operation by remote control.
(4) Control and monitoring equipment shall be installed so as to allow the
licensed operator at the remote control point to perform all the functions in a
manner required by the Commission’s rules.
(b) All stations, whether operating by remote control or direct control, shall
be so equipped, in accordance with sec. 3.932, so as to be able to follow the pre-
scribed CONELRAD alerting procedure set forth in the CONELRAD Manual
for Broadcast Stations.
23 F. C.C.
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