TOH Legal ID

Anyone Know If WRCN 103.9 Riverhead . is it Currently owned or used to be owned BY JVC know if they have some sort Of STA( just kidding about STA) that allows them to Get away with ZERO
I mean No TOH ID of any sort.
I was out on the east End over the weekend. interesting Automated Format.. shows ran a few mins past the TOH then traffic/ Weather or Music back to another show. Not Once in 2 days
did I hear a TOH ID except LINews..???
dfid the FCC change the Rules For this station?
Neal.

Same issue out here in ABQ. 102.1 which is an LPFM, and live, mentioned the frequency and call sign several times in the half hour I listened (before and after the TOH) but never mentioned the COL.

Why not mention it to the FCC? I bet they'd love to hear about it.

I agree, tell the FCC.

Legal IDs are to be at a natural break in programming as close to the top of the hour as you can get. The call letters and city of license (with few exceptions) in that order without anything inbetween. For LPFMs that would be KXXX-LP, City of License.

The question up for debate is what constitutes a natural break in programming? Many larger market station hide the ID inside the final commercial break of the hour, around :45 past the hour although the DJ might speak at or near the top of the hour. So, the ID is intentionally 'hidden'.

Interestingly one FM in Texas was licensed to a tiny town but studios and everything they did was geared to a large nearby town. They edited the space between the call letters and city of license so it went by so fast even if you tried, you would be hard pressed to catch the call letters and city of license. I call it a loophole. The FCC does not say you can't do it fast (like the disclaimer on a car commercial).

DavidEduardo said:

There is no FCC term "top of the hour ID". There is a requirement to give an ID as close to :00 each hour in a natural break in programming, as already mentioned. Some believe... and more important, the FCC has never stopped such a belief... that a natural break is NOT in between songs in a music sweep. So the ID can go at the end of the last stopset of the hour, often around :50, not at the real "top of the hour".

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I listened for 2 days. Finally I had to go to the FCC site and Do a Search for Riverhead,NY and Found the Calls for 103.9... Not even hidden in a Natural break . Nothing within the window of 10 before through 10 after the TOH is Considered Normal.. I even thought maybe the Clocks were way off on the automation... But commercial breaks were exactly at the TOH..

If you really want to hide the TOH ID, I believe it may still be in the FCC regulations that you can do the ID in morse

When you file your complain, include tapes from off the air. Give them what you heard. Leave it up to them. That's their job.

WXXL-FM in Orlando also does this too (I know they are not in NYC, but it's also happening in Orlando). They hide their TOH ID at :45-50 every hour and at the top of the hour, they air a jingle of XL 106.7, instead of the legal ID. The thing is, they are owned by iHeart.

What you describe with WXXL is commonplace among major market stations. They've been doing it for years.

I don't understand this 'turn them into the FCC'-thinking. I've been in this business a long time, and turning in a fellow broadcaster, public, LPTV, LPFM, translator licensee, whatever, has always been considered the last resort. And this from someone who doesn't particularly think LPFM is worthwhile.

Rather than being a d**k about it, why not contact the station and let them know you've noted that they don't seem to be running legal station ID's?

How strict is the FCC on enforcement when it does receive a complaint? Staying on Long Island, WPPB Southampton often airs improper IDs on weekends, when volunteers host specialty music shows. There a man who plays jazz who consistently gets the wording wrong, inserts ad-libbed liner-type material ("Your community public radio station for eastern Long Island!") between call letters and COL, that sort of thing. For whatever reason, WPPB allows all air staff to do IDs live rather than running recorded IDs at the top of the hour as many other non-comms do, especially ones with long lists of translators to recite. The pros who do the weekday programming know the drill by heart, the weekenders tend to improvise. (And try telling a jazz enthusiast that improvisation is bad!)

CTListener said:

How strict is the FCC on enforcement when it does receive a complaint?

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Here's a recent example: An LPFM in the Seattle area was supposedly-unknowingly broadcasting that "F"-Trump rap repeating it over and over for about a week. That, and the station was broadcasting only the obscenity-laden lyrics without even program test authority under a C.P. I know several complaints went into the FCC field office in Los Angeles in one day. The church where the station is located was tipped off and notified the CP holder outside the area. So no license, broadcasting obscene content for roughly a week. Even with all that, no action has been taken. And yes, the station has started broadcasting again without the rap, but still with no license to cover application on file.

Kelly A said:

I don't understand this 'turn them into the FCC'-thinking.

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My point was why post it on a message board? If it's an issue for the IP, take it to the responsible people.

Agreed. Why try to hurt the station? What's in it for you?

One thing I have learned is the FCC has an elephant's memory. Don't mistake inaction for no action. Before the FCC pounces, they have all their ducks in a row and usually have you with no wiggle room on anything. They're not a think we're right but rather we know we're right and can prove every single detail. Sometimes that takes a long time to line up just right but they are not pushed to act within a certain time frame. In many cases, an issue is settled by the FCC merely talking with the FCC and coming up with a remedy.

I recall a new subdivision going in behind our tower. At the closest homes we were bleeding through, messing with the cable TV picture, etc. The FCC merely phoned and asked if we could look in to it and if we'd be willing to help find a solution. We did and the FCC appreciated our cooperation...no visit, no letters, etc., just the most efficient way to clear up a problem that by law we actually weren't responsible for since we were there first. Our engineer found the solution and we helped homeowners convince the builder to apply the solution. Yes it cost a few dollars and some time but everyone was smiling in the end, so it was a great direction for us to go. Seems all the wiring in those homes was cheap and not shielded. Some cheap filters did the trick. I might add, if we had not been cooperative, the FCC might have had to visit us and they would not have been real happy having to do so. In other words, they're busy enough and if you can clean something off their plate, that's a good thing.

"That's for certain auxiliary services."

I can at least find the data for translators (don't know whether that counts as an auxiliary service).

From FCC Part 47, Section L (translators), 74.1283 (2), edited .. (2) By transmitting the call sign in International Morse Code at least once each hour.

In spite of the fact LPFM's technically fall under Auxiliary Service like translators, they are required to ID the same as full-class stations. Translators are allowed to CW ID because they should be re-broadcasting a station that does their own station ID. Also, translators aren't required to ID each hour, that's why you'll commonly hear stations with a bunch of translators play a prerecorded ID, which includes all the translators rebroadcasting that station, and their individual ID's twice per broadcast day.

A few years ago I was building a new 6 tower 50kW AM DA1. I was planning on doing some full power directional and non directional tests during experimental hours, and thought it would be fun to do a continuous loop CW ID during the testing period at night. I notified one of the larger DXing clubs to be ready to listen, but was concerned doing the station ID CW may not satisfy the Commission' requirements for station ID. I called DC and asked for a clarification. The answer I got was interesting; they had never heard that request before, but in principal, didn't have any issue with running a CW ID on an MW station. Rather than giving me official approval however, they asked that I send them a letter notifying them that K** will be testing and identifying using Morse Code. That way if they received any complaints or concern when listeners hear CW on their radio, the Commission will have an answer.

Even better than that, FM Translators can identify using frequency-shift keying. Tune into your local translator and see if you can catch some "popping" near the top of the hour. Sounds very close to the "sub-audible" tones some sat services use.