December 16, 2025
by John Baich, SECC Chair & CBA ABIP Inspector
Sangre de Cristo Broadcast Consulting, LLC
A recurring issue identified during inspections is confusion regarding the role and regulatory requirements of the Station’s Chief Operator. While some Chief Operators are fully compliant with FCC rules, others are unaware of their obligations, with many falling somewhere in between. Ultimately, the Chief Operator serves as the station’s primary point of contact with the FCC and is accountable for technical compliance.
Pursuant to 47 CFR § 73.1870, all broadcast stations—AM, FM, TV, and Class A TV—must designate a Chief Operator in writing. This designation must be posted with the station license at all designated control points, including the main studio, transmitter site, and, where applicable, any hub designated as a control point with the FCC. An alternate or temporary acting Chief Operator must also be designated in writing to cover periods when the primary Chief Operator is unavailable. It is critical that any individual serving in this capacity be properly trained to perform the required duties.
Chief Operators for all television stations, directional AM stations, or AM stations licensed for power greater than 10 kW must be station employees. Non-directional AM stations licensed for less than 10 kW, as well as all FM stations, may designate either a station employee or a contract engineer as Chief Operator. When a contract engineer serves as Chief Operator, a copy of the agreement must be retained in the station’s files; however, it is not required to be posted with the station license.
Core Responsibilities of the Chief Operator
- Serve as the primary technical point of contact with the FCC.
- Ensure inspections, calibrations, and repairs of transmission systems, performance monitors, metering, and control systems are conducted as required to maintain licensed FCC performance compliance (see 47 CFR § 73.1580).
- Conduct or oversee periodic AM field strength monitoring point measurements. Where authorized, a certified and calibrated FCC-approved antenna monitor may be used (see 47 CFR §§ 73.1820, 73.51(e), 73.53, 73.61, 73.62, and 73.68).
- Perform a weekly review of station records. This is the most frequent compliance deficiency observed in the field. The Chief Operator or Alternate Chief Operator must review, take corrective action as necessary, and sign and date the following records each week:
- EAS Logs: Each station must transmit a Required Weekly Test (RWT) and receive an RWT from each assigned monitoring source (LP-1, LP-2, IPAWS/CAP, and NWS). Any failure to send or receive an RWT must be documented with the cause and corrective action taken. Stations must also receive and relay the Required Monthly Test (RMT) as scheduled in the State Emergency Communications Plan and as published by the state broadcast association. If you choose, forwarding the RMT supplants the need to originate a RWT that broadcast week.
- Transmitter Logs: Including power levels, tower lighting status, mode changes, and other required parameters.
- Conduct periodic reviews of transmitter maintenance logs, quarterly tower lighting tests, and other required technical records.
A common question is: “If our workflows are entirely electronic, do we still have to complete weekly reviews?” The answer is yes. Weekly reviews are still required, and the station must be able to verify that the review was completed by the Chief Operator or Alternate Chief Operator within the seven-day window. A serialized electronic signature is acceptable, provided the station can demonstrate that the signature belongs to the designated Chief or Alternate Chief Operator. Electronic systems such as DocuSign may be used, provided records are retained in an accessible format (e.g., PDF), and hard copies may also be maintained. All such records must be retained for a minimum of two years, or longer if an FCC inspection or investigation is underway.
References
• 47 CFR § 73.1870 – Chief Operator
• Title 47, Code of Federal Regulations
