FCC Form 301

FM does it with frequency!
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FCC Form 301

Post by smalltownbroadcaster » Thu Nov 03, 2016 6:55 am

During a routine self inspection of our station, I came to the realization that our FCC license is slightly incorrect with our transmitter location Lat / Long. It is off by about 5 seconds of arc. It appears that the original ASRN for the tower (not owned by us) is off, and that's what was used for the original construction permit.

WIth that being said, we need to file a modification. Can anyone tell me if this is a simple form 301 filing? Or is it more complicated than that, requiring a new construction permit, and then a new 301? I try to stay 'out' of filing as much as possible, so if anyone has experience and wants to submit a bid to do this, please pm me.

Thank you

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Re: FCC Form 301

Post by grich » Thu Nov 03, 2016 9:51 am

Be sure the coords are really off. Remember the ASR coords are in NAD83, and the broadcast license coords are NAD27.

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Re: FCC Form 301

Post by Deep Thought » Thu Nov 03, 2016 9:56 am

Assuming that the coordinates are truly incorrect (see grich's comment about that above) the FCC 301-AM to correct the coordinates 5 seconds is a simple, non-fee application you can fill out and file online yourself. Just put "coordinate correction" in the 'other' box where it asks about being fee exempt on section I #3.

If the ASRN is incorrect you're going to have to deal with it first, and THAT involves going through the FAA approval process again.
Mark Mueller • Mueller Broadcast Design • La Grange, IL • http://www.muellerbroadcastdesign.com

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Re: FCC Form 301

Post by TPT » Thu Nov 03, 2016 1:22 pm

If the difference in coordinates would be found to be less than 3 seconds in either latitude or longitude (or both), this is a minor change under Section 73.1690(c)(11):

(11) Correction of geographic coordinates where the change is 3 seconds or fewer in latitude and/or 3 seconds or fewer in longitude, provided there is no physical change in location and no other licensed parameters are changed. The correction of coordinates may not result in any new short spacings or increases in existing short spacings.

This used to be an option under form 302. However the present version of the form doesn't seem to allow this, which would seem to require filing the 301, as well as the FAA for 7460 and changing the information on the ASRN. This could get sticky if you don't own the tower.

If the difference in coordinates is actually more than 3 seconds in latitude and longitude (and I would recommend hiring a surveyor to verify this, as well as verify the actual AMSL at the site) you will need to file a 301. If the site elevation is off, and this is an FM, it could then effect the licensed ERP of the station.

Then you will probably be better off hiring a consulting engineer to handle the paperwork. Many problems can crop up. For example, if the station is an FM non-com, then you will probably need to demonstrate the proposed change in coordinates does not create a prohibited overlap with another station's contours (see Section 73.509). Same with an AM station. If this is a commercial FM station, it's easier--you will just need to demonstrate that the new coordinates meet the minimum spacing requirements of Section 73.207. "Preliminary FM Survey" on the FCC.Gov site allows you to enter the coordinates and frequency & get a list of stations & distances from these coordinates.

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