Keep this bad boy tuned up … and check your state regulations to make sure you don’t encounter unexpected limitations in running it. credit: WPWX(FM), courtesy Crawford Broadcasting

The purpose of the article is to make you aware that state environmental regulations may limit use of your station’s generator in certain circumstances, and how that issue is playing out in one particular state.

Most broadcasters are familiar with FCC Rules and Regulations. The FAA maintains jurisdiction over tower construction. These two agencies are familiar to broadcast engineers. Other government agencies regulate disposal of PCB-laden components and hazardous materials. Facilities must adhere to Americans With Disabilities (ADA) regulations, building, fire and electrical codes.

Generators used during commercial power outages must be wired in accordance with the National Electrical Code (NEC) by a licensed electrician and installed in compliance with local regulations. The fuel supply must adhere to state and local codes. The generator must be located a certain distance from an occupied structure and protected from accidental vehicular contact. The same considerations apply to propane or above-ground fuel storage tanks.

Generators employed by broadcasters can vary widely in generating capacity. A studio site generator may only power sufficient equipment to remain on the air or it can power the entire facility, inclusive of heat and air conditioning. Facilities with multiple stations can further increase the need for a larger generator. A transmitter site generator may be sized to accommodate one or more transmitters, environmental machinery, tower lights, etc. Sites with more than one station may share a generator or there may be individual generators for each broadcaster. Different fuel types may also be used. Some generators also exercise at half-speed on no load.

Generators must be at the ready to supply power when the commercial power fails. One common method to ensure proper operation is to exercise the generator on a regular basis. This may or may not involve placing a load on the generator. At unattended transmitter sites this process is usually automated by a timer in the transfer switch. The generator is programmed to start and run for a period of time. Typical periods are weekly for 30 to 60 minutes. The generator’s voltage and frequency can be locally or remotely monitored.

Unintended consequences

In July 2012, Michael C. Rice, president of the Connecticut Broadcasters Association, received an inquiry from the chief engineer of a station.

The engineer related how he had been in the process of starting up the transmitter site emergency generator, in anticipation of power outages likely to be caused by severe thunderstorms heading into the area, when he received a visit from a Connecticut Department of Energy and Environmental Protection field inspector.

The DEEP inspector informed the engineer that on days for which the DEEP forecasts “ozone air quality index levels classified as unhealthy for sensitive groups (USG, or worse) anywhere in Connecticut,” an emergency generator can only be operated — whether in anticipation of outages or for routine testing — when there is an emergency, e.g., when there is in fact a power loss. The inspector also informed him the station should be keeping logs on its generator operation.

Research confirmed the field inspector’s assertions to be generally correct, though generators with less than 3 million BTU hours’ output are exempt from record-keeping and compliance plan requirements. (Much of the information here is from minutes of the CBA board meetings.)

In October, a public hearing was held to consider amendments to Section 22A-174-22 of the regulations of Connecticut State Agencies.

The proposed amendments would permit nuclear and healthcare facilities (and construction sites when construction interrupts power supply to the site) to operate their generators on days with unhealthy air quality index levels in order to maintain proper power levels. However, the proposed amendments do not include testing and maintenance of broadcasters’ generators.

Jeffrey R. Hugabonne, an SBE member and chief engineer for a major radio station in Connecticut, testified at the hearing on behalf of the CBA. Hugabonne pointed out that all broadcasters are required to install and keep operational Emergency Alert System equipment and use it to participate in EAS national alerts. Additionally, virtually all stations participate in alerts activated by state officials and the National Weather Service through the Connecticut State EAS Plan.

Hugabonne further noted that the combined emergency generator emissions ofallbroadcast stations statewide is significantly less than those of individual industrial buildings, power plants and institutional facilities. Thus, he concluded, broadcasters too should be exempt from the restriction on gen use during bad air days.

In light of these facts the CBA proposed the following amendment:

Add to Section 2 as Section 22a-174-22(c)(2)(D) the following:
(D)To test and anticipatorily start up emergency power for production operations and transmission of Federal Communications Commission-licensedradio and televisionoperators (whether broadcast, cable or satellite) so as to assure such operators suffer no interruption in production or transmission if a power outage occurs.

According to Elizabeth McAuliffe of the Connecticut DEEP, “At this point the proposal is still just that, unless and until it is approved by the Legislative Regulation Review Committee and the Secretary of State’s Office.”

It would be wise for Radio World readers to investigate their state regulations to see if similar restrictions are in place. If so, consider seeking relief through state broadcasters association.

Officials rely on the media to advise the public of hazardous materials incidents, road closures, weather hazards and other safety issues as well as Amber and Silver alerts. Broadcasters must have power to be able to broadcast under all conditions. Exercising power generators is an essential ingredient to ensuring this equipment is up to the task.

Tom Osenkowsky is a radio engineering consultant in Brookfield, Conn., and a longtime RW contributor.