FM Translator Filing Window, Ratchet Rule, FM Migration Among Issues In AM Comments

Broadcast engineering consultants du Treil Lundin supported the adoption of rule changes that can be used by AM stations to improve their flexibility in developing technical facilities to improve their coverage in the existing AM band (http://bit.ly/LUc9nD). It backed elimination of the daytime community coverage standards for existing AM stations. AM stations provide a very small segment of the electronically delivered audio content available to the public from an increasingly diverse number of over-the-air sources, said the firm. A radical change is called for “to allow them the flexibility to see normal business forces guide them in how to best serve their actual audiences,” it said.

As original petitioners for elimination of the “ratchet rule,” du Treil Lundin insisted the rule not be postponed “by inclusion in this larger proceeding.” That referred to the rule aimed at limiting nighttime interference. The AM antenna efficiency standards should be eliminated, it said. AM stations “should have complete flexibility in choosing tower height and ground system dimensions and normal business forces can be relied upon to influence their owners to seek optimum locations for serving their audiences,” du Treil said. It said the FCC’s concern should only be with the avoidance of interference to other stations, “something that can be safely addressed by requiring that allocation studies be based on minimum efficiency standards where actual radiation efficiency, whether due to lower height, ground system restrictions, or both, may be expected to be lower.” Du Treil also suggested that FCC rules allow the flexibility needed for AM stations to make choices about their transmitter site locations and antenna characteristics “to optimize coverage without regard to ‘on paper’ foreign overlap,” it said.

S-R Broadcasting, licensee of KRKO(AM) Everett, Wash., urged the FCC to support FM migration and remove all foreign ownership restrictions on the AM band. Doing so “may actually serve to enable distressed AM owners to realize a once-in-a-lifetime opportunity to resurrect their investments and bring new owners willing to invest in the band,” it said (http://bit.ly/1g1e8E2).

Some AM licensees said the proposal to create an opportunity for AM stations to obtain FM translators would help their stations better serve their coverage areas. North Carolina Central Broadcasters, owner of WCKB(AM) Dunn, N.C., supported having an FM translator filing window. Each translator should be locked into the AM license, “so the two may not be sold off individually,” it said (http://bit.ly/1kYAic8). NCCB said an FM translator would help the station compete with FM stations serving the Raleigh-Durham and Fayetteville designated market areas. Berkshire Broadcasting Corp., licensee of Connecticut AM stations WLAD Danbury, and daytime station WAXB Ridgefield, said an FM translator grant would allow WLAD to provide reliable 24/7 transmission, “and even more importantly, wider service to the market in the event of a nighttime emergency,” (http://bit.ly/1mtrFlq). MonsterMedia, licensee of KCYK(AM) Yuma, Ariz., also supported the filing window opportunity (http://bit.ly/1aLGJpk).

Bemidji Radio in Minnesota also supported a filing window for FM translators. The window “should be open for all AM stations and no AM daytime-only preference should be awarded,” it said (http://bit.ly/1aqWRC3). Bemidji doesn’t support relaxation of the ratchet rule “absent a similar relaxation in the night skywave protection requirements for all stations,” it said.

Opening an FM translator window will help expand the pool of cross-service translators “and allow more AM stations to provide enhanced service to more listeners and compete more effectively in today’s marketplace,” said NAB (http://bit.ly/1mHco3p). However, any AM station demonstrating financial hardship should be allowed to reassign or otherwise dispose of an FM translator obtained in this filing window, it said. NAB also supports eliminating the nighttime coverage standards.

Although Du Treil will support the translator effort, “we do not see FM translators as a universal avenue to revitalization of the AM radio service,” it said. FM translators “do nothing to improve or revitalize the AM broadcast band,” said Burt I. Weiner Associates, a provider of broadcast technical services (http://bit.ly/1c3KD0J). Many translators have a history of abuse “in that many operate very differently from the intended purpose of the translator rules,” it said. If FM translators are made available for AM stations, then the commission must make sure that the AM translator service is protected from abuse, it said. The rules should enforce that an AM translator is prohibited from carrying separate programming for any reason and should be non-transferable except by way of transfer of ownership with its parent AM, it said.

The AM digital transmission method in-band on-channel (IBOC) should be revisited, Weiner Associates said. It said that due to the nature of propagation in the AM broadcast band, IBOC “has proven itself to not be a reliable method of digital transmission at these frequencies and only adds to the list of interference sources to other licensees.” (klane@warren-news.com)