The lights are on, but we’re not home…

fcclogowordsFCC fines to broadcasters is nothing new.  Broadcasters have often tried to cut corners, hiring incompetent staff that cannot be bothered to report tower light outages, or simply not monitoring tower lights at all. Untrained operators who do not know the EAS rules, sloppy public files, unattended main studios, over power operation, etc.  Some AM stations have power changes as sunset and sunrise, most are now automated but who is checking the automation system to make sure the power changes?

The FCC does not have nearly enough field agents to monitor everything.  Most rules infractions never get discovered, like the translator operating at double its licensed power.  Or the FM station with the antenna at the wrong height on the tower.  It never ends.  When I first got into this business, I remember one FCC inspector that was going to issue a NOV (Notice of Violation) because the operator signed her name in red ink.  RED INK, by god!  It seems things have swung far in the other direction.

Fortunately for us, these infractions become public record, so we can all learn from other’s mistakes, right?

Here is the current crop of FCC fines being shuffled through the bureaucracy:

Clarion County Broadcasting Corp. the licensee of radio station WKQW in Oil City, Pennsylvania, apparently willfully and repeatedly violated Section 73.1745(a) of the Commission’s Rules by operating at times beyond the station’s post-sunset authorization. Clarion is liable for a forfeiture in the amount of four thousand dollars ($4,000.00). To determine whether WKQW was operating consistent with its authorization, an agent from the Philadelphia Office installed radio monitoring equipment in Oil City, Pennsylvania to record, on a continuous basis, the relative signal strength of WKQW’s transmission on the frequency 1120 KHz. The equipment was in place from October 28, 2008 to December 12, 2008.The agent reviewed and analyzed the radio transmission data recorded between October 28, 2008 and December 12, 2008, and found several violations. The agent determined that, between October 28, 2008, and October 30, 2008, the station operated after 8:30 p.m. local time, which is the end of the station’s post-sunset authorization during the month of October. The agent also determined from the recorded radio transmission data that, between November 1, 2008 and November 13, 2008 and between November 15, 2008 and November 25, 2008, the station operated past 7:00 p.m. local time, which is the end of the station’s post sunset authorization during the month of November. In response to an inquiry from Commission staff, the owner of Clarion confirmed that the station’s transmitter did not malfunction during the period between October 28, 2008 and December 12, 2008.

I find it interesting that the FCC has some sort of remote monitoring device that it can install and monitor an AM stations power levels. I wonder where they installed it.  I also have to wonder what it looks like.  Is it an outdoor unit, like something one might see attached to a utility pole, or an indoor unit, stashed away in an office somewhere.  Very curious, indeed.  If I were the station owner, I might ask to see the records that the automated recording device created.  That would seem to be a reasonable request.

Caron Broadcasting, Inc. licensee of station WKAT, in North Miami, Florida, apparently willfully and repeatedly violated Sections 73.1745(a) and 73.3526 of the Commission’s Rules by operating at times with power other than those specified in its license and failing to maintain and make available a complete public inspection file. Caron is liable for a forfeiture in the amount of eight thousand dollars ($8,000). We also admonish Caron for the failure of the station’s chief operator to review, sign and date the station logs on a weekly basis as required under Section 73.1870(c)(3) of the Rules.On January, 26, 2009, an agent from the Miami Office monitored WKAT’s transmissions from approximately 5:00 p.m. until 7:00 p.m. The agent made several field strength measurements of the station’s signal and observed no reduction in the transmissions’ field strength after sunset.On January, 27, 2009, an agent from the Miami Office monitored WKAT’s transmissions from approximately 5:25 p.m. until 6:45 p.m. The agent made several field strength measurements of WKAT’s signal and observed no reduction in the transmissions’ field strength after sunset. At 6:43 p.m., the agent made a field strength measurement of the station’s signal one block from the WKAT studio.

On February 5, 2009, at 11:01 a.m., an agent from the Miami Office made a field strength measurement of the station’s signal one block from WKAT’s main studio, which measured approximately the same level as the nighttime measurement that was made there on January 27, again indicating that WKAT was not reducing its power at night. The agent immediately conducted an inspection of WKAT’s main studio with the station’s general manager and designated chief operator. The chief operator stated that the station uses a remote phone monitoring system, which allows the caller to change from day mode (mode “2”) tonight mode (mode “1”). At 11:55 a.m., the chief operator called the transmitter using the remote monitoring system, which indicated that the daytime mode transmitter power was 4,758 watts. At the request of the agent, the chief operator switched the transmitter to nighttime mode, and the system indicated that the power was 316 watts. At 1:45 p.m., with the WKAT transmitter in nighttime mode, the agent made a field strength measurement near the WKAT studio which was much lower than the daytime mode measurement made earlier that day. This measurement confirmed that the station’s transmitter and transmitter remote control system were functioning properly.

Still on February 5, 2009, the agent inspected WKAT’s available daily transmitter logs, which showed that from December 4, 2008 until February 4, 2009, WKAT was not reducing power at night as required by its license. All the log entries made during the daytime and nighttime were in the range of approximately 4,600 to 4,900 watts, and indicated that the transmitter was in mode “2,” the day mode, at all times. The log entries for the early morning hours of February 5, 2009 indicated that WKAT was operating at nighttime power at that time. Neither the station manager nor the chief operator could explain why the power was not being reduced, or why or how the situation was corrected early that morning. The agent also found that none of the station logs were signed by the chief operator or by anyone else. There was apparently no verification of whether or not the station was operating with authorized power, and no initiation of any corrective action for the overpower condition that had been ongoing for several months. The agent also requested to inspect the station’s public inspection file and found that it did not contain the quarterly radio issues/programs lists for the 1st through 4th quarters of 2008. The station manager stated that he did not know where the issues/programs lists were, but that they may be in storage since WKAT moved its studio in August 2008.

They tracked that one down the old fashioned way, multiple visits at sunset to take field strength meter readings.  It seems like no one at this radio group knew anything about FCC requirements and rules. None of this is rocket science, really. These NAL’s are both over a year old.  I wonder why it is taking the FCC so long to get through this process?

Low Power FM, House passes H.R. 1147

The house passed the “LOCAL COMMUNITY RADIO ACT OF 2009 ” (aka HR 1147) last night in one of the last legislative acts of 2009.  This is the companion bill to S. 592, which is still in committee.

The need for LPFM stations is justified thusly:

  • In part due to consolidation of media ownership, there have been strong financial incentives for some companies to reduce local programming and rely instead on syndicated programming produced for hundreds of stations, though noncommercial educational radio stations, including FM translator stations, currently provide important local service, as do many commercial radio stations. A renewal of commitment to localism–local operations, local research, local management, locally originated programming, local artists, and local news and events–would bolster radio’s service to the public.
  • Local communities have sought to launch radio stations to meet their local needs. However, due in part to the scarce amount of spectrum available and the high cost of buying and running a large station, many local communities are unable to establish a radio station.
  • In 2003, the average cost to acquire a commercial radio station was more than $2,500,000.
  • In January 2000, the Federal Communications Commission authorized a new, affordable community radio service called `low-power FM’, or `LPFM’, to `enhance locally focused community-oriented radio broadcasting’.
  • Through the creation of LPFM, the Federal Communications Commission sought to `create opportunities for new voices on the airwaves and to allow local groups, including schools, churches, and other community-based organizations, to provide programming responsive to local community needs and interests’.
  • The Federal Communications Commission made clear that the creation of LPFM would not compromise the integrity of the FM radio band by stating, `We are committed to creating a low-power FM radio service only if it does not cause unacceptable interference to existing radio service.’.
  • Currently, FM translator stations can operate on the second- and third-adjacent channels to full-power radio stations, up to an effective radiated power of 250 watts, pursuant to part 74 of title 47, Code of Federal Regulations, using the very same transmitters that LPFM stations will use. The Federal Communications Commission based its LPFM rules on the actual performance of these translators, which already operate without undue interference to FM stations.
  • Small rural broadcasters were particularly concerned about a lengthy and costly LPFM interference complaint process. Therefore, in September 2000, the Federal Communications Commission created a process to address interference complaints regarding LPFM stations on an expedited basis.
  • In December 2000, Congress delayed the full implementation of LPFM until the Federal Communications Commission commissioned and reviewed an independent engineering study. This action was due to some broadcasters’ concerns that LPFM service would cause interference in the FM radio band.
  • The Federal Communications Commission granted licenses to over 800 LPFM stations despite the congressional action. These stations are currently on the air and are run by local government agencies, groups promoting arts and education to immigrant and indigenous populations, artists, schools, religious organizations, environmental groups, organizations promoting literacy, and many other civically oriented organizations.
  • After 2 years and the expenditure of $2,193,343 in taxpayer dollars, the independent engineering study commissioned by the Federal Communications Commission concluded that concerns about interference on third-adjacent channels were unwarranted.
  • The Federal Communications Commission issued a report to Congress on February 19, 2004, which stated that `Congress should readdress this issue and modify the statute to eliminate the third-adjacent channel distance separation requirement for LPFM stations.’
  • On November 27, 2007, the Federal Communications Commission again unanimously affirmed LPFM, stating in a news release about the adoption of the Low-Power FM Third Report and Order and Second Notice of Proposed Rulemaking that the Federal Communications Commission recommends `to Congress that it remove the requirement that LPFM stations protect full-power stations operating on third-adjacent channels’. Until the date of enactment of this Act, Congress had not acted upon that recommendation.
  • Minorities represent almost a third of the population of the United States. However, according to the Federal Communications Commission’s most recent Form 323 data on the race and gender of full-power, commercial broadcast licensees, minorities own only 7 percent of all local television and radio stations. Women represent more than half of the population but own only 6 percent of all local television and radio stations. LPFM stations, while not a solution to the overall inequalities in minority and female broadcast ownership, provide an additional opportunity for underrepresented communities to operate a station and offer local communities a greater diversity of viewpoints and culture.
  • LPFM stations have proven to be a vital source of information during local or national emergencies. Out of the few stations that were able to stay on the air during Hurricane Katrina, several were LPFM stations. In Bay St. Louis, Mississippi, low-power FM station WQRZ remained on the air during Hurricane Katrina and served as the Emergency Operations Center for Hancock County. After Hurricane Katrina, when thousands of evacuees temporarily housed at the Houston Astrodome were unable to hear over the loudspeakers information about the availability of food and ice, the location of Federal Emergency Management Agency representatives, and the whereabouts of missing loved ones, volunteers handed out thousands of transistor radios and established an LPFM station outside of the Astrodome to broadcast such information.

Similar to S. 592, the bill aims to:

  1. Increase the number of LPFM station by doing away with the 3rd adjacent protections.
  2. Mitigate interference by creating a 1 year period during which a new LPFM station must broadcast “periodic announcements that alert listeners that interference that they may be experiencing could be the result of the operation of the new low-power FM station on a third-adjacent channel and shall instruct affected listeners to contact the low-power FM station to report any interference.”  LPFM licensees are then tasked with solving interference complaints with in a licensed full power FM station’s protected contour.
  3. Protect translator input signals.
  4. Protect reading for the blind services.

I am not finding fault with any of the justifications, they are all true and make a good point about the decline of Radio in general as I have discussed in previous posts.

The potential increase of LPFM stations is in the thousands.

The proposed interference mitigation is a pipe dream.  The FCC enforcement bureau is overworked as it is.  We have had a pirate on one of our frequencies for years, every once in a while they drive out and bust the guy, only to have him return a week or two later.   Somehow this group of overworked people will be able to process hundreds or thousands of interference complaints?

Unless there is increased funding for the FCC enforcement bureau, I am skeptical.  There is no specific discussion on funding, only specifying that the cost should be below $139 million.

We live in interesting times.

Transmitter readings

I recently got into an argument about the requirements for transmitter readings with a fellow engineer.  Said fellow stated that transmitter readings need to be taken every three hours and that all operators needed to sign on and off the station log.  Time was when those things were supposed to be done, that is true.  I believe the rules have changed a little bit since he last read them.  The current FCC rules (part 73.1820) state that the following items need to be in the station log:

  1. Tower light malfunctions and repairs
  2. Emergency Alert System (EAS) tests and activations
  3. AM antenna field strength measurements (73.61) (monitor points)
  4. Calibration of remote control equipment
  5. Equipment performance measurements (frequency, harmonics, spurious emissions, etc) (73.1590)
  6. Each entry must be signed
  7. The logs are to be reviewed and signed by the chief operator

The exception to this is AM stations without an FCC approved antenna sampling system, which indeed require readings on the antenna system every three hours. Most AM stations have an approved antenna sampling system.

If an AM station has an approved sampling system, it will be noted on the instrument of authorization (license).

For transmitter operations, a review of part 73.1350 shows that the licensees are responsible for insuring transmitting apparatus complies with all FCC regulations.  Specifically:

73.1350 (b)(2)(c)The licensee must establish monitoring procedures and schedules for the station and the indicating instruments employed must comply with Sec. 73.1215.

And

73.1350 (b)(2)(c)(1) Monitoring procedures and schedules must enable the licensee to determine compliance with Sec. 73.1560 regarding operating power and AM station mode of operation, Sec. 73.1570 regarding modulation levels, and, where applicable, Sec. 73.1213 regarding antenna tower lighting, and Sec. 73.69 regarding the parameters of an AM directional antenna system.

One would assume that would mean some sort of logging. Further, a review of all recent NAL, NOV and citations from the FCC’s enforcement bureau shows that field agents investigating a radio station will make their own power measurements if they suspect a broadcast station is operating out of power tolerance. Most particularly with AM directional stations that are supposed to reduce power at night. I doubt very much that producing an operating log with in tolerance power readings would do any good in those circumstances.

For directional AM stations that change power/mode at night, some routine of checking the transmitter for proper power levels after power/pattern change needs to be established. If there is an auto logging system, such as a Burk Autopilot, then checking that system for proper time of day and/or proper pattern/power change functioning could take the place of checking the actual transmitter readings as long as there were an alarm (and notification) generated during an out of tolerance condition.

For most FM stations and AM non-directional stations, most modern transmitters have Automatic Power Control (APC) built in. As long as the APC is functioning properly and there is an alarm (with notification) generated when an out of tolerance condition occurs (under/over power), logging power output readings can be done on a weekly maintenance log.

Station logs are to be retained for two years (73.1840) and should be available to the FCC for inspection.  After two years, throw the logs out because anything that you have on file is liable to be inspected.   Any rules infractions found in the station logs can lead to a NOV or NAL, even if it happened more than two years ago.

For your reading pleasure:
73.1820

Sec. 73.1820 Station log.

(a) Entries must be made in the station log either manually by a
person designated by the licensee who is in actual charge of the
transmitting apparatus, or by automatic devices meeting the requirements of paragraph (b) of this section. Indications of operating parameters that are required to be logged must be logged prior to any adjustment of the equipment. Where adjustments are made to restore parameters to their proper operating values, the corrected indications must be logged and accompanied, if any parameter deviation was beyond a prescribed tolerance, by a notation describing the nature of the corrective action. Indications of all parameters whose values are affected by the modulation of the carrier must be read without modulation. The actual time of observation must be included in each log entry. The following information must be entered:
(1) All stations. (i) Entries required by Sec. 17.49 of this
chapter concerning any observed or otherwise known extinguishment or improper functioning of a tower light:
(A) The nature of such extinguishment or improper functioning.
(B) The date and time the extinguishment or improper operation was observed or otherwise noted.
(C) The date, time and nature of adjustments, repairs or
replacements made.
(ii) Any entries not specifically required in this section, but
required by the instrument of authorization or elsewhere in this part.
(iii) An entry of each test and activation of the Emergency Alert
System (EAS) pursuant to the requirement of part 11 of this chapter and the EAS Operating Handbook. Stations may keep EAS data in a special EAS log which shall be maintained at a convenient
location; however, this log is considered a part of the station log.
(2) Directional AM stations without an FCC-approved antenna sampling system (See Sec. 73.68). (i) An entry at the beginning of operations in each mode of operation, and thereafter at intervals not exceeding 3 hours, of the following (actual readings observed prior to making any adjustments to the equipment and an indication of any corrections to restore parameters to normal operating values):
(A) Common point current.
(B) When the operating power is determined by the indirect method, the efficiency factor F and either the product of the final amplifier input voltage and current or the calculated antenna input power. See Sec. 73.51(e).
(C) Antenna monitor phase or phase deviation indications.
(D) Antenna monitor sample currents, current ratios, or ratio
deviation indications.
(ii) Entries required by Sec. 73.61 performed in accordance with the schedule specified therein.
(iii) Entries of the results of calibration of automatic logging
devices (see paragraph (b) of this section) or indicating instruments
(see Sec. 73.67), whenever performed.
(b) Automatic devices accurately calibrated and with appropriate
time, date and circuit functions may be utilized to record entries in
the station log Provided:
(1) The recording devices do not affect the operation of circuits or
accuracy of indicating instruments of the equipment being recorded;
(2) The recording devices have an accuracy equivalent to the
accuracy of the indicating instruments;
(3) The calibration is checked against the original indicators as
often as necessary to ensure recording accuracy;
(4) In the event of failure or malfunctioning of the automatic
equipment, the person designated by the licensee as being responsible for the log small make the required entries in the log manually at that time;
(5) The indicating equipment conforms to the requirements of Sec. 73.1215 (Indicating instruments–specifications) except that the scales need not exceed 5 cm (2 inches) in length. Arbitrary scales may not be used.
(c) In preparing the station log, original data may be recorded in
rough form and later transcribed into the log.

73.1350:

Sec. 73.1350 Transmission system operation.

(a) Each licensee is responsible for maintaining and operating its
broadcast station in a manner which complies with the technical rules
set forth elsewhere in this part and in accordance with the terms of the station authorization.
(b) The licensee must designate a chief operator in accordance with Sec. 73.1870. The licensee may designate one or more technically competent persons to adjust the transmitter operating parameters for compliance with the technical rules and the station authorization.
(1) Persons so authorized by the licensee may make such adjustments directly at the transmitter site or by using control equipment at an off-site location.
(2) The transmitter control personnel must have the capability to
turn the transmitter off at all times. If the personnel are at a remote
location, the control system must provide this capability continuously
or must include an alternate method of acquiring control that can
satisfy the requirement of paragraph (e) of this section that operation
be terminated within three minutes.
(c)The licensee must establish monitoring procedures and schedules for the station and the indicating instruments employed must comply with Sec. 73.1215.
(1) Monitoring procedures and schedules must enable the licensee to determine compliance with Sec. 73.1560 regarding operating power and AM station mode of operation, Sec. 73.1570 regarding modulation levels, and, where applicable, Sec. 73.1213 regarding antenna tower lighting, and Sec. 73.69 regarding the parameters of an AM directional antenna system.
(2) Monitoring equipment must be periodically calibrated so as to
provide reliable indications of transmitter operating parameters with a
known degree of accuracy. Errors inherent in monitoring equipment and the calibration procedure must be taken into account when adjusting operating parameters to ensure that the limits imposed by the technical rules and the station authorization are not exceeded.
(d) In the event that a broadcast station is operating in a manner
that is not in compliance with the applicable technical rules set forth
elsewhere in this part or the terms of the station authorization, and
the condition is not listed in paragraph (e) or (f) of this section,
broadcast operation must be terminated within three hours unless antenna input power is reduced sufficiently to eliminate any excess radiation. Examples of conditions that require termination of operation within three hours include excessive power, excessive modulation or the emission of spurious signals that do not result in harmful interference.
(e) If a broadcast station is operating in a manner that poses a
threat to life or property or that is likely to significantly disrupt
the operation of other stations, immediate corrective action is
required. In such cases, operation must be terminated within three
minutes unless antenna input power is reduced sufficiently to eliminate any excess radiation. Examples of conditions that require immediate corrective action include the emission of spurious signals that cause harmful interference, any mode of operation not specified by the station license for the pertinent time of day, or operation substantially at variance from the authorized radiation pattern.
(f) If a broadcast station is operating in a manner that is not in
compliance with one of the following technical rules, operation may
continue if the station complies with relevant alternative provisions in
the specified rule section.
(1) AM directional antenna system tolerances, see Sec. 73.62;
(2) AM directional antenna monitoring points, see Sec. 73.158;
(3) TV visual waveform, see Sec. 73.691(b);
(4) Reduced power operation, see Sec. 73.1560(d);
(5) Reduced modulation level, see Sec. 73.1570(a);
(6) Emergency antennas, see Sec. 73.1680.
(g) The transmission system must be maintained and inspected in
accordance with Sec. 73.1580.
(h) Whenever a transmission system control point is established at a location other than the main studio or transmitter, a letter of
notification of that location must be sent to the FCC in Washington, DC, Attention: Audio Division (radio) or Video Division (television), Media Bureau, within 3 days of the initial use of that point. The letter
should include a list of all control points in use, for clarity. This
notification is not required if responsible station personnel can be
contacted at the transmitter or studio site during hours of operation.
(i) The licensee must ensure that the station is operated in
compliance with Part 11 of this chapter, the rules governing the
Emergency Alert System (EAS).

MMTC Radio Rescue, sort of like the Patriot Act – For Radio

I read with interest the MMTC’s (Minority Media Telecommunication Council) ideas for rescuing radio.  In the summary, they make the statement:

By granting this Radio Rescue Plan quickly, the FCC can provide lenders and investors with assurance that the federal government stands behind the survival and sustainability of this industry that is so vital to public service, public safety, minority entrepreneurship and democracy

Red flag.  Anytime some groups want to rush something through because of some perceived crisis, it should be closely examined for potential conflicts of interest.

It is fine to look into the rules and make changes as technology evolves, rushing some change through because the economy has gone south is not the best plan.  If radio is in such bad shape that it needs a rules relaxation to survive, that indicates there is something seriously wrong with the underlying structure.  No amount of rules changing is going to help that.

Anyway, they lay out some ideas, most of which have been batted about before and have had little of the intended affects.

  1. Re-purpose TV channel 5 and 6 to the FM broadcast band.  Allow AM station to migrate there with a priority given to relieve interference issues on the AM band.
  2. Night time AM signal contour rules, relax requirement to cover 80 percent of city of license at night.
  3. Modify or eliminate principle community coverage rules
  4. Replace minimum efficiency standards for AM antenna systems with “minimum radiation standards”
  5. Allow FM applicants to specify Class C, C0, C1, (etc) in zone I and IA.
  6. Delete non-viable FM allotments from the table of allotments.

1.  The first idea is to re-purpose TV channel 5 and 6 to the FM band.  This would allow more FM stations to exist and presumably many AM station to migrate to the FM band.  Sort of like the expanded AM band project in the 1990s where AM stations moved to the 1600-1700 khz range and then turned in their old licenses in the 540-1600 khz range to reduce interference.  Worked out well except for the last part, almost no AM station that moved into the expanded band has ever turned in it’s original license.  I doubt that they would in an AM to FM band migration.

Perhaps using this expanded FM band to move all of the NCE stations from the commercial channels and allow for LPFM’s to proliferate would be a good idea.

Then there is the problem of what to do with the various LPTV-6 stations that are still around.

I doubt the FCC will go for this because they can make too much money auctioning off the spectrum in one whole chunk to the highest bidder.

2.  Night time AM coverage rules.  The proposal is to allow a relaxing of the night time AM coverage rules over the city of license.   Currently required to cover 80 percent of the area or population except in the expanded band, where the requirement is 50 percent.  Making it all one uniform standard (50%) would make the most sense.  Not that it would make a lot of difference listener wise, still, it might ease the burden on some AM station that would otherwise be solvent.

3.  Modify or eliminate principle community coverage contours.  This idea  just seems like a way to satisfy more big radio consolidators and have more stations move out of their communities of license, which they are supposed to be serving.  This is the money statement:

MTCC believes that modification fo these rules benefit small, women, minority, and all broadcasting licesnses by providing them with additional flexibility for site location

How?  I still cannot fathom how this will benefit those groups mentioned above, seems like a generic statement with no merit.

The rim shot signals which are at least providing some type of radio programming to rural areas would cease to exist as they would all pick up and move toward population centers.  This is a bad idea.  The owners who bought rim shots should have known they were buying rim shots in the first place and not be expecting too much in the way of moving things around to accommodate their idea of what the FM broadcast band should be.

4.  Replace minimum efficiency standards with a minimum radiation standard for AM antenna systems.   The proposal states that when those standards were adopted, land was plentiful and electricity was not.  I would comment that neither land nor electricity is plentiful today.  Reducing this standard would open up potential AM station buyers to risk of investing in a bigger money pit than what AM radio currently is today.

In other words, it is a bad idea which would only cause potential owners to be saddled with huge electric bills and hasten the end of AM radio.  As an engineer, I know that with the right amount of capacitance and inductance, I can load up an AM transmitter to a chain link fence.  That doesn’t mean it is a good idea.

5.  Allow FM applicants to specify class C, C0, C1, C2, C3, (etc) in zone I and IA.  I presume they mean to allow a class B to specify class C2 and a class B1 to specify a class C3.  This might make the application process a little more uniform, but I doubt it would make much difference in the FM band.

Also, they seem to use the term “spectrum warehousing” often.  What does that mean?  They make an elusion to the difference between a 54 dBu and a 60 dBu contour.  Is that 6 dBu a “spectrum warehouse?” It is really nonsensical, sort of like “precious bodily fluids” in Dr. Strangelove.

6.  Non-viable FM allotments.  Sure, delete them or re-align them so that they might be usable to someone.  Makes sense.