NAB thinks Translators offer more value than LPFM

Alternate title: “I love Stupidity,” somebody else’s, usually not my own.  It’s a bit hard to reconcile the NAB’s desire for translators against the need and strong community support for local radio.  The original intent of translators was to fill in coverage areas of existing FM licenses within the parent stations’ protected contour.  Very few translators are actually used for that purpose today.  They have, instead, morphed into vast over-the-air relay networks for NPR and religious stations or are relaying programming of HD-2 channels that would otherwise not be heard.  Why we would need more of that, I don’t know.

The unfortunate part of all that stupidity is the side effects.  Think of the stupid driver who cuts off a tractor-trailer on the interstate and causes a big pile-up.  There are potential injuries to those involved in the accident but also the inconvenience to all those stuck in miles of backed-up traffic.  That is a fairly minor occurrence.

With big corporate government, the size and scale of stupidity can reach epic proportions. To wit:  During the natural disasters that overtook the northeast, indeed other areas of the country as well, local radio was proven to be a reliable, sometimes life-saving means of communication time and time again.  Yet, in spite of all that, the NAB seems to think that LPFM stations (community radio) should be second to cross-band translators broadcasting AM stations and HD-2 channels.  Regarding FM translators on AM stations, the NAB says:

NAB first commends and supports the Commission’s proposal to eliminate the restriction on the use of FM translators by AM stations to translators that were authorized as of May 1, 2009. FM translators enable AM stations to overcome inherent technical disadvantages that limit audio quality compared to other services, thus limiting their service to the public and even threatening their economic viability.

Oh where to begin? First of all, AM stations do not have inherent technical disadvantages, that is a myth.  Off-the-shelf AM receivers are of inferior quality and make a well-designed, well-executed AM station sound like a telephone. If one were to listen to an older AM radio or AM on a receiver with variable bandwidth IF, one would find that it can sound quite good, if not very good. The problem is that the receiver manufacturers never carried through with the promise to open up the bandwidth following the implementation of NRSC-2 in 1991.  One should wonder why.

Second, there are many AM stations out there that are economically viable. Those stations have local programming and serve the community of license and have not been neglected or turned into an automated syndicated radio repeater.  Now, could a class C or class D AM station benefit from a translator at night, sure? That may not be a bad distinction to draw, especially for those class D stations with no nighttime operating authority.

Regarding more translators in general, it is difficult to imagine what all those new signals will be used for, other than more of the same (relaying distant, out-of-market religious stations, NPR stations, or HD-2 programming which nobody cares about).    The FM band is already full of such things and could actually use less, not more.

While unfortunate, the NAB’s position is not surprising.  They do the bidding of their dues-paying members, after all.  The anti-competition we are a monopoly stance of the NAB members is not new either. Remember the required economic impact study required by the LCRA on the LPFM vs full power commercial FM stations.  To think that a 100-watt LPFM could significantly impact the business of a class A, B or C FM station is laughable.  Yet, it was a requirement stuck into the bill at the behest of the NAB.

It is up to the broadband-minded FCC to see how to slice the remaining FM spectrum up and whether the corporatist NAB’s argument holds water or the rising call of the people who want a return of local radio and local community service will be heard.

This is a video of what happened during Tropical Storm Irene in Ulster County, where I live:

We are truly fortunate that no one here was killed. In the mean time, the waters around here are still receding, we had some additional flooding Wednesday (9/7) with another 6 inches of rain from Tropical Storm Lee with flood warnings still in effect for several local creeks.

In my neck of the woods, we have nine radio stations licensed within about a 16 mile radius.  One is religious, one is a college station, the other is a classical music format programmed from Albany, 90 miles away, one is a LPFM run by a local high school and two are commercial AM or FM station.  The commercial stations used to be located in downtown Ellenville but moved to Poughkeepsie, about 30 miles away in 1999.  The religious, college, and classical stations are small and have no backup systems or interest in emergency programming.  That leaves the high school LPFM, WELV-LP.

In the height of the storm, 11.53 inches of rain had fallen in the previous 8 hours, the power was out, cable was out, the internet unavailable, the Verizon telephone company office in town was almost underwater, we had two sources of local Ulster county information; WDST (100.1 MHz, class A) in Woodstock and WELV-LP in Ellenville.  WDST  studios are located in Bearsville, which is about 25 miles north of here.  They are a locally owned, locally programmed station with a good record of community support.  They did a good job updating emergency information, flooded roadways, emergency shelter information, power restoration information, dry ice, alternate emergency numbers in case 911 went out, rallying points for local fire departments, etc.  Ellenville Central School district’s WELV-LP also did a good job, although much more confined to the local area around Ellenville and have a much smaller coverage area.  Still, they were live on the air with up to date information.  Thankfully.

Next time, who knows?

FCC seeks further comment on Low Power FM (LPFM)

While I was away, the FCC released a Further Notice of Proposed Rule Making (11-105) regarding LPFM and translators.  There are several issues with a backlog of translator applications and the possible LPFM window that looms out in the future somewhere.  The current FCC translator rules bear little or no resemblance to the reality of FM translator use today.

The basic translator rules are found in FCC 74.1206 through 74.1290 with the programming and permissible service outlined in FCC 74.1231:

Sec. 74.1231 Purpose and permissible service.

(a) FM translators provide a means whereby the signals of AM or FM broadcast stations may be retransmitted to areas in which direct reception of such AM or FM broadcast stations is unsatisfactory due to distance or intervening terrain barriers, and a means for AM Class D stations to continue operating at night.
(b) An FM translator may be used for the purpose of retransmitting the signals of a primary AM or FM radio broadcast station or another translator station the signal of which is received directly through space, converted, and suitably amplified, and originating programming to the extent authorized in paragraphs (f), (g), and (h) of this section. However, an FM translator providing fill-in service may use any terrestrial facilities to receive the signal that is being rebroadcast. An FM booster station or a noncommercial educational FM translator station that is operating on a reserved channel (Channels 201-220) and is owned and operated by the licensee of the primary noncommercial educational station it rebroadcasts may use alternative signal delivery means, including, but not limited to, satellite and terrestrial microwave facilities. Provided, however, that an applicant for a noncommercial educational translator operating on a reserved channel (Channel 201-220) and owned and operated by the licensee of the primary noncommercial educational AM or FM station it rebroadcasts complies with either paragraph (b)(1) or (b)(2) of this section:
(1) The applicant demonstrates that:
(i) The transmitter site of the proposed FM translator station is within 80 kilometers of the predicted 1 mV/m contour of the primary station to be rebroadcast; or,
(ii) The transmitter site of the proposed FM translator station is more than 160 kilometers from the transmitter site of any authorized full service noncommercial educational FM station; or,
(iii) The application is mutually exclusive with an application containing the showing as required by paragraph 74.1231(b)(2) (i) or (ii) of this section; or,
(iv) The application is filed after October 1, 1992.
(2) If the transmitter site of the proposed FM translator station is more than 80 kilometers from the predicted 1 mV/m contour of the primary station to be rebroadcast or is within 160 kilometers of the transmitter site of any authorized full service noncommercial educational FM station, the applicant must show that:
(i) An alternative frequency can be used at the same site as the proposed FM translator’s transmitter location and can provide signal coverage to the same area encompassed by the applicant’s proposed 1 mV/m contour; or,
(ii) An alternative frequency can be used at a different site and can provide signal coverage to the same area encompassed by the applicant’s proposed 1 mV/m contour.
(c) The transmissions of each FM translator or booster station shall be intended only for direct reception by the general public. An FM translator or booster shall not be operated solely for the purpose of relaying signals to one or more fixed received points for retransmission, distribution, or further relaying in order to establish a point-to-point FM radio relay system.
(d) The technical characteristics of the retransmitted signals shall not be deliberately altered so as to hinder reception on conventional FM broadcast receivers.
(e) An FM translator shall not deliberately retransmit the signals of any station other than the station it is authorized to retransmit. Precautions shall be taken to avoid unintentional retransmission of such other signals.
(f) A locally generated radio frequency signal similar to that of an FM broadcast station and modulated with aural information may be connected to the input terminals of an FM translator for the purpose of transmitting voice announcements. The radio frequency signals shall be on the same channel as the normally used off-the-air signal being rebroadcast. Connection of the locally generated signals shall be made by any automatic means when transmitting originations concerning
financial support. The connections for emergency transmissions may be made manually. The apparatus used to generate the local signal that is used to modulate the FM translator must be capable of producing an aural signal which will provide acceptable reception on FM receivers designed for the transmission standards employed by FM broadcast stations.
(g) The aural material transmitted as permitted in paragraph (f) of this section shall be limited to emergency warnings of imminent danger and to seeking or acknowledging financial support deemed necessary to the continued operation of the translator. Originations concerning financial support are limited to a total of 30 seconds an hour. Within this limitation the length of any particular announcement will be left to the discretion of the translator station licensee. Solicitations of contributions shall be limited to the defrayal of the costs of installation, operation and maintenance of the translator or acknowledgements of financial support for those purposes. Such acknowledgements may include identification of the contributors, the size or nature of the contributions and advertising messages of contributors. Emergency transmissions shall be no longer or more frequent than necessary to protect life and property.
(h) An FM translator station that rebroadcasts a Class D AM radio broadcast station as its primary station may originate programming during the hours the primary station is not operating, subject to the provisions of Sec. 74.1263(b) of this part.
(i) FM broadcast booster stations provide a means whereby the licensee of an FM broadcast station may provide service to areas in any region within the primary station’s predicted, authorized service contours. An FM broadcast booster station is authorized to retransmit only the signals of its primary station which have been received directly through space and suitably amplified, or received by alternative signal delivery means including, but not limited to, satellite and terrestrial microwave facilities. The FM booster station shall not retransmit the signals of any other station nor make independent transmissions, except that locally generated signals may be used to excite the booster apparatus for the purpose of conducting tests and measurements essential to the proper installation and maintenance of the apparatus.

With a  possible exception for use by Class D AM stations, the translator service has gone far away from what it was intended to be and even, in some cases, contradicts the current rules.  DIY Media goes more into this in Unholy Alliance.

Consolidators are using translators to get around market ownership caps by using them to re-broadcast HD-2 and HD-3 channels, which would otherwise go unheard.  Others are using translators to establish large networks of over-the-air relays to greatly extend their coverage far beyond any natural signal contour.  Religious and public radio stations rely extensively on translators to establish radio signals that are several times the size of the original station.  In one case, a translator in Harrisburg, PA is broadcasting a satellite feed of the True Oldies Channel that does not appear on any AM, FM or HD sub-channel in the market.  The 80/160 KM distances noted above in section B(1)(i) and (ii) seem to be largely ignored.

What the FCC wants to know is this: There are thousands of pending translator applications; what is to be done about them in light of the new LPFM legislation Congress passed last year?  Should they be dismissed, approved, or some market-based combination of the two?  Keep in mind, the new LPFM stations are on an equal regulatory footing with translators, unlike full-power FM or the previous LPFM licenses granted in 2003.

Whatever the outcome, it would appear that this will be the final chance to get an LPFM license when the filing window opens.   After this, there will likely not be a scrap of spectrum left to dole out.  The deadline for filing comments with the FCC is August 29th.

Local Community Radio Act becomes law

The President has signed the reconciled bill into law, it will be published in the national register.  FCC Chairman Julius Genachowski promises “swift action” to get the new rules in place.   If this law leads to a bunch of new, live local community radio stations springing up across the country then it is a welcome thing.  With all the rumbling in Congress about cutting public radio funding, LPFM may have some big shoes to fill.  I have to admit, that I am generally a supporter of public radio, however, they have gotten off track (full of themselves) in the last few years.

There are many different requirements placed on the FCC by the LCRA to thread the LPFM needle around translators and full-power FM stations, so it may take a little time to craft new LPFM rules, however, I’d expect to see a filing window sometime in 2011.

If you are considering an LPFM station and are eligible for a license, take a peek at Prometheus Radio Project, which has a wealth of information about LPFM station building.

If you need a good engineer to file paperwork, specify equipment, consult about transmitter locations, towers, antennas, and so forth, drop me a line.  You can find my info and contact information in the About section.