FM Translators for AM Stations?
Comments are due to be filed with the FCC by this Thursday, August 24, on the NAB's proposal to allow AM radio stations to use FM translators to fill in nulls in their coverage. Particularly for AM stations with very directional patterns, or with authorizations that specify little or no nighttime coverage, this proposal could provide an excellent way for these stations to maximize service to their listeners. The NAB is making the filing of comments easy through an electronic filing system available on its website here.
While it is important for those supporting this proposal to file comments to urge the FCC to consider it, this is but the first step in a long process before this proposal can become reality. The FCC here is asking only for comments on the NAB's Petition for Rulemaking. If the FCC finds merit in the NAB proposal, then it would have to draft its own Notice of Proposed Rulemaking to suggest rules that would govern the use of such translators. After taking comments on the Notice, if the FCC is still convinced that the idea is a good one, the Commission would then have to draft a set of final rules and an order adopting those rules. Thus, in the best case, this is a long process.
And this might not be the best case. As you may remember, the FCC already has an open proceeding trying to determine the relative value of FM translators versus low power FM stations. That proceeding seeks to determine if low power FM stations should receive a preference over FM translators. That proceeding also put a freeze on the processing of all new FM translator applications - a freeze that was supposed to last 6 months but has now been in place for almost a year and a half. Since the FM translators that would be authorized by the NAB proposal could also preclude LPFM stations, as well as be precluded by the translators still pending from the last FM translator window, the opportunity to file for translators for AM stations may be technically precluded in some areas, and may not be able to occur until the LPFM issues are resolved. And none of that may come quickly.
While this NAB proposal would normally take a long time to get past all of the regulatory hurdles of a new FCC rule, I think this one may be on a fast track. I think not only the NAB but the FCC and the supporters of digital radio will all be behind this one. While there have been many good reasons to promote the use of FM translators for AM for many years, the NAB always objected to calls for such use in the past. What has changed? Yes interference is greater but that had little bearing on day only stations who had ZERO night service anyway. Again what has changed? Digital radio, that is the difference.
What is really happening here in my view is a way to deal with the night time IBOC (HD-R) issue. We all know that night AM IBOC is not permitted due to sky wave problems. If most of the stations that would be affected by the sky wave digital noise are no longer depending on AM to get to their audience and they are using FM translators which can also be digital, the problem almost goes away.
Commentators on the NAB petition have said they support it as long as Class 1 50 kW stations are excluded. Keep in mind that the Class 1 stations operating at 50 kW do not need translators. What they need is the ability to run digital at night. That might be one reason not one 50kw station has filed a comment on the NAB petition as of this writing. The NAB petition looks like a win win and you would be surprised how fast it could get thru the FCC if all hands are pulling the same way. Look at it this way. The 50 KW stations in major cities some of which are already digital would be a step closer to night operation because objections would be quashed if the smaller affected AM stations get FM operation. The no night power or low night power AM stations get to provide noise free service for the first time and they will see new dollars coming in. The digital folks at Ibiquity get their investment saved from possible ruin if IBOC did not survive the night test. So far not one serious objection with any merit has been filed with the FCC. If the FCC decides as some have asked in comments to assign FM frequencies to AM stations, then it would be very easy for the translators to be implemented. Since only the lower power stations would be at the front of the line, I can see how the road to nighttime IBOC might be an easier trip for the AM big boys just waiting to keep the digital carrier on past sundown. Look for this one to have lots of grease!
Larry Langford
There is no place left in the FM band for AM stations to have FM translators in most populated parts of the USA.
The spread of FM stations from using one analog channel to the iBiquity/HD digital plan of 3 channel wide digital FM transmission will wipe out virtually all frequencies for AM translators on the FM band. Any coverage or advantage of low power AM translators on the FM band will disappear from the increased interference.
Sincerely,
R. F. Burns