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.