In a speech yesterday at the MMTC Ninth Annual Broadband and Social Justice Summit, Chairman Pai revealed that a Notice of Proposed Rulemaking to adopt a new Class C4 FM station, that would allow the increase in power of some Class A stations that meet new spacing requirements, had been drafted and was circulating at the FCC for consideration. So we should expect to see something soon. While some Class A stations are certainly in favor of getting more power to increase coverage and increase building penetration in area that they already cover, there are some who are more leery about the proposal. We wrote the following about some of those concerns in September 2016, when this idea was first discussed by then Commissioner Pai at an NAB Radio Show:

A Class C4 station would fit between Class A FM stations (limited to 6 kw ERP at 100 meters antenna height above average terrain) and a Class C3 (25 kw at 100 meters). The Class C4 station would be authorized with a power of up to 12 kw ERP. According to the Commissioner’s speech, this would allow for Class A stations to upgrade their facilities to better serve their communities. We wrote about this proposal when it was first released (here), presenting more details about the technical facilities that are involved in this proposal. While some broadcasters did initially support the proposal, others were less enthusiastic about the idea. Why are there issues with this proposal?

One of the biggest issues is simply the congestion of the FM band. The more stations that are shoehorned into the FM band, the more interference that is created. Many FM stations enjoy listenership beyond the coverage that is predicted by the FM spacing tables. Increasing power of existing Class A stations might well limit those areas of service enjoyed by some stations, and might also limit the ability of existing stations to upgrade to higher classes with more meaningful coverage increases.   It may also reduce flexibility of existing stations to change transmitter sites if something happens to the sites from which they currently operate.

But, today, the area where there is perhaps the most concern is the impact that the proposal, if implemented, could have on FM translators and LPFM stations.   Congestion in the FM band limits opportunities for new FM translators and LPFMs, and could even disrupt the operation of existing translators and LPFM stations. Upgrades by Class A stations to Class C4 could cause interference to the existing translators and LPFMs, perhaps requiring these secondary stations to have to change frequency (if other frequencies are available in their market). In the two years since comments were initially filed on the Class C4 proposal, the use of translators has only increased, particularly to rebroadcast AM stations. Obviously, any consideration of this proposal would have to look at the differences in the use of translators that have occurred since it was first advanced.


The concerns expressed above have only multiplied since they were written, based on the thousands of translators that have been repurposed for AM uses in the recent filing windows. So, in evaluating this proposal, the Commission would be faced with the need to weigh the benefits of the upgrades that some stations could enjoy against the limits on translators and other FM upgrades that could be precluded.  We should see exactly what is being proposed shortly.