AM on FM translators

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On Friday, the FCC finally took action in its long-awaited AM revitalization rulemaking proceeding.  Friday’s order came in three parts – one adopting certain changes to FCC technical FCC rules and also adopting procedures for AM stations to acquire FM translators, a second asking for comment on a series of additional proposals looking to further change certain AM rules, and a final section a more preliminary inquiry looking at longer term policy changes to the AM rules.  While not providing everything some AM proponents may have wished for, the order does promise some immediate help for AM stations – including steps to, in the short-term, bring FM translators to many of the AM stations that feel these translators are necessary for their continued survival.  Today, we’ll look at that aspect of the order – the proposals to make available FM translators to help AM stations.

As we have written (see our articles here and here), there was a major controversy at the FCC about whether or not to open a window, restricted to AM licensees, letting them file for new FM translators, or to instead provide a process where AM stations would need to buy existing translators to provide FM service for their stations.  In Friday’s order, the FCC promised both.  Initially, in 2016, it will open a two-part window during which it will waive its minor change rules so as to allow AM licensees to buy an FM translator authorization, and “move” that translator up to 250 miles from its present location, to its AM market to operate on any available FM channel in that market.  Later in 2017, it will open a more traditional window for any AM that was not able to acquire a translator in 2016 where that AM will be able to file an application for a new FM translator. There are many details associated with each of these windows.
Continue Reading FCC Adopts AM Revitalization Order – Part 1 – The Upcoming Windows for AM Stations to Acquire FM Translators

A proposal to allow AM station licensees to buy FM translators located as far as 250 miles away from the AM station and move them to an area where they can rebroadcast the AM station was the talk of the NAB Radio Show last week.   With battling news releases from FCC Commissioners (one from Commissioner Pai supporting an immediate translator window during which AM licensees would have an exclusive right to file for new FM translators, and a subsequent one from Commissioner Clyburn where she indicates her belief that the 250 mile proposal was the quickest way to bring translators to AM licensees), this proposal seems to have replaced the proposed translator window restricted to AM owners that had been proposed in the AM revitalization order introduced by the FCC about 2 years ago (see our summary of the initial proposal for an AM window here, and a discussion of the controversy over that window here and here). What does this proposal entail?

While the precise rules that are being considered by the Commission are unclear as they have not been released for public comment, from comments made in the public statements released by FCC Commissioners last week, other comments made by FCC staffers at the Radio Show, and stories reported by the trade press, it appears that the FCC is considering allowing any AM licensee to buy a translator located within 250 miles of their AM station and, as a one-step minor change application, to move the translator onto any channel that fits in the AM station’s market.  An AM licensee buys the translator authorization – and it basically gives that licensee the right to file for a vacant frequency in its market on a first-come, first-served basis. 
Continue Reading Moving FM Translators 250 Miles to Rebroadcast an AM Station – What the FCC is Considering as Part of Its AM Revitalization Proceeding

An order deciding on the steps the FCC will take to revitalize AM radio is currently being actively considered by the Commissioners. As we wrote earlier this week, the biggest argument about the proposal that is circulating is reportedly whether or not that order will provide for a window for filing for new FM translators specifically to be used for the rebroadcast of AM stations. As we wrote, the FCC Chairman has indicated his opposition to that proposal – and the reasons for that opposition were made clearer in the press conference following yesterday’s open FCC meeting. While AM radio was not on the agenda of the meeting, the Chairman was nevertheless asked about his opposition to the AM-only translator window. His response? He said something along the lines of – Everybody has the right to ask for free spectrum, but it’s not the general policy of this agency to give it away. It seems to me that this cannot be the full reason for his opposition, as the process for awarding FM translators generally results in spectrum being given away for free – and Congress in fact set up the system that way, reserving an auction only as a last resort in the award of FM translators. An AM-only window for FM translators is no more a give-away of free spectrum than is any other translator filing window.

Applications for new FM translators are filed during pre-announced auction filing windows. If, during one of those windows, mutually exclusive applications are filed (applications that, for technical reasons conflict with each other), these applications are not immediately thrown into an auction as would be the case when there are mutually exclusive applications for full-power FM or TV channels. Instead, pursuant to the Congressional authorization for the auctions used to award spectrum to commercial broadcasters, an auction is used for secondary services like FM translators, and for AM stations where there are no pre-allocated channels, only where the applicants cannot themselves first find a solution for their mutual exclusivity. Thus, once applications are filed, the FCC announces a window during which applicants can work together to coordinate modifications to their proposed facilities to attempt to come up with engineering solutions so that both applications can be granted, or to work out other permitted settlements. As a result of the 2003 FM translator window, the FCC has already granted thousands of new FM translators – and none of these applications were granted as the result of an auction (see our articles here, here and here about the grant of these translators). All were either singletons (meaning they were not technically mutually exclusive with any other application) or they were granted after engineering amendments or other settlements resolved their mutual exclusivity. All of the thousands of new FM translators granted after the 2003 window were “free spectrum,” no different than any applications that would be granted following any AM-only translator filing window.
Continue Reading More on AM Revitalization – Why the FCC Chairman is Against an AM-Only Filing Window For FM Translators

In 2011, licensees of FM translators who wanted to move those translators to areas where there was a need for their service thought that the FCC had done a great thing by authorizing the use of the “Mattoon” waiver (see our article here).  The Mattoon waiver allowed the processing of an FCC application to move the location of a translator as a minor change (meaning that it could be filed at any time, rather than having to wait for a window for the filing of major changes and new translator applications – the last of which opened in 2003) if the current and proposed interfering and protected contours of the stations overlapped.  Without the waiver, the rules deem a minor change to occur only when the protected 60 dbu contour of the station from the proposed and exiting sites overlap, allowing much smaller moves. But, as we have written before, the FCC now seems to be backing off the use of these waivers, and two recent decisions raise the question of whether the policy is doomed (as the Commission proposed in its AM improvement proposals, which we summarized here).

The use of the waiver in many cases eliminated the need for multiple “hops” of translators to get them from existing locations to the sites at which a broadcaster wanted to use them to provide service.  These hops would move the translator from the locations at which it was licensed to a new site, only to file another application as soon as the initial move was granted to move the translator yet again to get them to the location where a broadcaster wanted to use them to provide service.  In some cases, multiple intermediate hops were necessary to move the translator to the site at which its use was ultimately desired.  The Mattoon waiver allowed many site moves to be accomplished through a single application rather than requiring multiple hops, each of which cost the broadcaster time and money in filing multiple applications and in actually building the translator at multiple sites, and also saved the FCC the time and effort to process each of the applications necessary to approve these intermediate stops for the translator. 
Continue Reading The End of the Mattoon Waiver? – FCC Decisions Confirming Its Use Only for the Rebroadcast of AM Stations and Prohibiting Intermediate Site Changes

The FCC’s proposals for aiding AM radio have been released in a Notice of Proposed Rulemaking – one of the last actions for broadcasters under Acting FCC Chairman Mignon Clyburn (see our article here on the leftover broadcast issues with which her successor as chairman, Tom Wheeler, will have to deal).  The proposals for revitalizing the AM band that were contained in the NPRM are all ones that the Acting Chair had previewed at the NAB Radio Show, which we summarized in our article about that speech.  While the general proposals that were made in the NPRM were not surprising, in most of these areas there were a couple of surprises in the details – some of which will may be of concern to some broadcasters.

The Commission made several proposals, including the following:

  • A special FM translator window where applications would be restricted to AM licensees.
  • Reduction of both daytime and nighttime city-grade coverage obligations of existing AM stations.
  • Elimination of the ratchet rule that requires that any AM station making facilities changes do so in a way that reduces overall interference in the AM band (in many cases compelling a reduction of service if a change is proposed)
  • The potential for more liberal use of MDCL technologies, which decrease transmitter power when modulation of the station decrease, potentially saving power (though raising some questions about the robustness of the signal that will result)
  • The modification of AM efficiency standards in some way to allow for shorter towers that could be located on rooftops or in other more limited spaces – though the Commission asked for more comments on how its current rules actually limited such uses
  • A general request for other ideas that could help AM stations.

We will cover the special translator window in today’s post, and cover the other issues in more detail in the future.  Most of the other proposals deal with making facilities changes to the AM station, in some cases changes that might actually decrease service to their current service areas (e.g. were some stations to take advantage of the proposed city-coverage limitation to move further from the station’s city of license).  The translator proposal is the one most likely to bring the most relief to the most AM broadcasters in the heart of their service area – and is one that can be quickly implemented.  So below, we will look at the translator proposal in more detail. 
Continue Reading FCC Proposals For AM Improvements – Part 1 – A Restricted FM Translator Window and an End to the Mattoon Waiver?

Last week, acting FCC Chairwoman Mignon Clyburn delivered a speech at the NAB Radio Show, which talked about new technology and old, and her affection for AM radio.  In the most newsworthy aspect of the speech, the Chairwoman announced that the FCC is currently considering a draft Notice of Proposed Rulemaking looking to improve the service delivered by AM radio. As we wrote here, the issue of AM improvement has been a major initiative advanced by Commissioner Pai, looking to restore AM radio’s competitive posture.  Attention is needed to overcome some of the many obstacles that AM faces, including those from interference that has increased significantly in many metropolitan areas, causing more and more electronic “noise” that disrupts the AM service. The discussion at the Radio Show raised several proposals for AM relief. But will they really help AM stations?

First, it is important to understand that the Chairwoman was talking only about a series of proposed actions – nothing has yet been decided. There is a Notice of Proposed Rulemaking that is circulating at the Commission. This means that the proposal has been drafted and is being reviewed by the other Commissioners. Once they finish their review, the Notice will be released to the public, which will then have some period of time (probably a few months) to comment on the suggestions made by the Commission. According to the Chairwoman’s speech, and echoed by Commissioner Pai in an address that he delivered to the Radio Show, broadcasters will also be urged to come forward with their own ideas as to how to improve AM radio. All of the comments filed by the public will have to be digested before the Commission can actually implement any of them. With that background, what is to be proposed, and which actions will likely move the fastest?Continue Reading AM Improvement Proposals Coming from the FCC – What is Coming and How Quickly?

At the NAB Radio Show in Dallas in September, FCC Commissioner Pai promised that the FCC would take action to revitalize the AM band (see our story here). For years, AM has suffered a gradual erosion in listening, as interference on the band has increased – not necessarily from other AM stations, but instead from background noise that is now part of the environment in most urban areas. This interference is caused by everything from fluorescent lights to plasma TV screens to various other electronic devices that are prevalent in the modern world. At the NAB Show in Las Vegas the week before last, Commissioner Pai reprised his discussion of AM improvements, this time moderating a panel of experts to discuss the potential remedies to the problems faced by the AM radio service. So just what remedies may be possible?

The panel set out several possible solutions to AM interference issues, all of which have potential downsides or problems. These include the following:

  • — More FM translators for AM stations
  • — Blanket power increases for all AM stations
  • — A reduction in skywave protection
  • — The adoption of a cellular architecture for AM stations
  • — All-digital operation for AM stations

Let’s look at each of these options below.Continue Reading Saving AM Radio – What is the FCC Considering?