VHF Relocation, FM Translator Limits, Easing Nighttime Coverage Standards Addressed in AM Reply Comments

Clear Channel urged the FCC to promptly open an AM-only FM translator window, “with NCE [noncommercial educational]-like conditions on assignability,” it said (http://bit.ly/1hOWuzB). The commission also should revise the geographic requirements for FM translators rebroadcasting AM stations and set the daytime community coverage minimum for new and existing AM stations “to 50 percent of the community of license area by a daytime 5 mV/m contour,” it said. The geographic limit for FM translators should be revised so the translator’s 60 dBu contour must fit within the greater of the 25-mile radius from the AM station’s transmitter site and “the AM station’s daytime 2 mV/m contour,” it said. This “would be a straightforward and easily administered solution to the current overly restrictive geographic limits,” it said.

Holston Valley Broadcasting endorsed the opportunity for AM stations to apply for FM translators and to give primary status to translators carrying the programming of an AM station “if the licensee of the AM station chooses to voluntarily turn in its AM license,” it said (http://bit.ly/OI4h9I). Holston said there would be less disruption in the broadcast TV service if VHF channels 2 and 3, rather than channels 5 and 6, were chosen to be used by current AM licenses. AM broadcasters that voluntarily construct stations on these new VHF radio broadcast channels shouldn’t be forced to give up their AM band licenses or alternatively be forced to do so for at least five years, Holston said.

Butte Broadcasting, licensee of California stations KKXX(AM) Paradise and KYIX(AM) South Oroville, also agreed to opening an FM translator window for AM licensees and eliminating the current nighttime coverage requirement. Butte supports proposals to “provide for the ongoing opportunity for AM stations to file for new FM translators after the initial filing window has closed,” it said (http://bit.ly/1oGmCku).

NPR urged the FCC to implement an FM translator filing window as proposed in the NPRM instead of adopting proposals by some commenters to allow AM stations to obtain multiple FM translators independently of the AM station, it said (http://bit.ly/1gGtLur). NPR also requested a filing window for NCE-reserved band FM translators simultaneously with the FM translator filing window for AM stations, it said. Simultaneous windows “would serve a clear need for access to FM translator facilities for both AM and NCE FM services, without imposing an appreciably greater burden on commission resources,” it said. NAB called for the FCC to consider ways to deal with the potential displacement of FM translators (http://bit.ly/1d8SgFu).

Broadcasting engineers called for expeditious adoption and implementation of proposals to revitalize the AM band. T.Z. Sawyer Technical Consultants and Mullaney Engineering urged the FCC to adopt “sooner rather than later” many of the proposals submitted in the docket, they said in separate comments. Consideration should be given first to proposals that focus on technical matters that improve the AM service, they said (http://bit.ly/1r6qSvO) and (http://bit.ly/1h2c2OP). Adopting proposed rule changes for day and nighttime city-of-license coverage requirements and nighttime protection requirements “are needed now, not months or years from now,” they said. Major changes to an existing AM facility should be accepted when filed, not via a filing window which may occur only once a decade, they said.

While T.Z. Sawyer and Mullaney support an AM-only filing window for FM translators, they urged the FCC to consider opening a window to licensees in the AM and FM bands. Preference would be given to AM stations to resolve mutually exclusive issues if they occur, it said. It has been more than 10 years since the last FM commercial translator window was opened, it said. The engineering firms also support opening an expanded AM band to all applicants “with a preference given to new broadcast entrants and a secondary preference given to existing licensees moving from the standard band,” they said. A migration of the AM band to TV channels 5 and 6 “would be a dramatic improvement in coverage and service to the public by those stations that decide to migrate,” Mullaney said.

Hatfield & Dawson Consulting Engineers also urged swift action. It said the move to an all-digital AM service shouldn’t be limited to a specific defined digital system (http://bit.ly/1laKHAT). The limit should be on the signal’s occupied bandwidth and the allocations situation, which doesn’t restrict an entity with “inflexible regulations designed to benefit one system over the other,” it said. It backed Digital Radio Mondiale in its claim that “any approval of all-digital transmission standards should be system agnostic,” Hatfield & Dawson said.

IBiquity said it’s “generally supportive” of the FCC’s proposals for near-term relief, but other proposals should be carefully considered (http://bit.ly/NAh9hh). Relocating some or all existing AM broadcasters to spectrum that is free from interference conditions “would offer the possibility for better sound quality for the new channels and would reduce interference for those broadcasters that remain in the AM band,” it said. If the FCC decides to relocate stations to the TV channels 5 and 6 frequencies, broadcasters should employ digital modulation based on iBiquity’s HD Radio system, it said. IBiquity also supports the Clear Channel proposal that the FCC “permit all digital AM operation on a voluntary basis,” it said.

There was overall support for repealing the ratchet rule, which limits nighttime interference. With the repeal of the rule, AM station licensees and the FCC staff “will be spared the added time and expense of the waiver process for relocations of AM stations that would serve the public interest and are otherwise compliant with FCC interference standards,” Clear Channel said: Antenna efficiency standards can be eliminated or modified “provided the process ensures that AM stations do not increase interference to existing AM stations.”