FM Broadcast translator Stations to Originate Programming

[Groove1670]

Full disclosure. I am one of the petitioners.

Time is running out for comments:
Amendment of Seciton 74.1201 et esq. to Allow for FM Broadcast Booster Stations and FM Broadcast translator Stations to Originate Programming

https://www.fcc.gov/ecfs/search/fil...ngs_name=RM-11858&sort=date_disseminated,DESC

 

[TheBigA]

How would translators originating programming differ from LPFMs, other than allowing commercials?

 

[b-turner]

I feel there is a great benefit for allowing FM translators to originate programming. I believe originating programming is within the scope of the mission of the FCC in licensing stations in the first place, to serve communities with programming that is responsive to the community of license or specific coverage area. It is not logical for the FCC to rule that a distant signal is better than a signal with local emphasis is somehow serving a community better.

As we know, AM radio stations have been suffering for decades. The burden of operational costs is greater, in most situations, than the FM counterpart. From figures I have seen, AM dial radio listening ranges from 5 to 15 percent depending on locale. In theory, a 250 watt FM covering 25% of the coverage area of AM counterpart can reach more radio listeners than the AM station reaching 100%.

Since I have managed an AM daytime only station in a major market, I can tell you from my experience the economic situation is always an issue. With an AM signal, selling of advertising, in many situations, is ineffective. Because of the low listening percentages, it is virtually impossible to attain regular advertisers because the number of listeners within that storefront business trade area is not ample enough to produce the results required for the dollars spent.

The lack of income in many cases means the AM station is operating on a shoestring budget, poorly maintained and operated in a way that makes one a bit nervous when it comes to FCC Compliance. The FM translator offered a breath of fresh air, a chance to change the poor economic conditions.

What I believe is a solution for the FCC is:

1) Allow AM stations with translators to originate programming on the translator.

2) Permit AM stations to attain primary status versus secondary for said translator (limit one primary per AM counterpart…the additional translators would be secondary).

3) Allow AM stations the option to surrender their license if they choose, retaining their 250 FM signal as their sole source of emission (unless they lease and/or hold additional translators). Any additionally owned translators remain secondary. Only one primary to a customer.

4) Charge spectrum use fees per population stats/market size as is done for commercial FM licensees.

SURRENDER OF AM LICENSE: I feel this is important. As the larger population centers are seeing expansion, typically the land the radio station requires for their AM transmission facility exceeds the actual value of the radio station itself. In a situation I know personally, the AM radio station is valued at less than the established property value and depreciated equipment value. Monthly operating expenses exceed income every month in excess of 3 years and running. This is all too typical.

Surrender of the AM license should be stipulated: a primary FM 250 watt license in return. There should not be the opportunity for a licensee to ‘double dip’ by selling the AM license or donating said license. I sure do not advocate donating to a minority or non-profit because it simply burdens the new licensee with the same problems the seller has dealt with for years. I see such a donation as setting up a new licensee for failure. Anyway, any surrendered frequencies could eventually be auctioned by the FCC and increase revenue a bit.

I believe the result of an AM surrendering its license for a primary 250 watt FM (former secondary service translator) is a return to more geographically centered radio, especially in larger cities. In larger cities, the bulk of potential advertisers cannot afford to advertise on radio, even AM. Many communities in any large city identify as a separate community versus a part of the large city. Given a 250 watt FM could effectively serve such a community, the FM would be required to serve the distinct community in order to be financially viable. Because of the lower cost of operation, more affordable advertising rates would permit a larger number of smaller businesses to advertise to their trade area via the station.

In short, the AM license burden vanishes. The broadcaster must be community responsive to survive and economically must be affordable to smaller businesses to derive income. The result is better programming, more community responsiveness and better economic climate for the localized business community by allowing another media venue to generate customers. In many respects, it’s suburban radio for many of these stations. None of this can happen without the ability for the translator to originate programming sensitive to the specific coverage area. The FCC enjoys a higher level of compliance because of the financial relief such a plan allows. Many compliance issues are financially driven.

 

[TheBigA]

It is not logical for the FCC to rule that a distant signal is better than a signal with local emphasis is somehow serving a community better.

You're making an assumption that the station would use this signal for local emphasis on the community. There are already provisions for such a service known as LPFM.

What this will create is entrepreneurs licensing translators and offering them to national services, as USA Radio is attempting to do in Philadelphia. Under current rules, USA Radio has to make a deal with a local AM or an FM-HD. That would be eliminated under this plan.

 

[davideduardo]

You're making an assumption that the station would use this signal for local emphasis on the community. There are already provisions for such a service known as LPFM.

Have you ever driven the signal of an LPFM? It's measured in blocks, not miles. I truly only slightly exaggerate. Citizens Band "stations" cover better!

Translators in some cases are 250 watts at heights of several thousand feet. They never have a powerful signal, but they really have an extensive marginal one.

What this will create is entrepreneurs licensing translators and offering them to national services, as USA Radio is attempting to do in Philadelphia. Under current rules, USA Radio has to make a deal with a local AM or an FM-HD. That would be eliminated under this plan.

What I like about Mr. Turner's idea is the ability to make permanent translators and to allow the elimination of AMs. I'd start immediately with allowing daytimers to be eliminated along with the former Class IV stations. Additionally, any AM where the translator covers as much as the AM does could shut off.

This would required giving a new class to such stations whereby they are protected and the improvement or move of a higher class FM would not force the former translator to move to accommodate. In other words, if you give up the AM, the FM is locked.

Simultaneously, I'd recommend that any cancelled AM be eliminated and the frequency not open for application for five years or so within a 100 mile radius. That thins the herd.

Many if not most nations have had a plan to phase out AM. Mexico has moved nearly 80% of all AMs to FM. Canqada had done the same over the last several decades. Brazil plans to totally eliminate AM, as do many South American nations. Europe has few remaining AMs and in some cases is even transitioning FM. A number of African nations no longer have AM stations, or just a few may remain for rural service.

Yet the US has no plan, even as AM dies and FM is challenged by new media.

 

[TheBigA]

Have you ever driven the signal of an LPFM? It's measured in blocks, not miles. I truly only slightly exaggerate. Citizens Band "stations" cover better!

Exactly! Perfect for what bturner was talking about. Local community service. They want to do something more? They should take on the responsibilities of full station ownership.

What I like about Mr. Turner's idea is the ability to make permanent translators and to allow the elimination of AMs.

Which is exactly what the FCC will hate about it. They have absolutely no reason to eliminate AM. They have no money at risk, and eliminating AM would mean fewer licenses to regulate. Bad for the FCC.

AM owners know what they bought. Allowing them to replace their "boat anchor" AM with an FM translator would be a windfall profit, and the FCC is not in the business of giving away spectrum space.

 

[xmtrland]

Except some of the AM's that have translators use the AM tower to get the FM antenna in the air. In some cases turning off the AM would not eliminate the transmitter site. It would allow for removal of towers not needed for directional and with the remaining tower it would be much easier to lease space on the tower if it's sturdy enough to handle more paying clients. If the property were worth more for commercial or residential use they would have to find a home for the remaining FM operation. Maybe they could sell the land/tower to Vertical Bridge or American tower, But for some AM's with a translator it may not be able to just shut the AM sight down and sell the land.

 

[b-turner]

Very true. However in a situation I know personally, a major market AM daytimer moved their 3 tower array far west of the city to point their signal east and south to cover the metro. From their location they could barely reach the outer suburbs if a translator was co-located with the AM. Even with an American tower lease, the monthly expenses of a 250 watt FM would be a fraction of the AM's monthly expenses. Given a translator can be located, I think, up to 25 miles from the AM tower site under certain conditions, it makes sense to get to where the people are. Some stations might simply benefit from being at the same site as the AM and enjoy good coverage. I talked to a guy in a market of about 450,000. He's centrally located between the two larger population centers and can easily cover the bulk of the AM coverage with a 250 watt translator. For him, the FM located at the AM site makes sense. And it would lower his monthly operational expenses.

 

[Groove1670]

AM stations are not going away. The next step will be digital which is already in the testing process (WWFD). A translator still has to be paired with the parent station (AM or FM or HD) and that won't change. This proposal is limited to around 40 hours a week of programming. Using my station as an example, it would allow me to carry another high school football game on Friday night. We have been approached several times and would use this proposal to do that.

If a broadcaster really Wanted to, a translator can go 24 hours a day and provide around the clock programming by securing a HD channel now. Eliminating this option.

This will benefit many rural communites by allowing stations to provide other programming where signals are limited.

 

[davideduardo]

AM stations are not going away.

Oh, yes they are. In much of the world they are gone or on their way out the door. As listeners get older and older and AM shares get lower and lower, even the heritage stations can't survive.

In most markets, around 5% of all radio listening by those under 55 is to AM. The US, rather than legislating the end to AM is allowing market forces to determine its end. And it is really near.

Of course, in bigger markets the issue is that few AMs cover the whole market cleanly, so that is another factor against AM and for FM and web based services.

The next step will be digital which is already in the testing process (WWFD). A translator still has to be paired with the parent station (AM or FM or HD) and that won't change. This proposal is limited to around 40 hours a week of programming. Using my station as an example, it would allow me to carry another high school football game on Friday night. We have been approached several times and would use this proposal to do that.

You are counting on consumers to buy radios to do that. They won't. Their budget is consumed by the average $40 a month charge for 24-month cellular smartphone payment plans.

Nearly nobody buys stand-alone radios today.

This will benefit many rural communites by allowing stations to provide other programming where signals are limited.

Not counting, of course, the thousands of streaming options they have.

"Radio" does not require and AM or FM transmitter. It's about content and using today's preferred distribution channels. If I were in a town with two high schools, I'd do each team's play by play on streams with loads of pregame and postgame content. I'd use the radio station to promote both, and only do updates there. Think of how many phones would get you bookmarked if you did that? And that would give you the chance to promote other aspects of your station.

 

[Groove1670]

Oh, yes they are. In much of the world they are gone or on their way out the door. As listeners get older and older and AM shares get lower and lower, even the heritage stations can't survive.

In most markets, around 5% of all radio listening by those under 55 is to AM. The US, rather than legislating the end to AM is allowing market forces to determine its end. And it is really near.

Of course, in bigger markets the issue is that few AMs cover the whole market cleanly, so that is another factor against AM and for FM and web based services.



You are counting on consumers to buy radios to do that. They won't. Their budget is consumed by the average $40 a month charge for 24-month cellular smartphone payment plans.

Nearly nobody buys stand-alone radios today.



Not counting, of course, the thousands of streaming options they have.

"Radio" does not require and AM or FM transmitter. It's about content and using today's preferred distribution channels. If I were in a town with two high schools, I'd do each team's play by play on streams with loads of pregame and postgame content. I'd use the radio station to promote both, and only do updates there. Think of how many phones would get you bookmarked if you did that? And that would give you the chance to promote other aspects of your station.

There is no argument that AM listenship has decreased. Owners and the FCC will not let AM go away, and because of that AM will continue to be on life support. Who is buying radios and who is listening is another subject. The FCC is not going to separate translators from their AM parent (of FM) for that matter. At least not in my lifetime.

I can speak for large or medium markets.

In rural markets, internet is not reliable. In our community we have a 1 meg upload, (downloads are not much better) continuous streaming is a nightmare, and outages are quite common. The power of rural radio: Last year we got caught in traffic going to an away game. We received over 50 concerned phone calls why the game wasn't on the radio.

Will this change in the future, yes with the rural broadband initiative (if it happens). Right now rural radio still rules.

 

[Kelly A]

T Owners and the FCC will not let AM go away, and because of that AM will continue to be on life support.

AM isn't so much on life support as it is circling the drain. The Commission threw AM stations a set of water wings in the form of FM Translators, but the audience is not stopping to help. Every time you see a funeral procession; so goes another AM listener.

Who is buying radios and who is listening is another subject. The FCC is not going to separate translators from their AM parent (of FM) for that matter. At least not in my lifetime.

I generally agree with that assumption. This request is similar to LPFM stations now complaining that they need to be able to carry full blown-ads, or have a wider coverage area to survive. Well...DUH! Guess they didn't do much research or due diligence before they applied for the Construction Permit. 'We're going on the airwaves with our 10 watt station and shake up the world!' Delusional thinking.

In rural markets, internet is not reliable. In our community we have a 1 meg upload, (downloads are not much better) continuous streaming is a nightmare, and outages are quite common. The power of rural radio: Last year we got caught in traffic going to an away game. We received over 50 concerned phone calls why the game wasn't on the radio.

Fifty concerned listeners is great and all, but how many of those 50 actually frequent your sponsors? Going forward, will those sponsors be able to cover the expense of covering the local High School sports teams, especially considering sports may be on hiatus for this and next season?

Sure, public Internet in many rural communities isn't great, but there are many options coming on line in the near future that will solve that problem. In the meantime, rural station owners better stop looking at the hand in front of their collective faces, and look down the road within their vision. Not if, but when Internet is more available, rural stations will feel the heat of advertisers jumping ship for the new way of advertising.

 

[b-turner]

LPFM stations are 100 watts at 30 meters, not 10 watts. Guess that extra zero didn't make it in.

 

[semoochie]

LPFM stations are 100 watts at 30 meters, not 10 watts. Guess that extra zero didn't make it in.

Kelly may have been referring to a taller tower. We have one in my area, on a mountaintop, running two watts that skips out all over the east side! If you're in a car and can see the mountain, you're good to go.

 

[Oldie919]

Kelly may have been referring to a taller tower. We have one in my area, on a mountaintop, running two watts that skips out all over the east side! If you're in a car and can see the mountain, you're good to go.

Sounds like WQNH-LP in Deerfield, NH......
Same setup -- 2 watts on a TV tower....If you can actually SEE the tower, you can hear the station....Otherwise, it's "catch-as-catch-can"!!
The problem here is that, at least for the moment, WQNH-LP lost its online stream (Stream Licensing went "belly-up" over a year ago.....) and hasn't picked up a new streaming service.
Kinda sad.....because the station offers a GREAT Easy Listening format........but practically no one can HEAR it!!
FYI....Deerfield, NH is NOT a large population area......!

 

[Kelly A]

LPFM stations are 100 watts at 30 meters, not 10 watts. Guess that extra zero didn't make it in.

Semoochie is correct. All stations and translators have to downgrade for higher AMSL/AGL. 100W at 30M is just the standard application. There are several LPFM's around the country who are running 10W or less.

 

[Michi]

Interesting how everyone is ignoring the elephant in the room. The redefinition of the "fill-in" contour to 45 dBu.

 

[Kelly A]

Interesting how everyone is ignoring the elephant in the room. The redefinition of the "fill-in" contour to 45 dBu.

Not sure what you're referring to. From 74.1201:

(g) Translator coverage contour. For a fill-in FM translator rebroadcasting an FM radio broadcast station as its primary station, the FM translator's coverage contour must be contained within the primary station's coverage contour. For purposes of this rule section, the coverage contour of the FM translator has the same field strength value as the protected contour of the primary FM station (i.e., for a commercial Class B FM station it is the predicted 0.5 mV/m field strength contour, for a commercial Class B1 FM station it is the predicted 0.7 mV/m field strength contour, and for all other classes of FM stations it is the predicted 1 mV/m field strength contour). The coverage contour of an FM translator rebroadcasting an AM radio broadcast station as its primary station must be contained within the greater of either the 2 mV/m daytime contour of the AM station or a 25-mile (40 km) radius centered at the AM transmitter site. The protected contour for an FM translator station is its predicted 1 mV/m contour.

(h) Fill-in area. The area where the coverage contour of an FM translator or booster station is within the protected contour of the associated primary station (i.e., predicted 0.5 mV/m contour for commercial Class B stations, predicted 0.7 mV/m contour for commercial Class B1 stations, and predicted 1 mV/m contour for all other classes of stations).

(i) Other area. The area where the coverage contour of an FM translator station extends beyond the protected contour of the primary station (i.e., predicted 0.5 mV/m contour for commercial Class B stations, predicted 0.7 mV/m contour for commercial Class B1 stations, and predicted 1 mV/m contour for all other classes of stations).

(j) AM Fill-in area. The area within the lesser of the 2 mV/m daytime contour of the AM radio broadcast station being rebroadcast and a 25-mile (40 km) radius centered at the AM transmitter site.

 

[Michi]

Not sure what you're referring to.

It's in the petition for rulemaking. In addition to the local origination, there's also a proposal to extend §74.1201 to the 45 dBu contour on FM.

The people who promoted this petition has said nothing about the 45 dBu fill-in expansion, just like how the folks who supported C4 did not mention the proposed §73.215 changes in their "hype" about that proposal.

From their Petition:

FM COVERAGE CONTOUR CONFORMANCE FOR FM TRANSLATORS
10. The FCC in its recent FM Translator Interference Report and Order set a new standard for the coverage contour of all FM stations as the 45 dBμ contour in relation to FM translator stations. The recognition that FM radio stations have listeners out to, and their coverage contours extend out to, the 45 dBμ contour, should be now recognized in this proceeding to allow FM translators to better serve the listening public. In addition, the rule should be conformed to the AM rule with the 25-mile radius alternative. Sections 74.1201(g) – (j) of the FCC’s rules should be amended to specify the FM station coverage contour as used in Subpart L as follows:

(g) Translator coverage contour. For a fill-in FM translator rebroadcasting an FM radio broadcast station as its primary station, the FM translator's protected contour must be contained within the primary station's coverage contour. For purposes of this Subpart L, the coverage contour of all FM stations is the greater of either the predicted 45 dBμ contour or a 25-mile (40 km) radius centered at the FM transmitter site. The protected contour of an FM translator rebroadcasting an AM radio broadcast station as its primary station must be contained within the greater of either the 2 mV/m daytime contour of the AM station or a 25-mile (40 km) radius centered at the AM transmitter site. The protected contour for an FM translator station is its predicted 1 mV/m contour.
(h) Fill-in area. The area where the protected contour of an FM booster station is within the protected contour of the associated primary station (i.e., predicted 0.5 mV/m contour for commercial Class B stations, predicted 0.7 mV/m contour for commercial Class B1 stations, and predicted 1 mV/m contour for all other classes of stations), or the area where the protected contour of an FM translator station is within the coverage contour of the FM primary station.
(i) Other area. The area where the protected contour of an FM translator station extends beyond the coverage contour of the FM primary station.
(j) AM Fill-in area. The area within the greater of either the 2 mV/m daytime contour of the AM radio broadcast station being rebroadcast or a 25-mile (40 km) radius centered at the AM transmitter site.​

As a consequence of this change in Sections 74.1201(g)-(j), certain conforming changes must also be made to 74.1232(d) and (e) as follows:

(d) An authorization for an FM translator whose protected contour as defined in §74.1201(g) extends beyond the coverage contour of the commercial primary station will not be granted to the licensee or permittee of a commercial FM radio broadcast station. Similarly, such authorization will not be granted to any person or entity having any interest whatsoever, or any connection with a primary FM station. Interested and connected parties extend to group owners, corporate parents, shareholders, officers, directors, employees, general and limited partners, family members and business associates. The coverage contour shall be as predicted in accordance with §73.313(a) through (d) of this chapter. In the case of an FM radio broadcast station authorized with facilities in excess of those specified by §73.211 of this chapter, a co-owned commercial FM translator will only be authorized within the coverage contour of the class of station being rebroadcast, as predicted on the basis of the maximum powers and heights set forth in that section for the applicable class of FM broadcast station concerned. An FM translator station in operation prior to March 1, 1991, which is owned by a commercial FM (primary) station and whose protected contour extends beyond the coverage contour of the primary station, may continue to be owned by such primary station until March 1, 1994. Thereafter, any such FM translator station must be owned by independent parties. An FM translator station in operation prior to June 1, 1991, which is owned by a commercial FM radio broadcast station and whose protected contour extends beyond the coverage contour of the primary station, may continue to be owned by a commercial FM radio broadcast station until June 1, 1994. Thereafter, any such FM translator station must be owned by independent parties. An FM translator providing service to an AM fill-in area will be authorized only to the permittee or licensee of the AM radio broadcast station being rebroadcast, or, in the case of an FM translator authorized to operate on an unreserved channel, to a party with a valid rebroadcast consent agreement with such a permittee or licensee to rebroadcast that station as the translator's primary station. In addition, any FM translator providing service to an AM fill-in area must have been authorized by a license or construction permit in effect as of May 1, 2009, or pursuant to an application that was pending as of May 1, 2009. A subsequent modification of any such FM translator will not affect its eligibility to rebroadcast an
AM signal.
(e) An FM translator station whose protected contour goes beyond the coverage contour of the commercial primary station shall not receive any support, before or after construction, either directly or indirectly, from the commercial primary FM radio broadcast station.
​

 

[Kevin]

There is no argument that AM listenship has decreased. Owners and the FCC will not let AM go away, and because of that AM will continue to be on life support. Who is buying radios and who is listening is another subject. The FCC is not going to separate translators from their AM parent (of FM) for that matter. At least not in my lifetime.

I can speak for large or medium markets.

In rural markets, internet is not reliable. In our community we have a 1 meg upload, (downloads are not much better) continuous streaming is a nightmare, and outages are quite common. The power of rural radio: Last year we got caught in traffic going to an away game. We received over 50 concerned phone calls why the game wasn't on the radio.

Will this change in the future, yes with the rural broadband initiative (if it happens). Right now rural radio still rules.

Agreed, if I were to listen to internet radio all the time my data would cost me $40. or more a month. AM and FM radio is free and dependable 24/7 no data to worry about. 5G data will cost you more when it becomes available in your area.