I went backwards from your letter, Paul, and read Mark Heller's letter again (TBH, I have been skimming most online posts of people "promoting" their participation in 25-133).
I'm rather amazed that, as a station broker, he doesn't realize how many of those deleted AMs went silent due to losing their towers. Does he not know that for AM stations, the tower itself is usually the radiator? Or how the land towers sit on has become more valuable than the station using that land? If he's that good a broker, why isn't he busting his ass finding AM operators considering throwing in the towel and finding buyers for them? He cites Audacy's two Vegas stations as examples, but how many of the now-silent AMs were at lower power, where moving them farther out geographically would automatically result in a worse service footprint? (And don't I remember reading somewhere that Audacy did end up keeping the licenses and are planning to put them back on the air diplexed from other towers?)
TIS is rapidly becoming an obsolete service. Has this guy ever opened Google Maps or Waze on his phone? Does he really think people are tuning their car radios to 1620 instead of getting real-time traffic information on their phones? And by that same logic, why does he think new stations in the expanded AM band will be any more successful than they were in the four decades since the band was expanded? And good luck getting people to tune in at the far left end of the FM band.
I am inclined to support more frequent auctions for deleted small-market FMs, but at the same time I have to wonder: If those licenses were surrendered, what was the reason no local owner stepped up and offered to take over? We know that the ad revenue "pie" is cut into too many slices in larger markets, but are we seeing the same thing in the smallest markets? Or has digital taken too much of the revenue for more than a handful of OTA stations to survive?
But I agree about the public file. Other than FCC staff and people looking for excuses to file license challenges, no one ever asks to see it. I was actively part of stations from 1973 to 1989 before going into consulting, and that file was always added to but never read (and at one station where I suddenly was "promoted" to Public Affairs Director, there was no public file so I had to create one, three years after the station originally went on the air).
Excluding the requirements of political advertising requests, the main argument people make about keeping the public file tend to center on the quarterly issues and programs entries. I read recently that those two "barter" public affairs shows produced by MediaTracks -- "Viewpoints" and "Radio Health Journal" -- are now on more than 1000 stations nationwide. That pretty much negates the point, if all of those stations have virtually identical public file entries for that programming.
And meanwhile, self-important people like Heller post ideas that are non-starters to everyone but him.
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