How do stations choose their COLs?

[DougD]

Contemplating The Wave's hourly IDs as "WRMO Milbridge, Bar Harbor, Machias" and "Milbridge, Ellsworth, Bar Harbor" (not to mention that one about "WGTZ Eaton Dayton Alive" , tell me: Just how does a station get to choose its COL as a given place when neither the studio nor the transmitter are actually located in that community? I gather this practice has been going on for many years, isn't at all unusual, and that the FCC appears to be fine with it. It strikes me as a little disingenuous, but OTOH I can see why, for example, WBZ would want to identify itself as being in Boston rather than Allston.

 

[Goat Rodeo Cowboy]

In the "early years" you decided what city you wanted to serve and be identified with, and then found a transmitter site that met the legal requirements for signal strength in you COL and gave you coverage of the desired audience area.

But when the dial became crowded and frequencies became hard to squeeze in, FCC rules began giving preferences to people who promised to serve communities that were "unserved"... where was no station licensed to the "ugly stepchild" community near the "pot of gold" community you wanted to serve. Plus, and big cities became bigger and bigger, it became hard to locate a frequency that would give the legally required signal strength over the entire city, so you couldn't be licensed to that BIG city for lack of full coverage. Thus, you accepted a license for some little city near your transmitter but pretended to be licensed to THE BIG MARKET.

SomeConsulting Engineers and Communications Lawyers make a good living because they understand all the "nooks and crannies" of the FCC rules on these issues.... and because they spend enough time talking to and negotiating with the FCC bureaucracy on such issues.

When you license a station, sometimes you get what you want, many times you have to take what you can get. You don't get to choose nuthin... except: "What is the lesser evil"!

 

[dpries8873]

My understanding, Goat Rodeo Cowboy basically correct. COL used to be city, usually surrounded by suburbs. Station(s) were licensed to COL, had to put 5 mv/meter (AM) or 70 dbu (FM) over entire COL (some exceptions allowed re 80% pop coverage). Transmitter had to be located to provide required signal strength, and studio HAD to be in COL. Transmitter site requirements basically stayed the same (some short space changes), studio location relaxed gradually to within City grade contour, then to 20 mile radius of COL, now, I believe, 25 miles of COL. This is how a station with an existing plant covering COL, moves studio, and has nothing in COL

 

[Fenway1912]

Allston is part of the city of Boston

 

[Goat Rodeo Cowboy]

A.M. has a unique problem. If you are building a new station, or in acquiring an existing station, part of the deal is you must find a new transmitter site because the current owner is able to sell it at obscene prices, you may not be able to find an available site anywhere in the COL that will give you the minimum required signal strength over the entire city. (If you do find one, it may be prohibitive in price.) So you pick a smaller city that is part of the metro area and you license to that small city if it will give you enough coverage of the metro area to be marketable. Even a single tower A.M. can take a lot of real estate, and a multi-tower directional can require more land than an up-state truck farm where they grow produce.

F.M. on the other hand requires a rather miniscule transmitter antenna that can be attached to an existing tower along with other broadcasters, or on the roof of a tall building, or on a water tower. But if your F.M. is a lower power station, you can be back to the problem that your signal will not be strong enough over the entire COL so you are forced to pick a suburb and license there, and hope you have enough slop-over signal to the entire metro area to be viable.

There was a time when you could specialize your programming to the peculiar needs and tastes of the smaller city and just love them to death with your programming and be financial viable without the big city or the total metro. Today's marketing and programming styles along with today's audience measurement methods have really thrown cold water on that concept... though I am sure some people will tell us of stations doing exactly that. If you are already established in that model, great. If this is a new station, or a station taking on an entirely new format and newly licensed to the smaller city, your chances of making that work are likely to be somewhere right between slim and none.

 

[NHRadio]

Just how does a station get to choose its COL as a given place when neither the studio nor the transmitter are actually located in that community?

After the rule changes in the mid 90s stations can use any city they wish as long the COL is listed first. The theory being you can serve your COL from anywhere as long as you throw a city grade signal over it.
Hence, WBZ Boston Portland San Diego is legal AFAIK.
WEEI-FM's stick is in Peabody but as long as there's a 70dbu signal over COL Lawrence all is right with the world. Thanks to WMFP-TV Lawrence having a transmitter in Boston, WEEI can have studios there even though it's more than 25 miles from Lawrence.

 

[ned]

Contemplating The Wave's hourly IDs as "WRMO Milbridge, Bar Harbor, Machias" and "Milbridge, Ellsworth, Bar Harbor" (not to mention that one about "WGTZ Eaton Dayton Alive" , tell me: Just how does a station get to choose its COL as a given place when neither the studio nor the transmitter are actually located in that community? I gather this practice has been going on for many years, isn't at all unusual, and that the FCC appears to be fine with it. It strikes me as a little disingenuous, but OTOH I can see why, for example, WBZ would want to identify itself as being in Boston rather than Allston.

Allston is a section of the City of Boston...

 

[Fenway1912]

Just how does a station get to choose its COL as a given place when neither the studio nor the transmitter are actually located in that community?

After the rule changes in the mid 90s stations can use any city they wish as long the COL is listed first. The theory being you can serve your COL from anywhere as long as you throw a city grade signal over it.
Hence, WBZ Boston Portland San Diego is legal AFAIK.
WEEI-FM's stick is in Peabody but as long as there's a 70dbu signal over COL Lawrence all is right with the world. Thanks to WMFP-TV Lawrence having a transmitter in Boston, WEEI can have studios there even though it's more than 25 miles from Lawrence.

So how does WAAF justify a Boston studio?

 

[NHRadio]

Grandfathered, I think. There is/was a loophole in the law allowing the studio to be anywhere within the Grade B contour of any other service licensed to the same COL. WUNI Channel 27 is licensed to AAF's former COL of Worcester. At least this is how I understand it. If I'm wrong, let me know.
They could also have a legal "main studio" in or near Worcester but use the Boston one 99.9% of the time.

 

[NHRadio]

Contemplating The Wave's hourly IDs as "WRMO Milbridge, Bar Harbor, Machias" and "Milbridge, Ellsworth, Bar Harbor" (not to mention that one about "WGTZ Eaton Dayton Alive" , tell me: Just how does a station get to choose its COL as a given place when neither the studio nor the transmitter are actually located in that community? I gather this practice has been going on for many years, isn't at all unusual, and that the FCC appears to be fine with it. It strikes me as a little disingenuous, but OTOH I can see why, for example, WBZ would want to identify itself as being in Boston rather than Allston.

As long as you give the proper Legal ID you can add any city you want. Technically, WBZ Boston, New York, Los Angeles is legal.

 

[fybush]

So how does WAAF justify a Boston studio?

Under current rules, the legal main studio can be anywhere within 25 miles of the COL, or anywhere within the primary signal contour of the station, or anywhere within the primary signal contour of any other station licensed to the same COL.

It's about 31 miles from the WAAF transmitter in Boylston to the studio in Allston. But WAAF is a class B signal, and the protected signal contour for a B is 54 dBu. WAAF's 54 dBu contour more than encompasses the Guest Street studios, so the studio location qualifies.

COL is an almost arbitrary concept these days. It's meaningful only to the extent that it still preserves some semblance of even distribution of signals across the landscape, and even at that it doesn't work very well.

 

[ray ting]

Actually, the contour used to determine main studio placement is 70 dbu, the "city grade". For a Class B like WAAF, that contour usually goes out about 20.5 miles from the transmitter. So my assumption would be that WAAF's legal "main studio" is not in Boston. The Boston studios/offices are probably in addition to the legal main studio.

 

[fybush]

Right you are, ray ting. (That'll teach me to post so late at night!)

There's an office on Moreland Street in Worcester that presumably serves as the nominal main studio for WAAF - and also for WVEI 1440 Worcester, which also can't have its main studio in Allston. (Or at least "probably" can't have its main studio in Allston, depending on whether the principal community contour of Worcester-licensed WUNI 27 hits Allston.)

 

[w9wi]

Right you are, ray ting. (That'll teach me to post so late at night!)

There's an office on Moreland Street in Worcester that presumably serves as the nominal main studio for WAAF - and also for WVEI 1440 Worcester, which also can't have its main studio in Allston. (Or at least "probably" can't have its main studio in Allston, depending on whether the principal community contour of Worcester-licensed WUNI 27 hits Allston.)

If Allston is a neighborhood of Boston, then the principal community contour of WUNI does easily encompass Allston. (it goes all the way out to Gloucester)

https://licensing.fcc.gov/cdbs/CDBS_Attachment/getattachment.jsp?appn=101272125&qnum=5470&copynum=1&exhcnum=1 , the 48dBu contour (inner circle) is the principal community contour.

The principal community contour rules for digital TV are VERY lax. WUNI's contour extends more than 86km, about 55 miles. As is being discussed on a different forum, the transmitter of one Tennessee TV station is more than 70 miles from the city-of-license, yet is compliant with the coverage rules.

 

[Fenway1912]

So - in theory WAAF could send the signal to Moreland Street in Worcester and from there use a STL to West Boylston?

Right you are, ray ting. (That'll teach me to post so late at night!)

There's an office on Moreland Street in Worcester that presumably serves as the nominal main studio for WAAF - and also for WVEI 1440 Worcester, which also can't have its main studio in Allston. (Or at least "probably" can't have its main studio in Allston, depending on whether the principal community contour of Worcester-licensed WUNI 27 hits Allston.)