KKVI is illegal

[radi0avenger]

One other minor correction to the original poster's otherwise well-researched investigation: there is not, in fact, any current requirement in the FCC rules that the legal ID be in English.

That's interesting, Scott. I hadn't looked lately, but I know other licenses (such as amateur radio) must ID in English, and I apparently mistakenly thought broadcasters must do the same.
I'll go try to find the exact wording for FM ID requirements and read up.

Thanks for the input!

So here's a question: If I were to request a LPFM on 95.9 in Garland with roughly the same specs, I would assume the app would get denied as the 2nd adjacent would be too close to Cedar Hill (in this case, 96.3) however the app for the translator at that ERP/height got approved? Wonder why that would be any different.

 

[fybush]

That's interesting, Scott. I hadn't looked lately, but I know other licenses (such as amateur radio) must ID in English, and I apparently mistakenly thought broadcasters must do the same.
I'll go try to find the exact wording for FM ID requirements and read up.

Here, let me save you the Googling:

http://www.hallikainen.com/FccRules/2010/73/1201/

So here's a question: If I were to request a LPFM on 95.9 in Garland with roughly the same specs, I would assume the app would get denied as the 2nd adjacent would be too close to Cedar Hill (in this case, 96.3) however the app for the translator at that ERP/height got approved? Wonder why that would be any different.

You surmise correctly, and it's all political. Somewhere along the line, translator owners persuaded the FCC to allow them to make "no-interference" showings. If KSCS puts, let's say, 75 dBu over Garland, then all the translator has to show is that there's no population in the area where the translator would deliver 115 dBu (75+40) or more. Depending on translator power and antenna height, you can sometimes make that showing simply by demonstrating that the interfering contour never touches the ground.

LPFM advocates didn't have the same kind of pull at the Commission, or in Congress for that matter. Congress explicitly outlawed translators on second- and third-adjacent channels to full-power FMs, and has only recently begun repealing the third-adjacent protections. (Yes, that makes the use of 95.5 at least theoretically possible in some parts of the Metroplex...)

 

[oldiesfan6479]

That's interesting, Scott. I hadn't looked lately, but I know other licenses (such as amateur radio) must ID in English, and I apparently mistakenly thought broadcasters must do the same.
I'll go try to find the exact wording for FM ID requirements and read up.

Here, let me save you the Googling:

http://www.hallikainen.com/FccRules/2010/73/1201/

The page has it revised as of two days ago. What bigger mess did the FCC
just make to its legal ID rules?

And regarding IDs (not) having to be in English--was this a requirement in
the past that was eliminated?

 

[fybush]

Harold's pages automatically update daily, or nearly so - that shouldn't be taken as an indication of when the rule itself was last revised. If I'm not mistaken, the last actual revision to 73.1201 was the mess that was inserted a couple of years ago about digital broadcasting.

I don't recall there ever having been anything in writing about a language requirement.

 

[jd]

While I agree that the made-up coverage map is ridiculous, I'm compelled to point out that the FCC does not, in fact, height-derate translators in the same way that it derates full-power stations.

Scott, I was going by Sec. 74.1235 which spells out the maximum ERP based on radial HAAT; the formula for height de-rating is included there. While translators don't have to specify HAAT it was my understanding that it's considered by the FCC when handling translator applications.

 

[fybush]

We're both right.

The derating provisions in 74.1235(b) apply to non-fill-in translators. Translators like the one in Atlanta are considered "fill-in" service and are covered by 74.1235(a), which does not include height derating.

I don't believe K240DS is a fill-in translator in its present incarnation; it could, I believe, be converted to fill-in service if, for instance, its programmers leased an HD-2 or HD-3 subchannel on one of the full-market FMs to use as the "primary." Not that I want to give them any ideas...

 

[fybush]

And on rereading what I just wrote, I'm thinking that converting K240DS to "fill-in" status is a little more complicated than I made it out to be. Fill-in translators have to be owned by the station they relay. That works for the station in Atlanta - it's a Cumulus station, and it rebroadcasts the HD-2 from the class C0 station it rebroadcasts. (Yes, this means that in practice it's the big guys, not the little ones, who get to benefit from those big 250-watt translators. Think it's time for a wholesale revision of the translator rules?)

 

[jd]

Think it's time for a wholesale revision of the translator rules?)

Without a doubt. I'd like to see one blockbuster proposal included in such an overhaul: clearing all NCE translators out of the commercial portion of the band. If they couldn't find a replacement frequency in the non-com band, so be it. They'd be silenced, and replaced either by peripheral commercial outlets (either AM to FM repeaters or justifiable commercial fill-in translators) or LPFM's. Sure, it's a radical idea, especially coming from me, an otherwise conservative person. But how radical was granting thousands of translators for religious broadcasters in the commercial band in the first place?

Hopefully there will be some sort of a revision in translator rules but in the meantime I'd like to see strict enforcement of the existing regulations. If an individual or group is originating programming from a translator they not only should be silenced, but also heavily fined and have their equipment confiscated. If they're found to be operating a non-commercial outlet as a commercial station, or making false statements about the operation (or even the existence) of a "parent" station they should be prosecuted and barred from future ownership of any station.

 

[davideduardo]

I don't recall there ever having been anything in writing about a language requirement.

As long as I have been involved in radio in Puerto Rico, which is just over 40 years, stations have identified either in English or Spanish. In fact, the ones that are rimshots to San Juan always used to ID in English to "hide" the non-metro COL... WDOY and WMEG are examples of this.

I know of quite a few cases where Puerto Rican stations were cited for either not doing the ID or being outside the (then) window for same, but never was one cited for language.

Over time, the assumption by operators of Spanish language stations that the ID should be in English has faded, and I hear many that do the call letters in Spanish. I don't know of any such station that has ever received a notice of violation on that, either.

 

[radi0avenger]

So I wonder if HCCN could be fined for “providing services and facilities incidental to the operation of an unlicensed radio transmitter.” - replace transmitter with translator perhaps?

See here:

http://www.rbr.com/radio/24151.html

 

[93-3TheSurge]

From my experiences, all stations (en Estados Unidos) that broadcast spanish programming do give their station ID in english, so I assumed it was required.

If it is a requirement, it's silly, because if you are broadcasting in spanish, why give a station ID in english? The station ID is for the listener, right?

 

[davideduardo]

From my experiences, all stations (en Estados Unidos) that broadcast spanish programming do give their station ID in english, so I assumed it was required.

I know of at least 120 US radio stations that are broadcasting in Spanish and identifying in Spanish.

I presume by "Estados Unidos" you mean the USA, not Brazil or Mexico.

If it is a requirement, it's silly, because if you are broadcasting in spanish, why give a station ID in english? The station ID is for the listener, right?

No, the ID was originally intended to allow tracking of interference, among other things.

 

[93-3TheSurge]

I know of at least 120 US radio stations that are broadcasting in Spanish and identifying in Spanish.

Sí, que es por qué escribí "en mis experiencias." No he escuchado a cada sola difusión de estación en el español en Los Estados Unidos de América.

No, the ID was originally intended to allow tracking of interference, among other things.
[/quote]

Es la información buena. Pensé que era para el oyente.

 

[davideduardo]

I know of at least 120 US radio stations that are broadcasting in Spanish and identifying in Spanish.

Sí, que es por qué escribí "en mis experiencias." No he escuchado a cada sola difusión de estación en el español en Los Estados Unidos de América.

I'm guessing that the above gibberish means that you have not heard any Spanish language station in the USA identify in Spanish.

What you said, very badly, is that you have not heard a disseminator of stations in Spanish in the US.

In Spanish, by the way, the United States of America is most commonly called the Estados Unidos de Norteamérica, to distinguish it from the other United States in our Hemisphere.

Anyway, here is a starter list of United States of America stations that ID in Spanish:

WABA WAEL WALO WAPA WBQN WBSG WCAD WCGB WCHQ WCMN WCMN WCPR
WCRP WDEP WDIN WEGA WEGM WEKO WELX WENA WERR WEXS WFAB WFDT WFID
WGDL WGIT WHOY WIAC WIAC WIBS WIDA WIDA WIDI WIOA WIOB WIOC
WIPR WIPR WISA WISO WIVA WJVP WKAQ WKAQ WKCK WKFE WKJB WKVM WLEO
WLEY WLRP WLUZ WMDD WMEG WMIA WMIO WMNT WMSW WNEL WNIK WNIK WNNV
WNOD WNRT WNVE WNVM WODA WOIZ WOLA WOQI WORA WORO WOYE WPAB
WPLI WPPC WPRA WPRM WPRP WPUC WQBS WQII WRIO WRRE WRRH WRSJ WRSS
WRTU WRUO WRXD WSKN WSOL WTIL WTPM WUKQ WUKQ WUNO WUPR WVID WVJP
WVJP WVOZ WVOZ WWNA WXEW WXLX WXRF WXYX WYAC WYAS WYEL WYKO WYQE
WZAR WZET WZIN WZMT WZNA WZNT WZOL

(Where a call is repeated, it is used on both AM and FM. Bold calls are stations I managed or consulted was otherwise involved with)

 

[jd]

Surge, just a heads up. The moderators don't look favorably on posting in any language other than English.

Not so, however, with the rule regarding ID's, common to all stations, which can be found in Sec. 73.1201, as Scott mentioned earlier: http://edocket.access.gpo.gov/cfr_2009/octqtr/47cfr73.1201.htm Nowhere in there is there any mention of having to ID in English.

 

[Sammi Brie]

If it counts, on the TV side, there's an open from KMEX-34 L.A. (Univisión) that spells out their calls in Spanish (in audio)...it's their 11pm news open so it's also a TOH ID of sorts.

 

[arnoldevns]

Back on topic.. I believe I heard KKVI back on the air this week.
Looking at the bridge89 website is quite interesting. They've done some very recent live remote broadcasts around Garland. They really don't make much pretense about whether they're on the air in Overton or not. It's just a number on a logo to them.

 

[radi0avenger]

If that's so, tested, I wonder where their license says their control point is, and moreover their TRANSMITTER. Because there were nothing but cows at the coordinates listed on the FCC website. And those remote broadcast pictures are old I believe. Is there something on one of them that makes you think they're recent?

 

[jd]

And those remote broadcast pictures are old I believe. Is there something on one of them that makes you think they're recent?

At least some of them appear to be recent, including a remote from a MLK parade in Greenville and the grand opening of the ALDI store in Garland (March 18th). "Hovering" over the parade photos reveals a 2010 date.

Something else that's interesting: http://bridge89fm.com/meet-our-board.html

 

[MikeShannon914]

OH, MY!! So is big, bad Iola going to huff and puff and blow Avenger's house down? Can Iola pack up the station in the middle of the night and disappear with it? (Remember that happening with her dress shop at Carriage Square in Denton years ago?)

Nice try at giving yourself credibility, Bill Wright...has Iola ever even seen the station, let alone listened to it?

By the way, I've appointed Bruce Springsteen to the board of The Hi-Fi Club. He just doesn't know it yet.

Reminds me...I sure miss those Iolaburgers at the Belo Commissary...