This has to be the ultimate manipulation of FCC rules. Watch EMF shovel crap a couple of loopholes.
EMF acting though licensee San Joaquin Broadcasting as an LMA partner and "Technical Consultant" has applied with the FCC to change the COL of KLVS (Formerly KSTN-FM) from Stockton to Livermore. Why? So they can bring KLVS into "compliance" since KLVS doesn't provide the required signal over Stockton, but does over Livermore. Nice....
https://licensing.fcc.gov/cgi-bin/w...xt=25&appn=101360596&formid=301&fac_num=69685
They're using the following argument....
https://licensing.fcc.gov/cdbs/CDBS...?appn=101360596&qnum=5320©num=1&exhcnum=1
That little pesky rule....73.315...Funny, KSTN-FM has been using that site with a Stockton COL since umm...oh let's see 1962?
The nice thoughtful people at EMF...
The same broadcasters that used a little thing like the FCC approved altenative Longley-Rice propagation prediction method to "prove" that moving KARA to Sutter Buttes would still cover Williams, CA with at least a 70 dbu using Longley-Rice even though they couldn't show adequate coverage using the traditional 73.315 method.
https://licensing.fcc.gov/cgi-bin/w...xt=25&appn=101228783&formid=301&fac_num=88177
The COL coverage argument for KARA 99.1
https://licensing.fcc.gov/cdbs/CDBS...?appn=101228783&qnum=5240©num=1&exhcnum=1
They clearly know their way around the rules....
If you use the same KARA argument (Longey-Rice) with KLVS (Formerly KSTN-FM), you will see that KLVS not only puts the required 70 dbu over Stockton it also does so over Elk Grove, parts of Sacramento, Modesto and points in between.
I cannot link a map, but you may make one for your self using FCC parameters with that really cool Canadian L-R Map making site....
http://lrcov.crc.ca/main/
KLVS FCC facility info:
http://www.fcc.gov/fcc-bin/fmq?list=0&facid=69685
What this is really about is:
1. First Move the COL to Livermore
Then:
2. Change the facility to effectively serve the lucrative San Francisco Bay Area.
I'm concerned that under-radioed Stockton is losing yet another station. On the surface, Stockton appears to be in the "Shadow" of significantly smaller Modesto. But if you were to take cash cow KATM and sister KHKK (both licensed to Modesto but puts a 70 dbu over the entire Stockton market as well) at move the station (with the same advertisers) to the Stockton market. The revenue for both markets would be the same. As it stands, revenue in the Modesto radio market is way above average for a market it's size while revenue in the Stockton radio market is way below average for a market it's respective size.
Now the Stockton market is left with...
AMs
1 Silent KSTN (1420), Might as well be silent KWSX (1280), KWG (1230), KCVR (1570) and KCBC (770). I think these AM's may collectively pull a 1 share.
FMs
Four Class A's ... KQOD (100.1), KJOY (99.3), KWIN (97.7) and KMIX (100.9) and non-coms...KAIS, KUOP and KYCC.
One final thought...
I wish America's NPR stations would have the tenacity to multiply like EMF's K-Love and Air 1. In fairness, EMF is hardly alone in the world of playing both sides of the fence to get what they want.
EMF acting though licensee San Joaquin Broadcasting as an LMA partner and "Technical Consultant" has applied with the FCC to change the COL of KLVS (Formerly KSTN-FM) from Stockton to Livermore. Why? So they can bring KLVS into "compliance" since KLVS doesn't provide the required signal over Stockton, but does over Livermore. Nice....
https://licensing.fcc.gov/cgi-bin/w...xt=25&appn=101360596&formid=301&fac_num=69685
They're using the following argument....
https://licensing.fcc.gov/cdbs/CDBS...?appn=101360596&qnum=5320©num=1&exhcnum=1
That little pesky rule....73.315...Funny, KSTN-FM has been using that site with a Stockton COL since umm...oh let's see 1962?
The nice thoughtful people at EMF...
The same broadcasters that used a little thing like the FCC approved altenative Longley-Rice propagation prediction method to "prove" that moving KARA to Sutter Buttes would still cover Williams, CA with at least a 70 dbu using Longley-Rice even though they couldn't show adequate coverage using the traditional 73.315 method.
https://licensing.fcc.gov/cgi-bin/w...xt=25&appn=101228783&formid=301&fac_num=88177
The COL coverage argument for KARA 99.1
https://licensing.fcc.gov/cdbs/CDBS...?appn=101228783&qnum=5240©num=1&exhcnum=1
They clearly know their way around the rules....
If you use the same KARA argument (Longey-Rice) with KLVS (Formerly KSTN-FM), you will see that KLVS not only puts the required 70 dbu over Stockton it also does so over Elk Grove, parts of Sacramento, Modesto and points in between.
I cannot link a map, but you may make one for your self using FCC parameters with that really cool Canadian L-R Map making site....
http://lrcov.crc.ca/main/
KLVS FCC facility info:
http://www.fcc.gov/fcc-bin/fmq?list=0&facid=69685
What this is really about is:
1. First Move the COL to Livermore
Then:
2. Change the facility to effectively serve the lucrative San Francisco Bay Area.
I'm concerned that under-radioed Stockton is losing yet another station. On the surface, Stockton appears to be in the "Shadow" of significantly smaller Modesto. But if you were to take cash cow KATM and sister KHKK (both licensed to Modesto but puts a 70 dbu over the entire Stockton market as well) at move the station (with the same advertisers) to the Stockton market. The revenue for both markets would be the same. As it stands, revenue in the Modesto radio market is way above average for a market it's size while revenue in the Stockton radio market is way below average for a market it's respective size.
Now the Stockton market is left with...
AMs
1 Silent KSTN (1420), Might as well be silent KWSX (1280), KWG (1230), KCVR (1570) and KCBC (770). I think these AM's may collectively pull a 1 share.
FMs
Four Class A's ... KQOD (100.1), KJOY (99.3), KWIN (97.7) and KMIX (100.9) and non-coms...KAIS, KUOP and KYCC.
One final thought...
I wish America's NPR stations would have the tenacity to multiply like EMF's K-Love and Air 1. In fairness, EMF is hardly alone in the world of playing both sides of the fence to get what they want.