KPFK vs. XHTIM on 90.7. Solutions Needed

[hipman2]

Suggestion: Shift Some Tijuana Stations (Oct 21, 2010)

The ongoing problem with Tijuana's radio station at 90.7 Mhz interfering with KPFK's 90.7 FM radio station in Los Angeles has been going on for almost three months. That's not the first time it's been going on.

From 2000-2008, XLNC-1 broadcasted on 90.7 Mhz until they moved to 104.9 Mhz that year, allowing residents in outlying areas of KPFK's signal to receive it once again.

The main problem with the co-channel interference with KPFK vs. XHTIM 90.7, which moved from 97.7 in August but is still simulcasted there for the time being, is the way the FM channel allotments for Tijuana-San Diego were given out, as well as KPFK's grandfathered status of broadcasting 110,000 watts, probably the highest wattage radio station in California.

Let's explain. KPFK is broadcasting so strongly on 90.7 MHz that it was probably not advisable to assign the frequencies of 90.5 and 90.9 MHz radio stations in Tijuana because of adjacent channel interference, though Tijuana radio stations can broadcast 100,000 watts or more. I'm not sure what the Mexican government was thinking when they decided to assign radio station frequencies that interfere co-channel with the Los Angeles stations to Tijuana radio stations such as 90.7 MHz, which is used by KPFK, and briefly in the early 1990s, 91.5 MHz, used by KUSC in Los Angeles.

In the early 90s, a radio station in Tijuana briefly used 95.5 MHz after shifting from 95.7 MHz so that KKOS 95.9 (now KUSS 95.7) would be heard better in North County, but the Tijuana station interferred co-channel with KLOS 95.5, and was later shifted to 99.3 MHz (a radio staion in Tecate which was using 99.3 MHz was shifted to 95.3 MHz as a result.)

The SCT of Mexico and the FCC of the U.S. are not quite coordinating with each other in regards of alloting FM and AM radio frequencies to radio stations within 200 miles of the U.S./Mexico border. They are not working hard enough to make sure that radio stations on both sides of the border are not interferring with each other when new stations sign on or move to another frequency.

The co-channel interference problems are not limited to FM. This happens on AM radio as it did in the mid 2000's when Bonilla launched a station on 780 kHz, causing interference with several nearby stations co-channel and adjacent-channel, and moved a station in Temecula from 1600 to 550 kHz, which caused interference with a station in nearby Tijuana on 540 kHz. When it moved to 560 kHz, stations from Yuma, San Francisco, Los Angeles, Phonenix, and others cried foul to the FCC and got them to tell the SCT to tell the 560 kHz station to move to the current 1700 kHz today.

Low powered XHITT at 88.7 MHz is broadcasting at such low enough power to not cause problems with listeners of KSDW 88.9 in Temecula, which moved its transmitter to Palomar Mountain to reach more listeners. XHITT is sometimes engulfed by a KUSC translator in Santa Barbara on the same frequency.

KLTX broadcasted on 1390 kHz for the longest time. XEKT was doing fine on 1380, but when it shifted to 1390, it causes co-channel interference, rendering both stations unlistenable if you're in both signal contours. XHKT should shift back to 1380 ASAP.

XEC 1310 broadcasts from Tijuana, but at 1kw, it's relatively a low power AM station. In Oceanside, KKSM 1320 broadcasts at 250 watts (not kilowatts), so it's limited in range from Carlsbad to San Clemente and eastward to Escondido. So far, no reports of problems with adjacent channel interference.

XESDD 1030 from Tijuana and KURS 1040 from San Diego are right next to each other in frequency and about 30 miles apart with their transmitters, yet they're both low-powered AM stations.

Even TV stations in San Diego and Tijuana can co-channel with problems. Currenty, XDTV channel 49 (since 1999) from Tecate is not quite reaching parts of North County due to a longtime low power TV station on channel 49 since 1990. The latter rebroadcasts KBNT 17.

In the early 90s, XHUAA channel 57 signed on from Tijuana, causing co-channel interference with viewers of a low power channel 57 from Poway. Oddly enough, the Poway station at the time broadcasted Spanish language programming from Tijuana's Telemundo affilliate 33.

With KPFK vs. XHTIM on 90.7 interferring with each other, we might need to propose a solution.

Several radio stations in Tijuana need to shift frequencies by 0.2 Mhz. Tijuana's radio staitons on 90.3, 90.7, and 91.1, could shift over to 90.5, 90.9, and 91.3 Mhz, as there aren't that many full powered radio stations near Tijuana broadcasting on those frequencies. That will mean that an under construction LPFM station on 91.3 Mhz KOPA would have to shift to either 91.5 or 91.1 Mhz.

KPFK would no longer suffer co-channel interference with XHTIM because the latter would be on 90.9 Mhz.

It might be advisable for KPFK to lower its transmitting power to not cause too much adjacent-channel interference with XHTIM or XHITZ (moving from 90.3 to 90.5) in the San Diego metro area.

91X (XETRA moving from 91.1 to 91.3) may get some adjacent channel interference with KUSC 91.5 when you drive too far away from its signal range. This is a normal occurrence.

This would free up an allotment of 90.1 MHz for use for low power non commercial radio stations in the San Diego area. Los Angeles and Orange may get allotments for 90.3 and 91.1 Mhz for low powered noncommercial radio stations there.

All the shifting may mean that nearby radio stations in outlying areas like KOPA would have to shift frequencies to not be interferred with the Tijuana stations.

What do you think of this solution? Fire away.

 

[davideduardo]

Suggestion: Shift Some Tijuana Stations (Oct 21, 2010)

The ongoing problem with Tijuana's radio station at 90.7 Mhz interfering with KPFK's 90.7 FM radio station in Los Angeles has been going on for almost three months. That's not the first time it's been going on.

And since FCC rules give grandfathered stations the ongoing use of their superpower statues without any more protecction than that of a conforming operation, KPFK has no claim to coverage in San Diego County. Mexico is well within the regulations of the Comision Mixta in using the channel in Tijuana.

Actually, KPFK is interferring with a Mexican conforming allocation. They could save some money and reduce power.

 

[SDRadio]

Actually, KPFK is interferring with a Mexican conforming allocation. They could save some money and reduce power.

David T., while your idea is well thought out, David Eduardo has it correct. KPFK is "out of bounds" in San Diego county. In North County, there is a FM collusion between LA and TJ on the air.

Welcome to Southern California!!

 

[radio-darn]

"In the early 90s, a radio station in Tijuana briefly used 95.5 MHz after shifting from 95.7 MHz so that KKOS 95.9 (now KUSS 95.7) would be heard better in North County, but the Tijuana station interferred co-channel with KLOS 95.5, and was later shifted to 99.3 MHz (a radio staion in Tecate which was using 99.3 MHz was shifted to 95.3 MHz as a result.)"

Victor Diaz personally worked to make that happen: it was a move that added many millions of dollars to the value of the KKOS station (and the Chandler family never even sent him a thank you card ) Victor's motives had nothing to do with wanting KKOS to have better reception: he just wanted better reception or his stations and to get ABC (then owners of KLOS) off his back. ABC had enough clout to generate some heat, but Victor, again, wanted more power for his Fiesta Mexicana station and to get a signal on which to place his classical music format (which was internet only at first).

The Mexican government, though, is generally not going to reach out on its own to resolve any alleged conflicts with US stations. Mexican governments have a long tradition of not wanting to be seen as doing anything to appease the Yonkes of the EUA. KPFK has no clout with the US government, so certainly the Mexicans should not be expected to do anything about KPFK's whining.

 

[davideduardo]

he Mexican government, though, is generally not going to reach out on its own to resolve any alleged conflicts with US stations. Mexican governments have a long tradition of not wanting to be seen as doing anything to appease the Yonkes of the EUA. KPFK has no clout with the US government, so certainly the Mexicans should not be expected to do anything about KPFK's whining.

The Mexican government does a pretty good job of coordinating with the US, given that their radio regulations are different from those of the US. Yes, there is some laxity of enforcement of the terms of licenses, just as there is a laxity today by the FCC in enforcing sign-offs of daytimers and switching to night operations by other AMs. That is what is to be expected in an era when regulating other parts of the spectrum have taken regulatory agency priority.

In any case, attitude towards "yanquis" is irrelevant. KPFK is legally only protected to the extent of what its coverage as a 50 kw station at 500 feet would be. And that means that a Tijuana station of moderate power would totally comply with all protection requirements.

 

[Big 121]

It works the other way around too...in the '90s, with it's suspiously strong signal into the L.A. basin, 91X had no standing for protection. Thousand Oaks signed on, and "interferes" much as TJ does here. Add LP's in Arcadia and Pacoima, also. Heck, what about KRTHs reduced coverage here
in San Diego, from KGB's digital jamming?
Also, KPFK is not in the "border zone".

Big 121

 

[SML]

Suggestion: Shift Some Tijuana Stations (Oct 21, 2010)

The ongoing problem with Tijuana's radio station at 90.7 Mhz interfering with KPFK's 90.7 FM radio station in Los Angeles has been going on for almost three months. That's not the first time it's been going on.

And since FCC rules give grandfathered stations the ongoing use of their superpower statues without any more protecction than that of a conforming operation, KPFK has no claim to coverage in San Diego County. Mexico is well within the regulations of the Comision Mixta in using the channel in Tijuana.

Actually, KPFK is interfering with a Mexican conforming allocation. They could save some money and reduce power.

KPFK has been on the air since 1959, first with 75KW, and then soon after 110KW. The FCC granted them a license, and the grandfathered super-power status remains on the books. Mexico granted Victor Diaz a license for 90.7 about ten years ago based upon a low power signal that would not overlap KPFK in the United States. Victor then built XHLNC at a much higher power and was proud of the fact that he was able to do so. Big deal, so what? He did not care. Despite running over 30 times the SCT licensed power, XHLNC received so many complaints about poor coverage due to KPFK's signal being stronger than XHLNC in many places in San Diego County that XHLNC petitioned the SCT for another frequency and moved out of the way.
So somebody else was watching, and decided to try and improve their coverage over San Diego too, and now they are on the air on 90.7 mhz and suffering the same poor coverage as XHLNC. Too bad, so sad. This is not KPFK's fault.

If the new station at 90.7 does not like the fact that KPFK is there, there is little they can do about it. KPFK is not going away. The SCT has no power over how KPFK operates.

And David, your idea about KPFK reducing power and saving money sucks eggs. Tijuana can just turn up their power if they want, and I expect they will when faced with such a poor signal in San Diego (their target market). Nobody north of the border can force compliance with the treaty on stations south of the border.
Meanwhile, KPFK is now on the air in mid-county San Diego on 93.7 mhz. It does not help the areas inside KPFK's protected coverage area (Oceanside and points north) that receive interference from Mexico, however. Only some common sense from south of the border would solve that.
And nobody at KPFK is holding their breath in hopes of that.

 

[davideduardo]

So somebody else was watching, and decided to try and improve their coverage over San Diego too, and now they are on the air on 90.7 mhz and suffering the same poor coverage as XHLNC. Too bad, so sad. This is not KPFK's fault.

"Somebody" is MVS / Multivision, a major, major operator of radio (nearly 100 stations in Mexico as well as in Central and South America), TV, Cable, Broadband, and publishing divisions. This is a company that has competent engineers and legal advisors and we can safely assume that they knew what they were getting when applying for 90.7.

The founder of MVS was a pioneer, in the 60's, of FM in Mexico and MVS continues to be a significantly family run business. When Joaquin Vargas applied for multiple FM licences, most thought him deranged and predicted FM would not work in Mexico; today Mexico is trying to eliminate all AM stations because they are not economically viable. This is a company with a tradition of visionary entrepreneurial actions.

If the new station at 90.7 does not like the fact that KPFK is there, there is little they can do about it. KPFK is not going away. The SCT has no power over how KPFK operates.

I don't think anyone from MVS has complained about KPFK. We have to assume they knew what the conditions on the channel were , and found that the frequency would adequately serve Mexico's 6th largest market, Tijuana, BCN, Mexico.

And David, your idea about KPFK reducing power and saving money sucks eggs.

As many have said, sarcasm does not always come across on the web. My point is that KPFK has so little audience in SD County (it has shown up one time in the last 18 ratings books, with a listening level of 200 persons) that they could scale the operation given the self-expressed problems with having nearly no listening in the LA market and feeling the pressures of diminished fund raising.

The reception of KPFK in San Diego County is the very least of KPFK's issues.

Tijuana can just turn up their power if they want, and I expect they will when faced with such a poor signal in San Diego (their target market).

Since it has been stated that the idea is to move the La Mejor operation from 97.7 to the new channel. Since 97.7 is the Tijuana opration of La Mejor, your statement on the target market is just wrong. La Mejor operates the same format on two FMs, one with commercials and content for SD and one for Tijuana. The one that appears destined to move to 90.7 is the Tijuana operation, which has no interest in the SD market.

Meanwhile, KPFK is now on the air in mid-county San Diego on 93.7 mhz. It does not help the areas inside KPFK's protected coverage area (Oceanside and points north) that receive interference from Mexico, however.

KPFK is not protected to the existing contours of the grandfathered operation. It is protected to the limits of a conforming station, whose 54 dbu would barely touch Santa Ana in northern Orange County, not Oceanside.

Only some common sense from south of the border would solve that. And nobody at KPFK is holding their breath in hopes of that.

There is no requirement to protect KPFK in San Diego County. I can point out a number of instances where new or improved US stations have interferred with the real signals of grandfathered LA stations but the FCC has granted the applications because the FCC does not protect grandfathered contours, just the conforming signals. Why would you expect the SCT to protect US grandfathered contours when the FCC does not?

 

[SML]

As many have said, sarcasm does not always come across on the web. My point is that KPFK has so little audience in SD County (it has shown up one time in the last 18 ratings books, with a listening level of 200 persons) that they could scale the operation given the self-expressed problems with having nearly no listening in the LA market and feeling the pressures of diminished fund raising.

The reception of KPFK in San Diego County is the very least of KPFK's issues.

Mr. Gleason, non-commercial radio is driven by individual listeners, often at the fringes of the station's signal. KPFK does not give a crap about market share, surveys and your opinion.

Since it has been stated that the idea is to move the La Mejor operation from 97.7 to the new channel. Since 97.7 is the Tijuana opration of La Mejor, your statement on the target market is just wrong. La Mejor operates the same format on two FMs, one with commercials and content for SD and one for Tijuana. The one that appears destined to move to 90.7 is the Tijuana operation, which has no interest in the SD market.

Signals don't respect borders, and owners of commercial operations change their minds. Money is the driver of their decision making, so what is true today may or may not be true on Tuesday next week.

"KPFK is not protected to the existing contours of the grandfathered operation. It is protected to the limits of a conforming station, whose 54 dbu would barely touch Santa Ana in northern Orange County, not Oceanside."

Mr. Gleason, you don't know what you are talking about (not the first time that hubris is trying to overcome facts, of course). According to the treaty, KPFK is protected to 92 kilometers from Mt Wilson, and to achieve that 60 dbu contour would require 44 kilowatts ERP from the tower at Mt. Wilson. The 92 Kilometer line from Mt Wilson is south of San Clemente, and somewhat on the border of the Pendelton Marine Base. If we could trust that our counterparts south of the border would actually operate at the power levels and directional patterns presented to the International Bureau of the FCC, then KPFK would have no right to complain. But based upon recent history, operators south of the border cannot be trusted to tell the truth about their actual operating parameters. I've looked at the facilities, and they can't be trusted.

And based upon the amount of interference that KPFK is receiving in Los Angeles itself from this facility, one could assume that something is not quite as it should be. This interference is happening despite the fact that KPFK is operating as a grandfathered, super-power B with 110KW.

Mexican watts indeed...


[quote} There is no requirement to protect KPFK in San Diego County. I can point out a number of instances where new or improved US stations have interferred with the real signals of grandfathered LA stations but the FCC has granted the applications because the FCC does not protect grandfathered contours, just the conforming signals. Why would you expect the SCT to protect US grandfathered contours when the FCC does not?
[/quote]


KPFK pre-dates all of the stations in question by decades. And the FCC did not grant anything, as the station in question is in Mexico, and not under the authority of the US Government. The FCC international bureau currently has a standing objection to the operation of the new 90.7 in Tijuana, for all the good that does. At the next bi-annual meeting between the IB and SCT, they will discuss this, of course. And despite your assertions, the KPFK 60 dbu is protected to a line that includes an area of Northern San Diego County.

Once again, you don't seem to understand or care about the problem caused by operators south of the border. Gee, what a surprise!

 

[radio-darn]

KPFK does not give a crap about market share, surveys and your opinion.

I don't know how they feel about Dave's opinon or his acts, but they sure as heck give a crap about the ratings:

From: Alan Minsky
To: programmers ; staff

Sent: Wed, July 21, 2010 11:31:22 AM
Subject: Important Letter to KPFK Programmers

Dear KPFKers,

We’ve reached a critical point at KPFK, as the painful length of our recent fund drive betrayed.

At the beginning of my time as iPD, I was instructed by the National Office to increase the station’s listeners; in particular, as measured by the Arbitron numbers. This has occurred. Through the beginning of June, the listenership for the station had steadily risen from 120,000 before the fall 2009 programming changes up to a plateau of 180,000. This is great.

However, the increase in audience is weighted almost entirely in our Monday through Friday morning programming – in essence from 6am until 1pm – while 5pm is also substantially out-performing what was there before. With only a few exceptions, the afternoon, evening, and weekend programming is dramatically underperforming by this measurement.

You can read the rest of it at http://www.indybay.org/newsitems/2010/07/21/18654452.php

 

[davideduardo]

Mr. Gleason, non-commercial radio is driven by individual listeners, often at the fringes of the station's signal. KPFK does not give a crap about market share, surveys and your opinion.

A large percentage of full signal non-commercial stations are Arbitron subscribers.

While commercial stations principally use Arbitron data for sales, and only secondarily for programming, non-coms use the data to make programming decisions so that they can reach the intended audience and fine tune or change programming that weakens appeal... and donations. Another difference is that non-coms program more like TV with block programming, so individual show listening is quite important.

As radio-darn says state in a separate post, the folks at KPFK do care a lot about market share and surveys (two "euphemisms" for ratings).

The one that appears destined to move to 90.7 is the Tijuana operation, which has no interest in the SD market.

Signals don't respect borders, and owners of commercial operations change their minds. Money is the driver of their decision making, so what is true today may or may not be true on Tuesday next week.

The border stations run by the major Mexican groups, as a rule, don't have a great interest in the US markets at the other side of the border as their sales is almost entirely based on the national coverage of dozens of stations in a format (La Mejor is on about 30 stations, Exa on nearly 50). And in MVS's case, when they go after the US market they use a separate facility to run the same format with different spots.

And even if they do go for more SD appeal (which means a new and separate format... something MVS has never done at the local level) that still does not change the fact that KPFK is not protected in SD county. I am only pointing out that your statement about the format they have announced for 90.7 is NOT aimed at SD, as they already have a signal that does that for the formatl

"KPFK is not protected to the existing contours of the grandfathered operation. It is protected to the limits of a conforming station, whose 54 dbu would barely touch Santa Ana in northern Orange County, not Oceanside."

Mr. Gleason, you don't know what you are talking about (not the first time that hubris is trying to overcome facts, of course). According to the treaty, KPFK is protected to 92 kilometers from Mt Wilson, and to achieve that 60 dbu contour would require 44 kilowatts ERP from the tower at Mt. Wilson. The 92 Kilometer line from Mt Wilson is south of San Clemente, and somewhat on the border of the Pendelton Marine Base. If we could trust that our counterparts south of the border would actually operate at the power levels and directional patterns presented to the International Bureau of the FCC, then KPFK would have no right to complain. But based upon recent history, operators south of the border cannot be trusted to tell the truth about their actual operating parameters. I've looked at the facilities, and they can't be trusted.

Every reference I have in FCC rules, and also in the Spanish language Comisión Mixta documents which I have read shows protection to conforming operations per the notified class of each station. If you have documents that state that actual operations as opposed to protection by class is required, I would like to see a link or reference and would also be pleased to appologize; if you have such documentation it necessarily contradicts the rules Mexico is running the SCT under which are by class.

It's certainly possible that the SCT thinks it is respecting by class and the FCC or stations licensed by the FCC think that the licensed facility is to be respected. It would not be the first nor the last case where different nations interpret mutual agreements differently.

And based upon the amount of interference that KPFK is receiving in Los Angeles itself from this facility, one could assume that something is not quite as it should be. This interference is happening despite the fact that KPFK is operating as a grandfathered, super-power B with 110KW.

And even the FCC does not protect either the power or the height beyond the limits of a conforming facility... which at the average Wilson site would not even 1/20th of the KPFK power.

There is no requirement to protect KPFK in San Diego County. I can point out a number of instances where new or improved US stations have interferred with the real signals of grandfathered LA stations but the FCC has granted the applications because the FCC does not protect grandfathered contours, just the conforming signals. Why would you expect the SCT to protect US grandfathered contours when the FCC does not?

KPFK pre-dates all of the stations in question by decades.

Most of the Wilson grandfathered facilities are from the same era as KPFK. In fact, the original sign-on KPFK facility was 75 kw in 1959... the upgrade to 110 kw was not built until '63 or '64. By late '62, at least 92.3, 101.1, 107.5, 102.7, 93.1, 94.7, 95.5, and 105.1 were also at superpower status. Many of not all have seen stations put on the air that protect the conforming signal but not the grandfathered signal.

I was referring to US stations licensed by the US FCC which respect the US protection afforded to US grandfathered stations but not the US grandfathered facility.

And the FCC did not grant anything, as the station in question is in Mexico, and not under the authority of the US Government.

Reread what I wrote. Your rage against things Mexican seems to have caused you to misread the statement I made to the effect that the FCC has licenced many stations over the years that would violate protection requirements for grandfathered facilities were it not for the fact that such facilities are protected only to the extent of a conforming facility at the same location.

The FCC international bureau currently has a standing objection to the operation of the new 90.7 in Tijuana, for all the good that does.

An attempt was made, for political reasons, to object to the Víctor Díaz operation, but it did not prosper as the operation was deemed proper by its licencing authority. The Comisión Mixta does not have the force of law; it is intended to be a channel of communication but Mexico can license, at the end of the day, whatever it wants.

Once again, you don't seem to understand or care about the problem caused by operators south of the border. Gee, what a surprise!

As I mentioned, the FCC does not seem to be able to keep daytimers from operating at night or DA-N or DA-2 facilities from using superior day facilities at night... or to enforce CH operations. It would be nice to apply the same standard of judgement everywhere. The idea that other countries should jump when we say so is as outdated as the Monroe Doctrine.

 

[w9wi]

Every reference I have in FCC rules, and also in the Spanish language Comisión Mixta documents which I have read shows protection to conforming operations per the notified class of each station. If you have documents that state that actual operations as opposed to protection by class is required, I would like to see a link or reference and would also be pleased to appologize; if you have such documentation it necessarily contradicts the rules Mexico is running the SCT under which are by class.

Not that I'm necessarily agreeing with Don Mussell, but... specifically within the FCC Rules, the regulation (73.209) which limits superpower FM stations' protection radius to that of a maximum-facility conforming station does not appear to apply to non-commercial stations. So KBIG-104.3's protected radius would be limited to the equivalent of 50kw/150m but it looks to me as if, at least as far as the rules themselves are concerned, KPFK's would be limited only by their actual 60dBu contour. (see 73.509)

The Four Disclaimers:
1. As I understand it, international treaties trump domestic rules. I don't know what's in the US-Mexico treaty - there may be something there that does limit the protection of superpower stations.
2. I am not a lawyer.
3. While I don't see the 73.209 limit on protection of superpower stations, I also don't see the looser 54dBu standard for protection of Class B stations. As I read 73.509, all non-commercial stations are protected to 60dBu regardless of class. Which means KPFK's protected radius would be 103km, not 120. Whether a 103km radius from KPFK's tower would reach San Diego County I have no idea.
4. If you don't like my opinions, you're entitled to a full refund of my fees.

 

[davideduardo]

Not that I'm necessarily agreeing with Don Mussell, but... specifically within the FCC Rules, the regulation (73.209) which limits superpower FM stations' protection radius to that of a maximum-facility conforming station does not appear to apply to non-commercial stations. So KBIG-104.3's protected radius would be limited to the equivalent of 50kw/150m but it looks to me as if, at least as far as the rules themselves are concerned, KPFK's would be limited only by their actual 60dBu contour. (see 73.509)

The Four Disclaimers:
1. As I understand it, international treaties trump domestic rules. I don't know what's in the US-Mexico treaty - there may be something there that does limit the protection of superpower stations.
2. I am not a lawyer.
3. While I don't see the 73.209 limit on protection of superpower stations, I also don't see the looser 54dBu standard for protection of Class B stations. As I read 73.509, all non-commercial stations are protected to 60dBu regardless of class. Which means KPFK's protected radius would be 103km, not 120. Whether a 103km radius from KPFK's tower would reach San Diego County I have no idea.
4. If you don't like my opinions, you're entitled to a full refund of my fees.

Good discussion points all. I concur with #2 and add myself to the non-lawyer list, too. ;D

I pulled the agreement in force and the ammended table of separations and what I see is that the criteria is based on "Class to Class" separation for adjacents, next adjacents, etc.

(I posted the agreement and the table at http://www.davidgleason.com/Radio_Archives.htm where they are viewable as PDF's as "Agreement" and "Table" at the lower left of the page below the view counter.)

I also see from the US side that all non-conforming "existing operations" meaning grandfathered stations were submitted as C's, whether commercial or non-commercial. In fact, in dealing with Mexico, the "sells ads" distinction is hard to make as 88 to 92 is not a non-commercial portion of the band in XH- territory.

The FCC rules do not allow C's where B's are the maximum facility standard (although we have things like Super B's and Super A's in Puerto Rico). My prior read of the CRT regulations showed that Mexico believes that a B is the maximum facility in the part of the border zone in discussion... this is confused by the inconsitency of having two C's in Tijuana, one with 100 kw and one with 93 kw in the notification Mexico made.

So, were KPFK to be considered a C by Mexico, Mexico would have to space 226 km from KPFK to licence both a class AA (6 kw @ 100 meters) station and its site in Mexico. That's 140 miles, and doable for Tijuana's southern-side transmitter hills. If Mexico considers KPFK to be a B, then another full conforming B could be put in at 147 miles, also feasable.

The important distinction is that while contour projections were used to establish the separation distances, individual station contours are not mentioned. The keys to allocations are Class and distance, and the table shows the separations for co-channel, adjacent, etc.., for every class to every other class. Interestingly, the agreement and the SCT internal rules both mention protecting class even if a lesser facility is built, but make no mention of stations operating in excess of the definitions of each class (also included in the documents).

One of the issues here is "interpretation" as we are dealing with separate nations, different languages (where a similar sounding or looking word may have a very different meaning) and somewhat different cultures. Any diplomatic negotiation, and that is essentially what the Mixed Commission is, is very subject to give and take or even push and shove. In today's spectrum usage world, it's easy to see how a bit of interference to some radio station "a long way from its city of license" could be given in on when the main focus of a Mixed Commission meeting is coordinating new cellular and broadband services where big money and politics are involved on both sides of the border.

I think this is a lot more about the US Government's attitude towards spectrum and overall cooperation with its neighbors than being about whether Mexico is or is not lax in policing its licencee's operation of FM facilities.

 

[radio-darn]

I don't know how they feel about Dave's opinon or his acts

Or his facts...

:

 

[SML]

Bla, bla, bla, bla...

Since speculation is more fun for you than reality, I'll just simply state that things are the way they are, and are not going to change much. Since I have been Pacifica's consulting engineer these last 20 years or so, working with the International Bureau of the FCC, along with the FCC field office in San Diego, we know what we are dealing with. And the playing field is far from level, and Mexico is not suffering at all.
You can speculate about the working agreement and what you think it all means, but the bottom line for KPFK is that the use of 90.7 in Tijuana was not the bright idea of the SCT, but by private business concerns, and they knew where to invest to get the results they desired. This "system", such as it is, is different from the way the FCC operates in the United States.

Have fun speculating. But the cows already came home.

 

[radio-darn]

Since I have been Pacifica's consulting engineer these last 20 years or so...

You should ask to get on the KPFK memo loop so you won't make anymore public gaffes about their alleged lack of concern for the ratings.

 

[davideduardo]

You can speculate about the working agreement and what you think it all means, but the bottom line for KPFK is that the use of 90.7 in Tijuana was not the bright idea of the SCT,

Just as most of the 13,000 or so radio stations in the US were not the "bright idea" of the FCC. In the case of AM, somebody did engineering, applied for a frequency, and hoped they might be granted. FM has the intermediate step of the table of allocations, but the idea is the same... apply for an allocated channel, or petition for a channel to be ammended and hope for a grant.

The rather brilliant engineers at MVS... a company that was founded to apply for positions in the nearly empty FM band in Mexico (where any use of FM was generally as an STL) and did some amazing engineering in harsh conditions to develop FM... found an opportunity to apply for 90.7 following the move of XHLNC. They filed, and got a grant which meets the border zone separation requirements.

The bright idea was that of MVS. Not everyone can get a new facility in the 6th largest market (the equivalent of getting a new FM in Washington, DC in this country) but MVS managed.

but by private business concerns, and they knew where to invest to get the results they desired.

Your unsubstatiated and ungrounded accusation of wrongdoing and impropriety is noted. We know you don't like anything Mexican already, though. No need to say it again.

This "system", such as it is, is different from the way the FCC operates in the United States.

Yes, in Mexico a station that runs programming inciting armed revolution, massacre and violence would not be tolerated. Yet that is just what a number of the Spanish language programs on KPFK espouse.

You probably are referring, though, to things like bribes, influence and such. Tell me again, why did General Tire lose some licenses, and was forced to dispose of all the others it had? Why was Don Burden stripped of his licenses?

Have fun speculating. But the cows already came home.

And the byproduct of the cows is the "estiércol" in the Spanish language shows on KPFK.

 

[w9wi]

I pulled the agreement in force and the ammended table of separations and what I see is that the criteria is based on "Class to Class" separation for adjacents, next adjacents, etc.

(I posted the agreement and the table at http://www.davidgleason.com/Radio_Archives.htm where they are viewable as PDF's as "Agreement" and "Table" at the lower left of the page below the view counter.)

(Very interesting, appreciated!)

I also see from the US side that all non-conforming "existing operations" meaning grandfathered stations were submitted as C's, whether commercial or non-commercial. In fact, in dealing with Mexico, the "sells ads" distinction is hard to make as 88 to 92 is not a non-commercial portion of the band in XH- territory.

The FCC rules do not allow C's where B's are the maximum facility standard (although we have things like Super B's and Super A's in Puerto Rico). My prior read of the CRT regulations showed that Mexico believes that a B is the maximum facility in the part of the border zone in discussion... this is confused by the inconsitency of having two C's in Tijuana, one with 100 kw and one with 93 kw in the notification Mexico made.

It does seem that most L.A. stations (including KPFK) and the Tijuana stations on 90.3 and 91.1 are notified as Class C. I would imagine that would simply make sense.. as these stations were already operating at facilities well above Class B figures for decades when the treaty was signed in 1992.

Yes, I rather figured there would be some differences in the treatment of non-commercial stations domestically and internationally; the idea of reserving 88-92 for non-commercial stations is strictly a U.S. concept.

So, were KPFK to be considered a C by Mexico, Mexico would have to space 226 km from KPFK to licence both a class AA (6 kw @ 100 meters) station and its site in Mexico. That's 140 miles, and doable for Tijuana's southern-side transmitter hills. If Mexico considers KPFK to be a B, then another full conforming B could be put in at 147 miles, also feasable.

The important distinction is that while contour projections were used to establish the separation distances, individual station contours are not mentioned. The keys to allocations are Class and distance, and the table shows the separations for co-channel, adjacent, etc.., for every class to every other class. Interestingly, the agreement and the SCT internal rules both mention protecting class even if a lesser facility is built, but make no mention of stations operating in excess of the definitions of each class (also included in the documents).

True, and that's really not any different from U.S. domestic procedure. It looks to me as if the important concept here is that KPFK (and most other LA stations) are considered Class B domestically but Class C for the purposes of the US/Mexico Agreement. Now, the LA stations are so far above nominal Class B facilities that most of them even exceed Class C numbers! -- but at least if they're regarded as Class C internationally it's not quite as out of hand as it might be.

 

[davideduardo]

True, and that's really not any different from U.S. domestic procedure. It looks to me as if the important concept here is that KPFK (and most other LA stations) are considered Class B domestically but Class C for the purposes of the US/Mexico Agreement. Now, the LA stations are so far above nominal Class B facilities that most of them even exceed Class C numbers! -- but at least if they're regarded as Class C internationally it's not quite as out of hand as it might be.

A real issue here is that the Comefer / SCT documents I have read (as part of a separate review related to due diligence) do not recognize Class C's in the US, apparently and by inference because they show A's and B's (and their subsets for the area actoss the border from Mexicali to Tijuana. While the US notified the grandfathered stations as C's for the most part, Mexico seems to consider them as B's. And since the Mixed Commission is purely "transactional" in the sense that things are negotiated (yeah, I know, you can't negotiate the Laws of Physics) and trade-offs are made, it's very possible if not probable that the US will not press on this relatively minor point when much bigger things are in play. And, since this is not a treaty (which would be negotiated by the Department of State, not an office at the FCC) there is not much that can be done in the way of appealing a decision or omission.

At least the Mixed Commission exists; I worked both with several stations and the PRBA to get resolution of protection requirements for non-existent Dominican Republic stations and it was illegal to contact the Dominican government or even the stations directly since doing so would violate an assortment of diplomatic procedures, treatys and laws. Of course, Canada has thinned the herd on the AM band, yet stations on frequencies now vacated there can't file for improved facilities because we still protect extinct stations and allocations (most coming from Pre-W.W. II NARBA) when the face of radio has changed.

Totally removed, but related to "international agreements" I once got a letter from the US of A's FCC at my station HCFV1 in Quito, Ecuador, stating that the station was operating on a frequency that was not allowed or permitted (I forget the exact term) by international agreements. So what? The station was licensed by Ecuador and was legally operating per the rules, laws and regulations of that nation. I still wonder who at the FCC thought that writing to the owner of a station in a foreign country was going to compel that person to change their licensed operation... several friends who owned stations got similar letters. Oh, yeah, HCFV1 was on 805 kcs.

 

[SML]

The rather brilliant engineers at MVS... a company that was founded to apply for positions in the nearly empty FM band in Mexico (where any use of FM was generally as an STL) and did some amazing engineering in harsh conditions to develop FM... found an opportunity to apply for 90.7 following the move of XHLNC. They filed, and got a grant which meets the border zone separation requirements.

The bright idea was that of MVS. Not everyone can get a new facility in the 6th largest market (the equivalent of getting a new FM in Washington, DC in this country) but MVS managed.

Your unsubstatiated and ungrounded accusation of wrongdoing and impropriety is noted. We know you don't like anything Mexican already, though. No need to say it again.

Yes, in Mexico a station that runs programming inciting armed revolution, massacre and violence would not be tolerated. Yet that is just what a number of the Spanish language programs on KPFK espouse.

You probably are referring, though, to things like bribes, influence and such. Tell me again, why did General Tire lose some licenses, and was forced to dispose of all the others it had? Why was Don Burden stripped of his licenses?

And the byproduct of the cows is the "estiércol" in the Spanish language shows on KPFK.

Brilliant indeed. Brilliant opportunists are worldwide, and we have a share of that type up here too. And David (that is your real name, right?), I never implied I did not like anything Mexican. That was something you manufactured out of thin air, as near as I can tell. There are plenty of sleazy American business people too. Equal time for all!
I guess if I was running a radio station in Juarez these days, I would not dare run anything on the air that suggested that the drug cartels might have some bad ideas. Yeah, it is a great time in Mexico these days. Nice climate I hear too.

Bla, bla, blaaah....