Denver KTLF runs into translator issues for the Denver metro

[Mark Roberts]

Earlier this year, Colorado Springs-based Christian broadcaster KTLF got a CP to change K213EG from 90.5 to 90.7 and increase power from 3 to 250 watts. This would give it a signal comparable to other Lookout Mountain-based translators, including K292FM at 106.3, which already rebroadcasts KTLF into Denver.

So it seems a little strange for KTLF to seek a second translator, but hold that thought.

KTLF broadcasts in Colorado Springs on a noncommercial educational (NCE) channel. There's no issue repeating such a station on a commercial channel, but the reverse doesn't hold.

KTLF asked the FCC to change the primary station for K213EG from KLDV, K-Love's primary outpost in Denver, to KQMT-HD3, an HD channel on a commercial station. This effectively was a request for a waiver of FCC policy. KTLF already uses KQMT-HD3 to feed K292FM. According to a petition for reconsideration that KTLF's parent, Educational Communications of Colorado Springs, has filed, the FCC's Media Bureau denied the request in an email on June 26.

The email is in an exhibit to the petition, and explains the Media Bureau's rationale for denying the request:

You are proposing to rebroadcast HD3 of KQMT-FM requesting a waiver stating that the HD3 will be NCE (non-commercial educational) programming.

Regardless of the programming on KQMT-FM HD3, the authorization can not (sic) list KQMT-FM as K213EG primary station since KQMT-FM is a commercial station. We have denied this request in the past and we are in agreement that this will not change.

The Commission staffer then instructed KTLF to return to rebroadcasting KLDV on K213EG. I haven't checked to see if that's been done, because those three watts don't really make it to my location, but I'm going to assume good faith here.

The new petition, filed July 15, states that "the denial does not discuss the reason why the waiver should not be granted." The petition argues that this implies that there hasn't been the level of review required by the Administrative Procedures Act. The petition goes on to argue that the intent of FCC regulation isn't violated by changing the primary station to KQMT-HD3 because it is carrying noncommercial programming.

One odd thing here is that a translator with just about the same amount of coverage that the NCE translator (K213EG will have K214FV calls, judging by the filing) is slated to have already rebroadcasts KTLF's programming. It's true that KTLF has four programming services. But, unless KTLF uses another method to rebroadcast a service other than its "Light" contemporary-music channel, which I believe it could do, it's proposing airing the same thing on both translators that cover equivalent areas. Puzzling.

While the longstanding FCC policy on translators wasn't explained well in the email, it was referenced, and a licensed broadcaster should have been familiar with it.

It could be argued that this is a religious broadcaster asking for special treatment, but the practical argument isn't entirely crazy. Use of the HD channel is a cost-efficient way of feeding the translators.

Whether KTLF's arguments go anywhere remains to be seen. The FCC seems to have been handing out waivers like tissues in a box lately; the fact that this one was denied could appear inconsistent with the Commission's approach. But, again, it's something Educational Communications of Colorado Springs should have understood...and it's something for which, I believe, alternatives are available.

That's not to mention that KTLF has a pretty robust online presence already. It makes me wonder why they're even bothering.

Edit to add link to the filing: Pleadings « License Modernization « FCC

 

[Richard Sanders]

Earlier this year, Colorado Springs-based Christian broadcaster KTLF got a CP to change K213EG from 90.5 to 90.7 and increase power from 3 to 250 watts. This would give it a signal comparable to other Lookout Mountain-based translators, including K292FM at 106.3, which already rebroadcasts KTLF into Denver.

So it seems a little strange for KTLF to seek a second translator, but hold that thought.

KTLF broadcasts in Colorado Springs on a noncommercial educational (NCE) channel. There's no issue repeating such a station on a commercial channel, but the reverse doesn't hold.

KTLF asked the FCC to change the primary station for K213EG from KLDV, K-Love's primary outpost in Denver, to KQMT-HD3, an HD channel on a commercial station. This effectively was a request for a waiver of FCC policy. KTLF already uses KQMT-HD3 to feed K292FM. According to a petition for reconsideration that KTLF's parent, Educational Communications of Colorado Springs, has filed, the FCC's Media Bureau denied the request in an email on June 26.

The email is in an exhibit to the petition, and explains the Media Bureau's rationale for denying the request:

You are proposing to rebroadcast HD3 of KQMT-FM requesting a waiver stating that the HD3 will be NCE (non-commercial educational) programming.

Regardless of the programming on KQMT-FM HD3, the authorization can not (sic) list KQMT-FM as K213EG primary station since KQMT-FM is a commercial station. We have denied this request in the past and we are in agreement that this will not change.

The Commission staffer then instructed KTLF to return to rebroadcasting KLDV on K213EG. I haven't checked to see if that's been done, because those three watts don't really make it to my location, but I'm going to assume good faith here.

The new petition, filed July 15, states that "the denial does not discuss the reason why the waiver should not be granted." The petition argues that this implies that there hasn't been the level of review required by the Administrative Procedures Act. The petition goes on to argue that the intent of FCC regulation isn't violated by changing the primary station to KQMT-HD3 because it is carrying noncommercial programming.

One odd thing here is that a translator with just about the same amount of coverage that the NCE translator (K213EG will have K214FV calls, judging by the filing) is slated to have already rebroadcasts KTLF's programming. It's true that KTLF has four programming services. But, unless KTLF uses another method to rebroadcast a service other than its "Light" contemporary-music channel, which I believe it could do, it's proposing airing the same thing on both translators that cover equivalent areas. Puzzling.

While the longstanding FCC policy on translators wasn't explained well in the email, it was referenced, and a licensed broadcaster should have been familiar with it.

It could be argued that this is a religious broadcaster asking for special treatment, but the practical argument isn't entirely crazy. Use of the HD channel is a cost-efficient way of feeding the translators.

Whether KTLF's arguments go anywhere remains to be seen. The FCC seems to have been handing out waivers like tissues in a box lately; the fact that this one was denied could appear inconsistent with the Commission's approach. But, again, it's something Educational Communications of Colorado Springs should have understood...and it's something for which, I believe, alternatives are available.

That's not to mention that KTLF has a pretty robust online presence already. It makes me wonder why they're even bothering.

Edit to add link to the filing: Pleadings « License Modernization « FCC

First, congrats to ECOCS for some creative engineering. It looks like they bought K214FJ and swapped channels with their existing K213EG to create a really nice 250 watt translator now being called K214FV. Did I get that right?

Translator rules give me a headache, so I’m curious about the alternatives you see available. It looks to me like KLDV fills its HD channels with other K-Love offerings. So, if KTLF wants to air its own programming, then it doesn’t seem like a KLDV HD channel is a viable alternative?

 

[Mark Roberts]

First, congrats to ECOCS for some creative engineering. It looks like they bought K214FJ and swapped channels with their existing K213EG to create a really nice 250 watt translator now being called K214FV. Did I get that right?

That is the proposal, along with moving K214FJ farther north to cover Boulder and Broomfield. I don't think these moves have been implemented yet. K214FJ (which will go to 213) is on a slient STA. K213EG (to go to 214) is not receivable at my location at all. If the moves had happened, I think I would hear something at 90.7 but, as of today, nothing's there at my location.

I wouldn't say the translator is "nice". It will be comparable in coverage to most other translators that are on Lookout Mountain. But much of the eastern metro, particularly including Aurora, doesn't get a city-grade signal from anything low-powered on Lookout. I'll probably get noisy reception at best.

Translator rules give me a headache,

No kidding! But, wait! It gets worse!

It looks to me like KLDV fills its HD channels with other K-Love offerings.

It does: Air1 on HD-2, Radio Nueva Vida on HD-3. K-Love has a translator for Air1 on 103.9 as well, but that barely makes it to Edgewater from Lookout.

So, if KTLF wants to air its own programming, then it doesn’t seem like a KLDV HD channel is a viable alternative?

Probably not.

But here's the thing: the current primary for K214FJ is apparently KBEI, Brush, CO, via an Internet feed. Reliable off-the-air pickup is highly unlikely at K214FJ's location, given that KBEI is a one-kilowatt station roughly 100 miles away. (This information is according to fccdata.org, which occasionally gets it wrong, but usually the information on individual station pages is correct as long as the FCC's own data have been updated.) KBEI is an NCE station owned by ECCS, but ECCS doesn't list it in its program guide. Moreover, the complete TOH ID on KQMT-HD3, which lists all the stations of "The Light", lists a translator in Brush and not KBEI. So, without making a trip up I-76 to Brush, I don't have a way of knowing what KBEI is airing, since ECCS has more than one service. Since K214FJ is currently silent, that forecloses that translator as a source of information.

The point behind all this headache-inducing information is that ECCS should be able to use one of its NCE stations as the primary for the new K214FV. The NCE rules are looser than the commercial rules for translators with regard to the program source; ECCS should be able to get an Internet feed to the site. Lookout Mountain is by no means remote and there's plenty of wiring up there already. So I'm puzzled as to why ECCS wants to stick with KQMT-HD3 as the primary, other than convenience and, possibly, a small increment in cost. I don't want to attribute motive here, so I'll leave the question open regarding what ECCS is trying to accomplish with its petition for reconsideration.

Here's the list of ECCS stations, by the way, at least as of two years ago: https://ktlf.radio/wp-content/uploads/2024/08/KTLF-Program-Guide.pdf - there have been changes since then.