I feel there should be a cap on how many translator stations can be applied for by the same entity.
Some people -- myself and
@Michi among them -- feel there should be such a cap, applying not just to translators but to non-comms owning full power stations.
However, the biggest of the latter -- EMF -- has already gotten so big, you couldn't enforce a cap without either forcing divestitures (I can hear them whining already) or grandfathering existing ownership (meaning it's a non-solution "solution".
I do have some fears that it could be messy because there is already so much on the FM dial and I'm afraid of interference issues.
There are rules about translators that are already in place and do a decent job of keeping everyone's signal protected from everyone else's.
I also truly wonder how on earth these Translator stations will even be able to operate at the normal 250 Watts that I always hear about.
Well, as
@fybush just pointed out, the NCE part of the FM band (which is the only place this proposed filing window would be implemented) is already overcrowded anywhere that anyone would want to try to squeeze in a translator.
Taking L.A. as an example (there's only one market that's larger),
every frequency between 88 and 92MHz is occupied by either a full-power station or one of those stations' boosters or translators. Even if Carr's proposal were to be implemented, the "filing window" would result in no applications for 100 miles around here.
I checked all of the Class D stations in the area, and none of them have an ERP above 100 watts. That is a general indicator that they are at the extreme edges of becoming short-spaced (which is not allowed under FCC rules, nor are waivers for same ever given to Class D stations).
There are some areas where a 250 watt translator gives very good coverage. There are several on the commercial band in Albuquerque, including one station I program for its owner. But anyone dreaming of 250w ERP in already-crowded areas should throw away the pipe they are dreaming with.