slim101 said:
I think you know how to reach me if you'd like to talk further. In the mean time, it might be useful to read the entire quote from the FCC's translator rules, rather than the good Inspector's abbreviated version. Since this is public information, and not copyrighted, I think it is OK to paste it here. I think you will discover that there are several loop-holes which are frequently exploited.
Chuck, I am curious as to what rules you think are "exploitable"?
Like Clouseau, I am an engineer and a translator owner, so I follow the rules as precisely as I can.
Jim Bradshaw at the FM branch has denied several of my waiver requests for alternative feed methods in very bad receive situations (nothing unusual about that, so just put up with it), and has made it very clear that non-reserved band translators must be fed an off-air signal received directly off the air
at the translator site.
The only way around it is to be well connected with "bridge to nowhere" Ted Stevens.
...And so we struggle on with phased receive antennas and banks of pass/notch cavities.
I am looking forward to the improved signal quality from rebroadcasting the local AM stations!
It is not really my job to defend what others are doing. I'm a "technician" not a licensed professional engineer nor am I an attorney. I have been working professionally in electronics for well over 40 years, and as it happens, I am married to an attorney. Perhaps some of that has rubbed off.
I have been informed that the signal must be received at the translator site, and that is what I practice. Not everyone does. Let's look at the rules to see what they hang their hats on:
"(a) FM translators provide a means whereby the signals of FM broadcast
stations may be retransmitted to areas in which direct reception of such FM
broadcast stations is unsatisfactory due to distance or intervening terrain
barriers."
OK, so if "direct reception of such FM broadcast stations is unsatisfactory," how is the translator supposed to get a satisfactory signal at the approved location? I can see how some people view that as contradictory.
(b) An FM translator may be used for the purpose of retransmitting the
signals of a primary FM radio broadcast station or another translator
station the signal of which is received directly through space, converted,
and suitably amplified.
I don't see anything about location of the receiver in that. Do you? It does say the signal must be received off the air. That is easy to using an FM tuner that feeds some type of STL, hard wire, or IP device.
You and I know that is not what the FCC means, but some people interpret it differently. It is fair to point out that the original use for translators was in hilly or mountainous areas where the terrain blocked the signal. Guess what? In many of those early installations, the receiving antenna was on one side of the mountain, and the transmitting antenna was on the opposite side. That is not my definition of co-located, but it seems to have flown with the FCC for many years.
Now, there is this:
However, an FM translator providing fill-in service
may use any terrestrial facilities to receive the signal that is being
rebroadcast. An FM booster station or a noncommercial educational FM
translator station that is operating on a reserved channel (Channels
201–220) and is owned and operated by the licensee of the primary
noncommercial educational station it rebroadcasts may use alternative signal
delivery means, including, but not limited to, satellite and terrestrial
microwave facilities. Provided, however, that an applicant for a
noncommercial educational translator operating on a reserved channel
(Channel 201–220) and owned and operated by the licensee of the primary
noncommercial educational FM station it rebroadcasts complies with either
paragraph (b)(1) or (b)(2) of this section:
This is where the big clue is that something might be wrong with the previous conclusions. The FCC would do themselves a favor by rewriting this so it was crystal clear. Better yet, with all the multitudes of opportunities for stray signals interfering with the input of a translator, I think the public would be better served if the Commission allowed alternate means of reception for all local translators, under the provision that, under normal conditions, it is possible to receive the originating station
off the air at the translator location. That would be very simple, and would result in more reliable reception of these stations. It would preclude using satellite networks or IP based distribution from distant stations that can’t ordinarily be received off the air at the translator location. .
The number one complaint I get about the translators I'm associated with is that they tend to go off the air, especially during the spring and early summer when tropospheric ducting is at its peak. The fact of the matter is they are designed to do that. It is to comply with FCC rules. The listening public does not understand that. They think they should be a reliable source at all times. Assuming that one of the objects of being a caretaker of the public airwaves is to be a reliable source of programming. In radio, “always there” is good. It is hard to do that when Mother Nature, somebody’s satellite radio modulator, or even a pirate that thinks it is fun to capture a translator, can make everything go very wrong.
