Question about FM translators

[PTBoardOp93]

I suspect that it's more of a case of the FCC not being fully aware of the problem. I can't believe that they want to force owners of AM stations that are low-powered daytimers or an AM station with a 40-year-old transmitter that needs a major equipment upgrade to stay on the air. If these owners would band together and lobby the FCC and make them aware of the problem, I find it hard to believe that the commission would not allow them to go dark with the AM and keep their translators. What's the
Downside of doing that?

The Commission is fully aware of the fact that their rules require an originating station.

The downside is that it would allow 18 networked translators to pop up in some place like Avoca, NY (south end of the finger lakes), which would further damage the few local broadcasters that exist in areas like that.

Anyone who owns FMs would have no reason to support a proposal to eliminate the originating station rule, because it would invite further competition.

Also less likely to support such a lobbying effort would be urban and suburban AMs, who were largely shut out from translators. How many AMs in Philadelphia/Trenton/Wilmington, got a good translator? Maybe a third?

 

[K.M. Richards]

It opens up a "can of worms" Let's take our friend Buddy as an example. He has 3 translators for WECK. 1 bound AM "re-vitalization" translator and 2 translators that were separately acquired. So does he get to originate 3 stations? 2 stations ? or do all 3 translators have to broadcast the same programming?

I am certain that such issues would become part of the rulemaking discussion when that time comes, and I agree with Scott Fybush that it will indeed come.

I suspect that it's more of a case of the FCC not being fully aware of the problem. I can't believe that they want to force owners of AM stations that are low-powered daytimers or an AM station with a 40-year-old transmitter that needs a major equipment upgrade to stay on the air.

Do you have any idea how relatively inexpensive it is to replace a 40-year-old tube-based transmitter with a solid-state one? The typical 1000 watt AM costs between $10,000 and $15,000 ... and as a bonus, will step down to lower powers much more cleanly than the tube-based ones.

A new Tesla costs three times that.

 

[Kelly A]

In the US, yes, the DTV conversion came with a spectrum auction that unlocked a lot of value in the 600 and 700 MHz spectrum. But it would have happened regardless. The entire world converted to either ATSC or some flavor of DVB, whether or not there was an auction involved, because technology advanced and regulations followed suit.

And I think we're simply not going to agree about how regulators work. I don't think it's the government's "responsibility" to do anything in this case.

Including changing long-standing rules to 'give' AM broadcasters full class protected status at no charge? If I still owned FM stations that cost money to purchase in the day, I'd be pissed.

I think it's in the "public interest, convenience and necessity" for regulations to follow marketplace reality, as they have for a century, pushed by broadcasters advocating for rule changes. If the public is still interested in the programming that a broadcaster provides, but not on the dead AM band on a useless facility like a 250-watt daytimer on 1550, it's not the government picking up WCGR and moving it out of the way. It's WCGR's owner seeing the truck coming and taking advantage of rules changes to invest in new FM facilities. For now, that requires carrying the deadweight of the useless AM. Why is it in the government's interest to force that expense if nobody's using that service?

Again, FM translators for AM stations were under the guise of the AM Revitalization Act. How is giving away protected full class FM stations revitalizing AM stations?

 

[Kelly A]

Do you have any idea how relatively inexpensive it is to replace a 40-year-old tube-based transmitter with a solid-state one? The typical 1000 watt AM costs between $10,000 and $15,000 ... and as a bonus, will step down to lower powers much more cleanly than the tube-based ones.

But, how many Ma and Pa AM broadcasters can afford to buy a new solid-state AM transmitter, when they don't want to spend a few hundred to purchase a replacement capacitor or filter choke to get the 40 year old one working? We dumped a ton into that FM translator already, why not just let the AM stay off the air? Nobody will notice!
That kind of B.S. thinking shouldn't be rewarded by the government bailing them out. In my mind, if you can't pay even the basic bills to stay within the agreed requirements, you need to get out and find something else.

 

[K.M. Richards]

Including changing long-standing rules to 'give' AM broadcasters full class protected status at no charge? If I still owned FM stations that cost money to purchase in the day, I'd be pissed.

Again, FM translators for AM stations were under the guise of the AM Revitalization Act. How is giving away protected full class FM stations revitalizing AM stations?

Ignoring the fact that any reorganization of translators into a full class protected service would make your question at the end irrelevant because of the reclassification, I think that there is something to be said about the investment those AM broadcasters made to put their translators on the air in the first place. Looking at it from their point of view, is it "fair" that they can be forced to change frequencies if a protected full-power FM makes changes that cause them interference, or be forced off the air if there's no open frequency to move to?

We're talking about a 250 watt service here ... closer to a LPFM than even the most restricted Class A signals at a high HAAT. The protection for those would not have to be anywhere near those for full class FMs. It would be a new class of service but we're not talking about facilities upgrades as part of that. Mainly, we're talking about letting these low-wattage FMs standalone and not require failing AM signals to be simulcasting them.

Any perceived damage to full-power FMs already happened when the translators went on the air.

 

[K.M. Richards]

But, how many Ma and Pa AM broadcasters can afford to buy a new solid-state AM transmitter, when they don't want to spend a few hundred to purchase a replacement capacitor or filter choke to get the 40 year old one working? We dumped a ton into that FM translator already, why not just let the AM stay off the air? Nobody will notice!
That kind of B.S. thinking shouldn't be rewarded by the government bailing them out. In my mind, if you can't pay even the basic bills to stay within the agreed requirements, you need to get out and find something else.

Thank you. You inadvertently made my point. If the cost of a new AM transmitter is excessive then the AM is not worth saving and the FM translator should be able to operate without it.

 

[fybush]

Including changing long-standing rules to 'give' AM broadcasters full class protected status at no charge? If I still owned FM stations that cost money to purchase in the day, I'd be pissed.

Again, FM translators for AM stations were under the guise of the AM Revitalization Act. How is giving away protected full class FM stations revitalizing AM stations?

You're here looking for things to be pissed about. I'm here trying to help small broadcasters serve their communities using spectrum niches that were otherwise unused. We are not the same.

I have no interest in what the politicians called the rulemaking that authorized FM translators for AMs. There's no "revitalizing" AM at this point. It's dying, verging on dead and no legislation or rules change is going to make any difference other than delaying the inevitable and costing someone money that they shouldn't have to spend.

A fair number of my clients operate in areas where there is no comparable FM facility out there to buy, even if they wanted to, or where all the FMs are locked up in clusters that have no reason to shed a single signal. That shouldn't be a death sentence for the small broadcasters trying to make a go with low budgets and niche audiences. I'm going to keep speaking up for their real-world situation. If it ever gets to a rulemaking, your hypothetical aggrieved FM operators are more than welcome to submit their comments and engage their lobbyists, and we'll see what happens.

 

[Kelly A]

Thank you. You inadvertently made my point. If the cost of a new AM transmitter is excessive then the AM is not worth saving and the FM translator should be able to operate without it.

So because AM broadcasters can't afford the basics to remain in business, then the government should just give them a full-class FM station? Isn't that what you're saying?

 

[Kelly A]

You're here looking for things to be pissed about. I'm here trying to help small broadcasters serve their communities using spectrum niches that were otherwise unused. We are not the same.

Sure I understand the motivation. You're looking to get and keep clients. Got that boat payment, right Scott?

I have no interest in what the politicians called the rulemaking that authorized FM translators for AMs. There's no "revitalizing" AM at this point. It's dying, verging on dead and no legislation or rules change is going to make any difference other than delaying the inevitable and costing someone money that they shouldn't have to spend.

So, do you think that FM station owners/licensees shouldn't have had to spend hundreds of thousands or millions of dollars to get into, or remain in the broadcasting business? Should they have just been given open spectrum and a full class protected license solely because they want to do something in the public interest? Of course not. Just like any business, you have to buy your way in. That includes paying someone to buy all the station assets, then a lawyer to file the transfer of control, etc.
Ignoring the realities of the marketplace and consumer habits since the 1970's shouldn't be rewarded by just giving something that others before them have paid big bucks for.

A fair number of my clients operate in areas where there is no comparable FM facility out there to buy, even if they wanted to, or where all the FMs are locked up in clusters that have no reason to shed a single signal.

I don't understand that statement. If FM's are locked up in clusters then that means other stations can be received, right?

That shouldn't be a death sentence for the small broadcasters trying to make a go with low budgets and niche audiences.

That's like saying if I own a small boutique bookstore, then I should be surprised when fewer customers come through the door anymore because they buy all their books via Amazon?

Life isn't fair. Consumer habits change. There are thousands of examples where small businesses are displaced or no longer viable because of changing consumer habits and competition from new businesses. That doesn't mean all these displaced businesses should have been bailed out by changing the federal rules.

 

[fybush]

Again with the "boat payments." It's getting boring.

And you seem to forget the guys like Jerry Lee who were, in fact, given open spectrum and a full class protected license for the asking in the 1960s and 1970s and profited to the tune of tens of millions of dollars when they sold out decades later. No, life isn't fair, and neither are regulations. Doesn't mean the little guys now shouldn't be allowed to fight for what they're fighting for. You're still trotting out grudges instead of explaining why it's in the public interest to keep dragging out the carcass of a dead medium.

 

[K.M. Richards]

So because AM broadcasters can't afford the basics to remain in business, then the government should just give them a full-class FM station? Isn't that what you're saying?

Kelly, I am going to point out where the fallacy is in your reasoning, based on things Scott, myself, and others have already said in our comments.

You seem to be equating the idea of making these admittedly low wattage FM translators equivalent to even a full Class A FM. We're not advocating that. We just believe that these small FM signals should be allowed to originate programming on their own without the need to maintain an AM signal which becomes more and more worthless every day it is forced to be on the air.

The only "protections" I have advocated are giving whatever this new class of stations ends up being called the same protections within their existing contour that they lack now. If you want to somehow convince me that I am wrong, please construct an argument as to why it is "fair" for full-power FMs to apply for changes in their licensed parameters without having to address the potential impact on translators.

 

[Kelly A]

Kelly, I am going to point out where the fallacy is in your reasoning, based on things Scott, myself, and others have already said in our comments.

You seem to be equating the idea of making these admittedly low wattage FM translators equivalent to even a full Class A FM.

Isn't that one of the proposals? And since translators are considered 'secondary service', that would mean the licenses would have to be changed to a full class to receive protections above secondary. Am I wrong?

We're not advocating that. We just believe that these small FM signals should be allowed to originate programming on their own without the need to maintain an AM signal which becomes more and more worthless every day it is forced to be on the air.

Putting on my Carnack turban: and then when regional full-class stations make even a minor change that displaces one of these translators, life isn't fair again because the translators don't have protection, especially if there are no open allocations to move the translator to. Now the broadcaster doesn't even have the AM to fall back to. Game over.

The only "protections" I have advocated are giving whatever this new class of stations ends up being called the same protections within their existing contour that they lack now.

So, you're advocating doing away with translators being classified as secondary services? So what's left?

If you want to somehow convince me that I am wrong, please construct an argument as to why it is "fair" for full-power FMs to apply for changes in their licensed parameters without having to address the potential impact on translators.

That's simple. Because they paid big dollars to play in the FM playhouse over many years. Those big dollars come with full-class protections against lesser-class stations or translators that have few, or no protections.

 

[K.M. Richards]

That's simple. Because they paid big dollars to play in the FM playhouse over many years. Those big dollars come with full-class protections against lesser-class stations or translators that have few, or no protections.

And that gives them the right, in your apparently unassailable POV, to steamroll these little radio stations out of existence if they can? I think you just became the equivalent of The Grinch on RD.

Here is what I think, in a nutshell: AM has been going downhill for some time now. The addition of rules that expanded the program origination provisions to allow AMs to be same probably kept a lot of those marginal AMs from going silent before now, and you apparently think (based on all of your statements here) that they should have done so. "Gee, too bad, mom-and-pop."

Okay, so maybe the translators didn't "revitalize AM" as was the original intent. But it did keep those small broadcasters from going under. Now you want to essentially call it a temporary reprieve, and I phrase it that way because those AMs are not any more viable now than before ... but if one of your precious steamroller FMs kills their translator, the result will be the same ... only delayed.

Maybe we should be looking at the translators as a transition from a dying transmission mode to one that can still serve a smaller area than the "FM playhouse" stations cost-effectively, and let the AMs that used to be perfect for that rest in peace.

 

[secondchoice]

So how many years have AM broadcasters seen this coming?

Some did and the bid and won FM translocators. The FCC has for decades has tried to have service in small towns. Class C AMs and sub one KW daytimers did this. Technology, lifestyle, RF noise floors (which the FCC could have done something about) have killed this service.

IMHO: The small towns and rural areas need OTA service probably more than cities due to the lack of robust internet infrastructure. An area of 20,000 that is 40 miles from a megalopolis' fm station 60db can support a small 250 FM operator, but that service goes away because someone wants to put the 18th FM signal in a market. Maybe it's not fair the megalopolis didn't get it's 3th CHR station because of a small station 50 miles away got to keep it's only service. But the life is not always fair

 

[Kelly A]

Some did and the bid and won FM translocators. The FCC has for decades has tried to have service in small towns. Class C AMs and sub one KW daytimers did this. Technology, lifestyle, RF noise floors (which the FCC could have done something about) have killed this service.

IMHO: The small towns and rural areas need OTA service probably more than cities due to the lack of robust internet infrastructure. An area of 20,000 that is 40 miles from a megalopolis' fm station 60db can support a small 250 FM operator, but that service goes away because someone wants to put the 18th FM signal in a market. Maybe it's not fair the megalopolis didn't get it's 3th CHR station because of a small station 50 miles away got to keep it's only service. But the life is not always fair

Nobody 'bid' on translators. If there was an open allocation in a community, a qualified AM station applied for it.
But this isn't 1955, and there are a lot more ways of getting information and entertainment. And as far as the Commission wanting service in small towns, I don't ever recall that being the case, other than back in the early days frequency allocations were established as 'first service' to a community that met the qualifications. Allocations were set up all over the U.S. Just as it was with allowing AM stations to apply for translators back in 2015, it was up to companies or qualified individuals to file for and build the station. The government didn't fund anything.
Granted, not all of the U.S. population has a cell/smartphone, but more do than portable radios. Even Mom and Pop stations can't provide 24/7 useful news or information to their community because it isn't financially possible, so just like the big stations, they crank up the automation with nationally syndicated programming, hopefully, maintain EAS capabilities, and sleep well knowing they're providing a unique community service. But, are they really?

 

[Kelly A]

And that gives them the right, in your apparently unassailable POV, to steamroll these little radio stations out of existence if they can? I think you just became the equivalent of The Grinch on RD.

Wow, that's taking hyperbole to a new level around here. Look, you know as well as anyone, that full-class stations aren't intentionally "steamrolling" FM translators. Rather, they're protecting and trying to grow their business because the class of license gives them the ability to do so. I would hope by now that anyone who applies for a secondary service like LPFM or translator understands that building and operating it comes at the risk of displacement. If they don't understand the rules of the game going in, then perhaps they shouldn't play.

Here is what I think, in a nutshell: AM has been going downhill for some time now. The addition of rules that expanded the program origination provisions to allow AMs to be same probably kept a lot of those marginal AMs from going silent before now, and you apparently think (based on all of your statements here) that they should have done so. "Gee, too bad, mom-and-pop."

But it's like any business K.M., the marketplace changes over time. It doesn't matter whether the business is a bookstore, buggy whip factory, or radio station. If the marketplace isn't interested in the product anymore and demand diminishes, then I agree its sad when long-standing small businesses lose that business or go under. But does the government step in and help the buggy whip factory stay in business because they provide a unique service that, in modern times, isn't that unique nor appealing anymore?

Okay, so maybe the translators didn't "revitalize AM" as was the original intent. But it did keep those small broadcasters from going under. Now you want to essentially call it a temporary reprieve, and I phrase it that way because those AMs are not any more viable now than before ... but if one of your precious steamroller FMs kills their translator, the result will be the same ... only delayed.

And that statement I agree with you. However, I don't think there is anything other than anecdotal data that would show FM translators for AM stations have extended the viability of the business model. You know as well as I do that ultimately content is still King. Just because the syndicated talk radio content or polka music Saturday is on FM too, doesn't mean there is more, or enough money coming in the door. I have yet to see that correlation, other than theoretically.

 

[secondchoice]

Kelly why do you just say you want all AMs in USA to go away you so you can be happy and make a snide remarks when a station fails like your post on 860 in Atlanta? Then I can see where you believe that FM translators are extending the life of some of these operatorions so translators are bad.

Could someone "reinvent" AM into a financially viable business. I don't know. But andl example of "hopeless business models" be changed is Western Union. The Telephone made the telegraph out dated but Western Union morphed into a money transfer business and is in just about every grocery store. Several financially successful folks I know took Clark Howards advice and still use dial up Internet to deal with their bank because they can positively know that the browser is off line and not being hacked. (I personally believe the hackers would grow old and retire before your data is copied it is soo slow). There could be smart people that will figure out how to make money with AM.

I believe 98.1 translator in Jasper GA. was auction off. It wasn't "free" or WYYZ would have took it.

 

[Cold Coffee]

There are AM's like WIZE in Springfield, Ohio who failed to file for a translator when the window was open. Now the frequency 97.5 has gone to an LPFM. Whoops. They missed the boat.

 

[K.M. Richards]

Nobody 'bid' on translators.

Okay, now you are ignoring history, Kelly, by using semantics.

Let me jog your memory: First there was a window in 2016 which AMs could acquire translators and move them up to 250 miles to bring it into the AM's market. This was the first time AMs were to be allowed to feed translators; prior to that, only FMs could, and then only if the translator was going to serve a shadowed area of their protected contour (that restriction never applied to non-commercial FMs).

When that was complete, two auctions did take place the following year for new translators for use by AMs. The first auction was only opened to Class C and D stations; the second was available to all AM stations which had not participated in any of the earlier proceedings. The translator authorizations won in those two auctions were permanently linked to the parent AMs' licenses.

During that process, FMs were excluded from even applying for new translators.

Here, read this ... while it was a news release at the time by a law firm specializing in FCC matters, it was very detailed and complete and now serves as a good telling of the history:

FCC Adopts Filing Windows for Relocation and Use of FM Translators by AM Stations

www.lermansenter.com

I am sure we will all be open to a recanting on your part after you read it.

 

[Don CT]

Don't translators just clog up they airwaves and make everything sound worse.