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SHOULD TRANSLATORS BE ALLOWED TO ORIGINATE LOCAL PROGRAMMING

A petition has been filed with the FCC to permit translators to originate programming.

Translators were designed to filll in 'holes' where a radio signal would not reach because the terrain blocked the signal. Around 1980 the FCC was asked to change those rules. It seemed like a good idea. For example, Christian ministries could put up a translator in a spot with no local Christian radio service or the state university could put up a translator here or there to reach more of their state. The result was a mess...thousands and thousands of translators rebroadcasting distant non-local signals.

I believe translators should be allowed to originate programming. At least it should be encouraged. Why waste spectrum with programming that is on the air because the area might have a big financial contributor living there?

We have already seen relief for some AM daytime only stations, now allowed to operate translators. They certainly originate programming. (I think the first was the AM station in the Nashville area that was being beat up at night by a Cuban station that received a translator that could operate from sunset to sunrise...something that happened years ago).

If traslators could opt for local programming who would win? The answer is varied: Translator owners could see a cash windfall selling underperforming stations. Local communities without local radio could have a local station. There would undoubtedly be many who would change from one flavor of satellite Christian programming to another, but some would really get local radio for their towns, albeit an upgraded version of LPFM. The FCC's mandate would be furthered. (Have you ever noticed how many rural areas have numerous distant non-local, especially Christian and NPR translators but no local radio service because it is not economically viable? Would this change if translators could do local programming?)

So much must be determined. Can a translator on a commercial FM frequency operated by a non-profit be allowed to become commercial? If no, why? If yes, why? What are the benefits of either choice.

Next, the question is whether the translators, if allowed to convert to local programming could be commercial stations. Why not? Why should they remain non-commercial? Where does your thinking stand in regard to for profit AM stations having commercial translators? If they can be commercial, then why not locally programmed translators?

Next, can a non-commercial, non-profit owned translator on a frequency between 92 and 108 FM sell to an AM station and that AM station be permitted to operate as a commercial radio service on this translator? Maybe a lawyer or industry watchdog will know if this has happened already. Must that non-commercial translator remain non-commercial and non-profit? If so why? If not, why not? Have you considered cases where non-profit non-commercial FM station in the commercial band sold to commercial broadcasters who converted the frequency to a for profit, commercial status? It has been done. As this is the case, why not with transators?

If translators can convert to local programming and are still restricted to 30 seconds an hour to acknowledge contributors, should we not have these specifics modified to benefit each sort of community? Let me explain. If a station operates 24/7/365, it can by current rules, take 30 seconds an hour for funding. This is 12 minutes a day or 4,380 minutes a year. Why not rewrite the rules by making the sentence say "an annual total not to exceed 30 seconds for each broadcast hour". In other words, you can run a maximum of 4,380 minutes a year if you're on the air 24/7/365. If you are a seasonal town that's dead between Labor Day and Memorial Day, you could run those announcements mostly during those months the town derives almost all of its income. Supporters want a benefit. Do not kid yourself. A bank that paid for a town's cheerleaders to go to Florida to compete in a national competition wrote the check because of the financial gains it would receive by the goodwill gesture...they saw a benefit! As a result, the kindly dentist that supports the local translator wants to be acknowledged when his office is open, not at 3 in the morning or Sunday afternoon. He wants the added benefit in addition to his charity, if he can get it.

My personal opinion is we spend too much time trying to break the legs of some radio services before it begins. The arguments are always about change not economic realities facing stations. Sometimes these aguments win and service is blown out the door as the operator spends all their time trying to find creative legal ways to raise funding versus worrying about how they can serve the community better. In almost every case, service suffers as those grand plans remain financially impossible. I remember when a Hershey bar was a dime...guess what, times have changed. Get used to it. Many times people think if you do something very well you should not ever be allowed to be compesated for your good job. Maybe you should take half pay for your hard work at your 9 to 5 job. Should a station be destined to utter poverty for providing a quality service? Not everybody is greedy. If I work hard to serve my community should I be relegated to living in a travel trailer and eating Ramen noodles the rest of my life or might I have a home as nice as yours and be able to take the wife out for a steak dinner here or there, or afford health insurance or a reliable car? Why am I evil for just wanting an a-typical lifestyle if I am heading a non-profit radio station? Would you pay that price? If you wouldn't, why force it on those in the business with an inner desire to serve their communities via radio?

Some will argue a non-commercial translator in the commercial band should stay non-commercial even if it is allowed to originate programming. Some will say the 30 seconds an hour rule should remain. I can understand the point but I ask you what is the motivation to create costs when compensation could be the same by not originating local programming? If you can 'sell' 30 seconds an hour hooked up to satellite, why bother doing anything else? How could you pay for the play by play guys doing high school sports or cover the cost of remote equipment to air school board and city council meetings or cover community events if you cannot increase your funding? Why would you even try when your revenue potential (quantity) remains the same? Would it not be more logical to spend all your time trying to find funding after you get off from your 9 to 5 job. And anyway, if you have to work fulltime to afford to have a translator, why bother? Why put yourself through that? But, if you might be able to make an average living, fulfill your inner needs and provide a service to the community and not spend every minute trying to manipulate incredibly restrictive rules to find a way to fund it all, what could a locally programmed translator become to a community? Could it become a place for local news, emergency information, slices of life in the community and a force for economic vitality for an area where the Mom and Pop business is threatened? I think it could, but please don't break my legs and tell me to walk and expect me to run a marathon. What would be so bad about a commercial if the community got a local radio service? Is the commercial so evil and distasteful that you'd rather sacrifice local radio service by tossing it out with the baby and the bath water? If you think so, I challege you to answer if you were ever in radio and specifically if you ever had to make a budget at any of those radio stations and meet it. If you have and had to be face to face with the business community, I accept your opinion as legitimate, otherwise I must assume your opinion comes without such experience. I can say a few communities are cohesive enough to make a non-profit, non-commercial station work, but in most places that is not the case unless the entity has decades of service and contributions behind them. For the most part a community must be taught to function this way and the learning curve is typically much longer than the financial resources extend.

I think now is the time for action on this. Poor economic times mean many non-profits will want to trim poorly producing holdings. I think it should be easy for the FCC to justify since it jives with their mandate and this comes on the heels of allowing AM translators. I even think the idea of a non-profit non-comm translator in the commercial band being allowed to become commercial is a no-brainer as the FCC has allowed the sale of full power non-commercial FMs in the commercial band to transfer to for profit companies and become commercial frequencies.

I close my book now and await your responses, looking to learn and be enlightened.
 
bturner said:
Translators were designed to filll in 'holes' where a radio signal would not reach because the terrain blocked the signal. Around 1980 the FCC was asked to change those rules. It seemed like a good idea. For example, Christian ministries could put up a translator in a spot with no local Christian radio service or the state university could put up a translator here or there to reach more of their state. The result was a mess...thousands and thousands of translators rebroadcasting distant non-local signals.

Some early translators served two additional (related) purposes: to extend FM service into places too small to support their own FM station and too far from the nearest large city to receive its stations; and to extend unusual FM formats into places that might have FM service but can't support a station in the unusual format. There used to be one just outside my Wisconsin hometown, relaying a religious station from Milwaukee about 70 miles away.

In both cases, the translator had to receive the primary station off-air. (fill-in translators can, at least today, use any desired means to receive the primary. I'm not entirely certain that was permitted at the time.)

What opened the floodgates was when the FCC agreed to allow non-commercial non-fill-in translators -- those that extend the coverage of the primary station beyond what its main transmitter allows -- to receive the primary station via means other than off-air. This made it possible to build national translator networks using satellite delivery.

I believe translators should be allowed to originate programming. At least it should be encouraged. Why waste spectrum with programming that is on the air because the area might have a big financial contributor living there?

Satellite-fed translators must belong to the same firm that owns the primary station. IMHO the one biggest step that could be taken to reform the FM translator service would be to reverse this requirement. Require that satellite-fed translators NOT be commonly-controlled with the primary station. That way, the translator would be far less likely to exist unless the locals wanted the primary station's programming badly enough to pay for the translator.

We have already seen relief for some AM daytime only stations, now allowed to operate translators. They certainly originate programming. (I think the first was the AM station in the Nashville area that was being beat up at night by a Cuban station that received a translator that could operate from sunset to sunrise...something that happened years ago).

Legally, the Nashville station isn't a translator -- it's authorized under Special Temporary Authority (which has been renewed dozens of times). And it's not originating anything, it's a 100% relay of AM 1160. (which is not a daytimer, although its night facilities are a LOT more limited than their 50kw non-directional day signal)

(Have you ever noticed how many rural areas have numerous distant non-local, especially Christian and NPR translators but no local radio service because it is not economically viable? Would this change if translators could do local programming?)

I have my doubts it would change. Of course, a translator is cheaper in terms of the cost of the transmitter and the electricity to run it; it's also cheaper in terms of the cost of acquiring the license. (although I think a lot of that difference would dry up if translators were allowed to originate their own commercial programming. The revenue possibilities would improve, and the prices would be bid up.)

But I think the larger part of the cost of a locally-programmed station is labor. Small-market local talent is going to cost pretty much the same whether they're speaking on a 50-watt station or a 6,000-watt outlet.

So much must be determined. Can a translator on a commercial FM frequency operated by a non-profit be allowed to become commercial?
...
Next, the question is whether the translators, if allowed to convert to local programming could be commercial stations. Why not? Why should they remain non-commercial? Where does your thinking stand in regard to for profit AM stations having commercial translators? If they can be commercial, then why not locally programmed translators?

If you don't allow commercial operation of locally-programmed translators, then you have a service that's very difficult to distinguish from the existing LPFM service. About the only difference is that translators can qualify for 2-1/2 times the power. (and a MUCH higher antenna)

FWIW, the FCC doesn't really recognize the concept of a "non-profit". Non-profit organizations (usually but not always religious in nature) can and do own commercial stations. I don't know of any for-profit organizations that own non-commercial stations, but I can see where a for-profit school (like ITT Tech) might start a station to assist their students in learning the ropes of radio. I'm an engineer, not a lawyer, but to my knowledge if the station was operated in a non-commercial manner and supported an educational mission, it would be legal.

Next, can a non-commercial, non-profit owned translator on a frequency between 92 and 108 FM sell to an AM station and that AM station be permitted to operate as a commercial radio service on this translator? Maybe a lawyer or industry watchdog will know if this has happened already.

It has happened, and quite frequently. All translators above 92MHz are authorized for commercial operation. Some of them choose to operate non-commercially (by relaying a non-commercial station) but they may sell to a commercial station -- either AM or FM.

_________________________________________________

What you propose is, fundamentally, commercial LPFM. The FCC has considered that, decided not to -- and then essentially changed their minds by allowing translators to relay daytime-only AM stations.

I'm pretty leery of the idea. If it would result in more local programming, I'd be for it. As written, I see the commercial program-originating translator ending up an outlet for satellite-fed national talk shows/automated music formats. And in the process, precluding non-commercial LPFMs (more likely to offer interesting programming) and clobbering not-quite-protected-contour-but-still-perfectly-listenable signals.

But I don't think the idea is wholly without merit.
 
Right now, the only real difference between commercial translators and non-commercial translators is the commercial versions pay an annual "Spectrum Usage Fee" to the FCC. Noncommercial translators don't pay a dime. Why not just carry that logic to the issue of Local Origination? Pay the fee, and you can run commercials.

I think there is more to be gained by allowing local origination, than there is to be lost. Even if the translator is generally a "satillator," allowing local usage, even if it is just an hour or two a day, would benefit most communities.

Ignoring the giants of the translator industry for a moment, most translators are owned by small (usually local) groups, individuals, and concerned citizens. They put these things on the air because they thought there was some kind of programming that was missing in their community. The idea of making a lot of money out of them was not on their radar screen, and probably still isn't. On the other hand, they would like to do this without going broke. Allowing local origination would go a long way toward helping with that.

In any case, changing the rules would allow these translators to super-serve their communities, if they so desired. It might just be something like the obvious choices of local school sports, local church broadcasts, even City Council meetings. In an age where the FCC claims they want to bring localism back to radio, this seems like a fairly painless way to do it.

As for the concept that it would really be a "Commercial LPFM," it certainly would. But that has been with us for a while, ever since FCC allowed AM stations to broadcast on translators, even after their normal broadcast day is over. They also allow supplemental HD channels to use translators. I don't see that anyone has suffered because of it. All-in-all, it seems to have worked out fairly well. The biggest problem is a lack of available translators.

While I’m in favor of allowing translators to originate local programming, I’ll bet that the biggest road-block to this idea will come from NAB and NPR, just as they did for LPFM.
 
Translators can basically originate local programming since they are allowed to simulcast HD2s. A third party owner can simulcast any station in the country on their translator. What's to stop someone from leasing an HD2 on a station in the middle of nowhere and leasing a translator in their market to translate the HD2. That's just wrong. I think translators should also be allowed to translate Internet radio.
 
Not a good idea.

1. Most markets already have too many radio stations for available advertising dollars. A 250 watt stand-alone FM station is just not practical. (Also note that in the east that's 250 watts are 100 feet or less AHAAT. To get reasonable antenna heights the power usually works out to be 100 watts or less...about a 3 to 5 mile coverage area for the 60 dbu (not 70 dbu city grade)

2. Present rules prohibit "satellators" in the commercial band (92.1 to 107.9)--i.e. translators relaying distant stations fed by satellite. Allowing "local" programming on a translator and you will have a number of translators consisting of a satellite receiver feeding a mixer than feeding the translator--with local ID inserted. Note that while LPFM's are supposed to be mostly locally programmed there are a lot of them just relaying satellite programming.

3. In terms of actually increasing "voices" in the community the most efficient use of translators is to relay AM stations. AM stations increasingly suffer from electronic smog generated by light dimmers, DSL, various microprocessor -controlled devices as well as poorly maintained electric grids. Adding a translator also provides incentives for daytimers and Class IV's to provide better nighttime programming.
 
This is a topic that needs to be discussed... and discussed a lot. The needs of listener in metro areas is much different than the needs of listeners in distant, rural American. And that is the "devil in the details" There is no strong lobby for the listeners in sparsely settled America and no strong lobby for the community leaders in sparsely settled America.

But here comes the fly in the ointment. I live in a county that 20 or 30 years ago was classic, rural Appalachian "sparsely settled" America. Many of our residents wake up every morning and still live in the bygone era... socially, religiously and economically. But today, because we are under the umbrella of Atlanta, many of our residents wake up every morning in their million-dollar-McMansion, strap their Lexus or BMW on their backside, and motor on down the "Alpharetta Autobahn" into the maze of high-rise locations for lawyers, doctors, executives, engineers and scientists.

If we could develop frequency allocation systems that serve metro areas and another allocation system for sparsely populated areas, which set would apply to a county like mine.
 
That's my point. How is it five satellite fed ministry broadcasters with translators in a sparsely populated area serve the community better? I'm not against Christian radio but I've come across MANY communities where the only offering on the AM and FM dial is one of a handfull of national ministries with a satellite delivered translator.

The metro areas are only a tiny amount of the land mass of the United States of America.

Another consideration: how about communities with not enough economic activity to provide the debt service on a Class A FM? A 250 watt FM serves the school district and trade area and the start up costs and monthly operating costs are low enough for a mom and pop to make an adequate living. At this point, the rules basically say these towns are out of luck.

We already have AM translators. That is legal. They originate programming. I say this because when they're on at night (aka daytimer) the translator is not simulcasting. What about all the others?

Coverage is not an issue. When you're in New England, or in a major market and near one, you won't get far thanks to a crowded dial. The LPFM in Paisley, Oregon gets 30 miles. I know. I visited. Like their liner indicated, they were the best on the air because all the rest were sssshhhhhhhh. KPAI is all a radio in that area will receive and the same goes on the AM dial.
 
Figure on at least 5K a month to operate even a minimal operation.

Consider:

1. ASCAP/BMI/SESAC
2. Insurance
3. Regulatory fees (translator are abt $650 a year now--if you create a new class that can originate programming this is bound to go up.)
4. Utilities-electric/phone/rent/ etc.
5. Unless someone wants to do it as a hobby--some profit to pay living costs!
 
Those figures seem a little high. ASCAP/BMI/SESAC is based on revenue although those minimums are a bit hefty. Electric would not be too bad. Likely the bigger expense would be tower lease and office space, if you did not already have such in place. I would think except for salary, a station could operate for under 1k per month plus any rent. A full power would be much more obviously.
 
There are many constants regardless of power. The electric bill might be less, but tower rent is still tower rent. They usually charge less for less windloading or height, but most tower rent isn't exactly cheap. The Acrap guys certainly don't care as much about power as how many listen for their tax. Then of course there's the debt for buying something in the first place. In many cases that's the biggest cost. The real problem with radio today is all the leaches that suck all the money up. By the time it's all overwith, there's not nearly as much left as their used to be to pay the help to do real radio. It's not impossible, but it's certainly harder. Radio used to print money. These days it's not quite that way...
 
ASCAP/BMI/SESAC is revenue based, not by number of listeners.

Certainly you have priced transmitters. A transmitter capable of 6kw ERP is several times the cost of a transmitter capable of 250 watts ERP.

Why lease tower space?

Equipment is cheaper these days than at any other time in radio. No cart machines, turntables, walls of carts and all the other goodies that based on today's costs would be several times as expensive as they were in the day.

My point is the investment for a 250 watt versus a full class A can be about like comparing a low end motorcycle to a Hummer as far as price goes. The debt service is a fraction and monthly fixed expenses aside from payroll is less.

As for me, I'd rather not have a huge chunk of my work going to my bank/investor(s).

An LPFM can easily be done in the $25,000 range and sound just as good as a Class A. A class A could easily run you 10 times that when you consider frequencies are doled out to the highest bidder.
 
I wonder how much it costs to share the master FM antennæ on the Empire State Bldg?
A 600w class B2 from it might cover more people than any station in any other domestic radio market, including those grandfathered super power FM's in LA...maybe?
 
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