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Thoughts on proposed upgrade for Class A FMs

Kind of like WIAA Interlochen and WWTV-FM Cadillac in Northern Michigan in the early 1960s. There weren't that many stations until the 1970s and then Docket 80-90 stations in the 1990s. Still wondering what you could have DXed with a good 10 element FM antenna and receiver there in the early 1960s.
I wish I had been an FM DXer when I spent an annual 9 weeks NNW of Traverse City. I was about 30 feet above the lake and had unobstructed FM paths in all directions. Water on three sides and cherry trees on to the north.
 
We have tropo just about every night in the Midwest. With a good antenna and receiver, I could hear 10 watt FM's 125 miles away.
3,000 watt stations 200 miles. 50,000 watt stations 300 miles. 100,000 watt FM's to 400 miles. This was common.

Then I allotted all those frequencies and ruined my DX hobby.
 
I didn't have a really good setup near Pellston until the mid 1980s. I could get most of the Class B stations in Southern Michigan regularly. I would have liked to have had a good setup before almost all the Chicago FMs moved to the Hancock and Sears/Willis sites with lower ERP. WMBI 90.1, WYCA 92.3, WYEN 106.7, and WNUS-FM/WGCI 107.5 before they also moved, were quite regularly heard in Genesee County, Michgan. Also WJML-FM 98.9 Petoskey "The Music Station" was heard in Southeast Michigan regularly before the Vassar, MI 80-90 drop In signed on in the same direction, and now IBOC sidebands. Also WIXX 101.1 Green Bay by nulling out WRIF. Right before the Docket 80-90 96.5 and 97.3 stations in Michigan signed on, I could also get the Milwaukee stations on those frequencies, then WFMR and WLPX as I recall.
 
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I could hear Green Bay Wisconsin in Indianapolis usually in the mornings when 101.1 from Chicago faded. I frequently listened to WRIF from Detroit. I could also hear WSGS from Hazzard, KY in Indy. WSGS still came in when I moved 80 miles north west of Indianapolis.. I could get about 10 States regularly on FM from Indianapolis.

With tropo the stations didn't fade much like E skip. I could actually listen to all those FM stations.
 
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When Mexico took up the issue, they realized due to lobbying by the CIRT that AM was declining and offered ways for AMs to migrate. A somewhat better solution than translators in the US, and achieved by relaxing second adjacent spacing.
Of course, but at that time several organizations opposed the modification of the defunct Cofetel to reduce the technical regulations from 800 khz to 400 khz separation of FM stations, among them was the ARVM of CDMX because it prevented the arrival of new players in different cities.
The migration of FM to AM stations changed the rules of the game commercially in radio broadcasting in Mexico, but it also massively affected the commercial tabulator.
 
And other than some AM broadcasters who shunned FM for decades being given a new place to be, that helps radios future how?

Put it another way: If you spent millions of dollars owning and operating a group of FM stations for years, would you still feel the same about AM broadcasters shoehorning in next to your stations?
If I can keep my protection contours as an owner in your scenario and put full effort into programming my stations I shouldn't have anything to worry about. Because the truth is if my main profit margin comes from the edge of my main coverage area 50-60 dbu, I already don't have a great property. Any owner that has a group of FM stations worth their salt won't have their core service area affected. And that's what matters.

Likely if this new allowance even occurs at all, it won't even be possible in alot of circumstances. I would imagine rural radio would gain the most and since the big owners dont really invest in rural areas anyway, they shouldn't be affected.
 
That is still an A in a market that is composed of many counties. It only covers a portion of that market.
And, with that signal, my wife and I beat the 50,000 watt Clear Channel Classic Rock station in one book. But Clear Channel also controlled many of the concerts in Indy. They contacted my sales department and offered to buy a quarter million dollars worth of ads for jam band concerts. If I would play the jam bands? So, I took the money and played the music. I acted like I loved jam bands and developed a passionate audience of young Deadheads. Clear Channels' station then recovered in the ratings.

K-Love owns WKLU today. They have used it as their flagship station.

In one rating period during covid, WKLU was number one in Indianapolis. I guess Christian Rock is doing well.
 
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This proposal is for an upgrade of Class A FM's. It doesn't do anything to help the translators for AM's to improve their status.

Now let's suppose the FCC would later remove 2nd adjacent protection for full power FM's Then, stations would move into cities and it would wipe out the translators and LPFM's. So, we better leave that alone.
 
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Several years ago, I had a stroke and had to sell WKLU. It sold for close to seven million. A couple years later a CP near Cincinnati sold for eighteen million.

Those were both Class A's.

Just a few years back the Disney stations in Indianapolis and St. Louis sold for a much lower price.
 
And this shows the problem with replacing engineers at the Commission with lawyers. Not only do they not have context on the history of what is being proposed, they don't have the technical background to adequately rule on this sort of dumb proposal.
 
I noticed this as soon as I read the Petition. I think there may be more that are incorrect besides the ones in italics. If I have a chance, I'll compute them all again myself, as FCC Engineers should and will probably also. I hope there are enough Engineers to do it, and that they prevail over the Lawyers Kelly A mentioned.

I suspect that the Petitioner didn't take into account that Class Bs are protected to the 54 dBu F(50,50) contour, and Class B1s are protected to the 57 dBu F(50,50) contour. All other Classes are protected to the 60 dBu F(50,50) contour.

They need to "show their work" like students in rigorous Physics, Mathematics, and Engineering Classes, as to how they came up with the Distance Separations in the Class A10 Table, and any corrections in Comments, on each entry.

The F(50,10) is what should be used for interfering contours. The interference ratios are as follows:

0 kHz 20 dB D/U
200 kHz 6 dB D/U
400 kHz -40 dB D/U
600 kHz -40 dB D/U
10.6/10.8 MHz 91 dBu contour overlap.
 
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And this shows the problem with replacing engineers at the Commission with lawyers. Not only do they not have context on the history of what is being proposed, they don't have the technical background to adequately rule on this sort of dumb proposal.
The proposal document was written by the petitioner, not by FCC staff. When I saw some of the proposed numbers, it automatically raised the red flags hence why I recalculated all of the distance separations and released what they should have been. REC has done a ton of technical studies on the upgradability of stations (hint, just over 50% of the class As in the US can upgrade but a significant majority will only be able to do it as part of a 73.215 request as long as they can make the overlap and meet the directional antenna requirements). Predicted new interference inside the service contours of about 12% of existing LPFMs and FM translators. REC will be filing comments in this proceeding.
 
The proposal document was written by the petitioner, not by FCC staff. When I saw some of the proposed numbers, it automatically raised the red flags hence why I recalculated all of the distance separations and released what they should have been. REC has done a ton of technical studies on the upgradability of stations (hint, just over 50% of the class As in the US can upgrade but a significant majority will only be able to do it as part of a 73.215 request as long as they can make the overlap and meet the directional antenna requirements). Predicted new interference inside the service contours of about 12% of existing LPFMs and FM translators. REC will be filing comments in this proceeding.
I get it, but who ultimately runs such a proposal through the system toward approval?
 
The proposal document was written by the petitioner, not by FCC staff. When I saw some of the proposed numbers, it automatically raised the red flags hence why I recalculated all of the distance separations and released what they should have been. REC has done a ton of technical studies on the upgradability of stations (hint, just over 50% of the class As in the US can upgrade but a significant majority will only be able to do it as part of a 73.215 request as long as they can make the overlap and meet the directional antenna requirements). Predicted new interference inside the service contours of about 12% of existing LPFMs and FM translators. REC will be filing comments in this proceeding.
Michi, thanks for the update you posted. I want your opinion on my question. With the limited number of stations that will ultimately be eligible for the upgrade, as well as the costs, legal, engineering and otherwise, will it be worth the few miles of coverage each station gains? I looked at 2 stations near me, both serving a city of 85k, that could upgrade, and used your figures on a map radius tool, and the coverage only increased by a few miles. One station I know would not pay for the upgrade, and the other ownership group is iffy on investing even one more dollar in their stations, so I really don't see either one happening. Also, looking at other stations in a 50 mile radius from me, I see so many stations limited by first-adjacent and co-channel spacing, that I think there may be 1 or 2 stations this would benefit, but no more. Does REC have any idea how many stations realistically this would benefit, and knowing the FCC and their changing whims, when or if this proposal becomes a reality?
 
Would allowing stations to go directional and upgrade without regard of spacing distances as long as existing stations' 45 DB is protected work? 100.5 in Atlanta could go on the Fish Stick with a directional antenna and not effect WSSL,'s 45. In fact the power directed East and North East could be reduced compared to what is happening now.
 
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