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TRANSLATOR QUESTION

I have a question regarding translators and the FCC. Back in 2003, the FCC opened a translator filing window that resulted in the filing of thousands of apps for new translators. After the window closed, the FCC immediatley began processing the apps and issued hundreds of CPs. Then, for some reason, they stopped processing them and there are still a large number of translator apps still waiting to be processed. Does anyone know when or if the FCC will resume processing these translator apps?
 
There are a lot of them that are MX'd (mutually exclusive).
 
The Commission halted processing on the applications because of accusations of abuse and gaming of the system by a two or three groups of applicants that filed hundreds of applications during the translator window. Many of the applications were defective on their face. At least two related applicants were accused of trafficing in the translators. In other words, they used the window to apply for free spectrum and then immediately flipped the permits or built facilities for a large profit. The Commission since then has struggled to resolve these concerns and issues.

The last word out of the Commission is that after the non-reserved band NCE window is opened and then closed, and President Obama has signed the bill removing the 3rd Adjacent protection from LPFM, that the next window will be for 100 watt LPFM's, with translators following next.
 
The Policy question for translators is whether the community is better served by a locally programmed signal (either LPFM or AM on FM) or by a satellite-fed translator (satellator) repeating the programming of a NCE station 1,000+ miles away. There are arguments on either side.
 
Some of the translators are not MXed but have not been processed. Word was tat "soon" thye would be processed. also heard this in 2004, 2006.
 
The bill moving through Congress that would remove the restriction on 3rd adjacent LPFM's also allows the same for translators.

Many of these translator apps.--by we know who--were plopped down on 3rd adjacent channels, using a loop-hole that allowed this where the 100 dbu did not overlap with the contour of an existing station in an "inhabited" area.

Passage of the bill would allow the Commission to run these through.
 
With all due respect Tom, I believe current FCC rules permit translators on 3rd Adjacents as long as the required contour spacing exists. The Bill removing the 3rd Adjacent protections was advocated to rationalize the difference in treatment between LPFM and FMX.
 
Contour protection is not required on third or second adjacent channels. Third requires a waiver. Second requires proof the transmitter area is rural and that the interfering contour of the translator is at a level which will not cause problems for the full power station.

Many of these have been run through.

LPFM is trying to get Class A status and get more of them on the air. The Bill in Congress might do this.
 
Nope:

Sec. 74.1204 Protection of FM broadcast, FM Translator and LP100 stations.

(a) An application for an FM translator station will not be accepted for filing if the proposed operation would involve overlap of predicted field contours with any other authorized commercial or noncommercial educational FM broadcast stations, FM translators, and Class D (secondary) noncommercial educational FM stations; or if it would result in new or increased overlap with an LP100 station, as set forth:

(1) Commercial Class B FM Stations (Protected Contour: 0.5 mV/m)


Frequency separation Interference contour of proposed translator station Protected contour of commercial Class B station

Co-channel............................ 0.05 mV/m (34 dBu)..................................... 0.5 mV/m (54 dBu)
200 kHz............................... 0.25 mV/m (48 dBu)..................................... 0.5 mV/m (54 dBu)
400 kHz/ 600 kHz..... 50.0 mV/m (94 dBu)..................................... 0.5 mV/m (54 dBu)

For B-1 the protected contour is 57 dbu; for all other stations 60 dbu.

The exception they use to sneak these in is 74.1204 (d):

(d) The provisions of this section concerning prohibited overlap will not apply where the area of such overlap lies entirely over water. In addition, an application otherwise precluded by this section will be accepted if it can be demonstrated that no actual interference will occur due to intervening terrain, lack of population or such other
factors as may be applicable.
 
Can't dispute your notation but Commission staff routinely grant 3rd adjacent waivers, and second. Because they are clients I don't want to note specific stations but "routine" is the word.

If you do this regularly you learn there are exceptions.

Also, interference in the air is not interference. 100 watts at 400 feet has how much interference at ground level? Or 3/4 of a mile away? Topo maps to demonstrate no population help to push these through. No population? No real overlap even if it does exist. One application recently used centroids of census data to move population out of a populated area...

You did look up the Rules but waiver of these Rules are regular.
 
I know they do. One of those "abusive" multi-translator filers tried to put a translator on my second adjacent--inside my 65 dbu contour--less than a mile from the main mall in our area. A call to the primary station ended that nonsense before the application got to the second stage filing. For one thing, the primary station ran the same long-form network show as my station--and there is a prohibition in the contract about translators inside the contour of another affiliate.

This particular proposal was for a "flagpole" cell tower, next to a McDonalds, across the street from a 3 story apartment building on a busy six lane highway. 250 watts on 94.3, where my signal is on 93.9. Commission would probably have granted it since they have repealed the laws of physics by fiat.
 
TomT said:
Nope:

Sec. 74.1204 Protection of FM broadcast, FM Translator and LP100 stations.

The case most cited for this particular loophole is "Living Ways Ministry (FCC 02-244)". Simply put, if a tree falls in the forest and there is nobody to hear it does it make a sound? If there is interferance in the forest, or overwater, and there is no population to hear it, is there really interferance?? How about if the interferance contour overlap is 200' around your tower coordinates, you move your translator antenna to 210' up your tower!
 
While this subject is open, it seems the vast majority of translators are limited to low double digit watts when in the 300' HAAT range. Yet at least 1 translator is licensed for 150 watts ERP at over 100 meters HAAT. I've heard the rule two ways...one being that translators may operate with up to 250 watts ERP with no HAAT limit and the other being that it's 250 watts at a relatively low height (100' ?) with power derating into the low double digits by the time you reach 100 meters or so of HAAT. What is the actual rule & is there a loophole to bypass the restriction that results in many translators being 10, 19 27 or 33 watts?
 
Without going to dig out the exact rule, there are limitations within a certain distance of the Canadian and Mexican borders. Then there are different limitations east and west of the Mississippi. Beyond all that, there is the basic (though widely ignored, contour protection rules against existing stations.

Also, unlike FM broadcast, the limitations are figured on a minimum of 12 radials, and for each radial.
 
HAAT isnt' even on the authorization any more.
How about 250 watts ERP @ 800 Meters HAAT. EMF in Boise.

Speaking of EMF has anyone read through the "Radio Rescue Plan"?
Less regulation
More translators (with less regulation)
More LPFM (with less regulation and more protection)

etc...
 
boiseengineer said:
HAAT isnt' even on the authorization any more.
How about 250 watts ERP @ 800 Meters HAAT. EMF in Boise.
Holy (pun intended) Toledo. What freq is that one on? Gotta see the contour map on that one. Anyone else know of a translator with more coverage than that one?
 
k260ai. More coverage in the main lobe than a Class A. Must have cost them a fortune in bribes.

Apparently the only real defense against translator interference anymore is a well-sharpened machete.
 
They have to move freq. soon. A former Salmon ID station has skipped & hopped accross the state to land about 50 km east of town on 99.9. (That could start a whole 'nuther thread.)

Speaking of creeping stations, what about translators filing 5 or more "minor changes" in a few months, each a small move until they reach their goal, the market where they have a daytime AM.
 
boiseengineer said:
They have to move freq. soon. A former Salmon ID station has skipped & hopped accross the state to land about 50 km east of town on 99.9. (That could start a whole 'nuther thread.)

Speaking of creeping stations, what about translators filing 5 or more "minor changes" in a few months, each a small move until they reach their goal, the market where they have a daytime AM.
I have seen that done, quite successfully I might ad. If the FCC had given AM's the right to drop in a new translator (duh), this wouldn't have been as necessary.
 
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