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My station is suffering a slight pull-back on power because of a stupid allocation in a market that cannot afford to have a station. It's not economically feasable. Yet, we here in OKC have to put up will less power. They really need to re-think some of the rules. This proposal would be a great start. If nothing else, a current licensee should be able to request a downgrade of classification for a unused allocation, maybe paying a bit of money to satify the autioneers, eh, FCC for the decreased value of "their" property (the allocation they will try to sell off). It serves the public's intrest that a station serving thousands in a market should be able to build out to at least their full class if the only thing that is stopping them is a allocation that clearly should be deleted anyway.
I take care of an A that is able to go to 6KW except for another 3KW A that is hemmed in to the point it will never be able to go to 6KW. Forget the negotiation...serve notice on the limiting station that if they can't/won't/don't file for a CP to upgrade within x number of months, they lose the protection. First come, first served. In another case, a 6KW A can do in excess of A status in desirable directions. Would this proposal drop the requirement that a workable reference location be specified where a non-da B1 would fit? If so, a LOT of A's and a number of B1's could benefit big time. It works in the non-comm band...why not in the rest of the band?
My Class A wouldn't benefit, but I'm sure there are many that would. Possibly, stations that aren't at full facilities and are precluding other stations' improvements could be given last-chance opportunities to upgrade via the FCC's "show cause" process, similar to what is done with Class C to Class C0 downgrades. I also like OKC's allocation downgrade idea. Maybe allocations that have gone through the auction process a certain number of times (2?) with no takers could be removed.
I completely understand WYAB's frustration with local service limitations caused by the whims of distant stations and unused allocations.
We've been watching, over the past few years, a similar situation. Grandfathered Class C station in Ky, lost its tower to an ice storm. Couldn't rebuild to previous height because of FAA considerations. Class A adjacent to the north petitioned FCC to downgrade station to a C-0. Eventually a deal worked out (with yet another adjacent Class A) to downgrade the C.
What this fellow is apparently proposing, though, is something similar to the rules under 73.509 ( for the non-com band) which uses contour protection rather than minimum spacing rules.
If you own or engineer a station which is not maxed out for its class, would you consider buying a bigger xmitter or a taller tower if this proposal for rulemaking is accepted? Obviously a taller tower is a MUCH more expensive option, especially out in class C land.
Thanks for the kind words on the petition. I filed it about two weeks ago with the FCC and definitely need all of your support if it is to even make it to the proposed rulemaking stage!
To Bob - as you suggested, one of the three changes requested drops the hypothetical allotment site - just like non-comms. The other two changes: (1) protect the actual facilities of other commercial stations, rather than hypothetical maximum class contours, and (2) eliminate the 73.215(e) minimum distance separations rule - also just like non-comms. Your A could go to higher power in certain directions under the proposal, and almost any other A, B1, B, C3, C2 station would benefit.
To PTBoardOp94 - I think that many operators would invest in more expensive equipment if they could serve a few extra listeners. It would be a huge boost to the equipment industry, as well as consulting business!
Thanks again for the kind sentiments. On a related note, if anyone has an inside man at the FCC that can make this happen, then I would be forever grateful!
Look at the big class C in Hopkinsville KY. 100.3 I believe. Station in Princeton Indiana was allocated and wanted to improve their signal. There may be a reference to it here already.
The station in Hopkinsville (WVVR?) at a lower height applied to build at the required height. It had a tower fall and had been in bankruptcy. What I found was that it was lower than the FCC thought. Then they applied (twice) to increase tower height. Let alone that the landowner didn't have land for guys at the supposed height, let alone the proposed height. Let alone the landowner found out about the plans to upgrade and hadn't been approached. One of those applications on paper that could never be built. Then consider the FAA. No FAA application was ever tendered. If tendered it wouldn't be approved. (Fort Campbell KY)
The money involved allowed the C to keep the Indiana station at a lower power level for 36 months of the CP they filed when the Indiana station asked for a downgrade. At the end of the 36 months thye asked for another CP to stifle competition. Again, this could never be built. The FCC downgraded them but they are still afforded protection beyond their signal. Thye are at max height (actual being able to build it) and at 100kw.
Similar case in Lafayette Indiana with 50kw WKOA. Can't upgrade, ever. It is at a lower height and the use of contour protection around it make it a Class B1 signal. So many stations have allocated nearby that it is Class B in name only.
The change to contour protection as in non com would be beneficial. Lately the engineering staff has had a change in the non com world. We used to file all apps as "contour protection" in the application. Maps are always included with applications. Last year I had an app bounced because the engineer indicated Contour protection was not used in Non com applications. I asked, "what?" I was told it is not truly contour protection but contour evaluation to determine interference. Layers of crap.
In any case the use of interference prediction is based on contour evaluation or protection. The red tape makers always go back to a socialist formula. The reason we had the overhaul of Rules not one but at least a hundred times over various issues. One rule should be applicable to any radio station equally and socialistic. If an AM station needs EAS so does an FM or Class D or LP. Based on this socialistic benchmark the Rules should apply to each station equally. Class C, Class B, Class A, commercial or non com.
As an added bonus the NAB should be behind this as it would be beneficial for all stations licensed and remove more holes for LP. Because big groups hold more Class C and B stations don't expect them to support it. See who they really support.
My comments about the socialist control by the FCC should be taken to heart. I am not a member of John Birch I am just observing fact. We talk about the socialistic role of government but this is actual proof of that. The intent was to make us equal in a democracy. Of course money talks and we know money affects the way your station is treated versus Clear Channel at the FCC. This is why Hopkinsville upheld the Indiana station move for 36 months with a CP they could never build.
There are several things the FCC should do. They are:
Establish a class C0 class of FM station which would pretty much operate with the OLD class A (3 kW/100 meter) facilities. I know of several dozen cities that could get one of these.
Allow FM stations to use theoretical allotment cooordinates. Everyone pretty much uses 73.215 anyway-why not just formalize what's already happening? If it fits on a land mass it should be allotted. I'm sick and tired of having the Commission doing things like shutting me down on allotting 100.1 to Long Island because the allotment "only fits on a 70m acre spot of land-and it is unlikely a tower could be erected there". I was planning on using 73.215 you IDIOTS!
Allow limited commercial announcments on LPFM stations. Allow LPFM stations to also use 73.215 like provisions just like full power FMs and translators do.
Allot 1710 - 1800 kHz for shared amateur radio and unlicensed Hobby use with no more then 15 watts with a 50 foot wire antenna. Hams could run much more power of course.
Allot TV channels five and six for FM broadcasting (and possibly channels 2-6, preserving 72-76 mHz and the six meter ham band). For the matter, why not include 30-50 mHz; no one's using it anyway.
Bring back terrain roughness on a voluntary basis (the country's terrain varies greatly and it FAR from the 30 meter figure the FCC uses by default). Today's computers and 3 second databases are a far cry from delta maps and slide rules.
Require that at least one FCC Commisisoner be an engineer.
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