Garziglia: Class C4 Is a Bad Idea

FCC, be wary.

That’s the caution from communications attorney John Garziglia, reacting to the idea that the commission should create a class of FM stations called Class C4. Such a proposal has been put forth by SSR Communications Inc. and its CEO Matt Wesolowski.

“The SSR petition is a bad idea in today’s world of broadcasting,” Garziglia writes to Radio World. He’s with Womble Carlyle Sandridge & Rice.

“While another new intermediate FM class might have been a good idea a decade ago prior to the FCC allowing FM translators to carry AM stations and HD2 signals, such a change now in the FM rules has the potential to displace many FM translators currently carrying AM stations and HD2 signals.”

He says many such translators likely would be knocked off the air and that the SSR proposal would probably have a similar effect on existing LPFMs.

“The only way I believe that the SSR proposal would not harm current stations as well as the listening public is if it is coupled with primary status for all translators carrying AM signals or HD2 signals,” he continued. “If primary status is given to FM translators, then the Local Community Radio Act of 2010 then may also likely require a similar primary status for LPFM stations.”

But even with primary status, he feels, the proposal would make it more difficult for additional AMs to get new FM translators (assuming a further translator window is opened), and likewise for new LPFMs to be obtained.

“There are now a good number of AM broadcasters serving the public with consistent signals from FM translators, diverse programming being provided by broadcasters through translators re-broadcasting HD2 and HD3 signals, and LPFMs giving a promise of community-based programming,” Garziglia concluded. “I would hope that the FCC would be very wary about any proposal that has the potential to cause future harm these services.”

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Class C-4 is a good idea... Let's also add Class B-2 with an identical power level and tower height as the proposed Class C-4 facility. With the C-4 and B-2 facilities, we have an intermediate 12 kw power classification that a few Class A FM stations can upgrade to nationally. The yet unresolved FM translator situation and upcoming LPFM window unfortunately makes this C-4 petition untimely.
By Richard F. Arsenault on 4/12/2013
I would respectfully ask anyone reading this to consider the total number of LPFM stations and translators that get knocked off the air due to the normal course of stations upgrading in the current regulatory environment. Even though these are secondary services, I am not aware of any LPFMs forced completely off the air, and a translator completely shutting down is extremely rare.
By Matthew Wesolowski on 1/29/2013

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