How Long Is Long Enough?
     

Consider the following. 
 
You’re a single-station licensee with a modestly successful Class A commercial FM operation. You have diligently served your community, remained financially solvent (even in “this” economy) and have even managed to do well against those pesky large group operators.
 
You’re lean, nimble, somewhat limited in power, and proud of it.
 
Your little Class A station’s comparatively low power level has also been protecting, via the FCC’s curves contour methodology, one of the “big guys” and their 100,000-watt FM flamethrowers located many miles (but only one notch on the dial) away from you.
 
The problem? Current FCC rules dictate that you must protect their station as if it were operating with a 1,500-foot antenna structure, even though their tower is but 1,100 feet tall.
 
The overprotected station has operated at the 1,100-foot level for more than 25 years, with no realistic hope of ever achieving fully built status.
 
Couldn’t you build out your full FM facility in 25 years? If not, why would you continue to deserve contour overprotection?
 
Still, FCC rules require the little guy (you) to reduce power, directionalize or abandon your specific upgrade plans in order to continue overprotecting the big guys’ station and its “future potential” to upgrade, forever preserved with no expiration date.
 
Mom-and-Pop operations all over the nation are facing similar situations. A new Petition for Rulemaking (see radioworld.com/links to read it) is now sitting at the FCC, with an attempt to change this imbalance.
 
Overprotected, underbuilt
 
The plea respectfully requests that the FCC create a new power class (the FM “C4” allocation), and also asks that the commission, via “triggering” application, direct overprotected stations that have been underbuilt for at least 10 years to either construct full facilities or take a Section 73.215 designation.
 
This rule change would enable upgrade-minded stations to protect each other to their actual contours, rather than hypothetical maximum facilities, paving the way for hundreds of specific FM service improvements.
 
If approved, the new FM Class C4 stations would call for a maximum effective radiated power level of 12,000 W from a reference antenna height above average terrain of 100 meters. This new allocation would also fill in the current incompatible power gap between the various FM classes, which is 3.0 dB, except for the transition from A to C3 (6.2 dB).
 
The petition examined an extremely narrow group of 1,286 FM Class A facilities and found that more than 376 (30 percent plus) would be eligible to upgrade to the new C4 power class.
 
This analysis did not consider stations located within border zones, nor did it include states with mixed Zone I/IA/II designations (such as California, for instance).
 
Finally, the analysis tossed out stations that otherwise could have taken a C4 allocation from an alternate community of license (i.e., the new C4 allocation also had to serve the station’s current licensed community).
 
Given these overly restrictive parameters, it is asserted that many more FM Class A stations would be eligible for upgrade.
 
As with all new ideas, the opposition is already lining up to squash the proposal, claiming Draconian consequences from such a “drastic” policy shift. Nothing could be further from the truth, of course, as the nearly identical C3 and C0 proposals from two decades ago somehow managed to avoid destroying the engineering integrity of the FM spectrum as we know it.
 
Now, the fun part. If you have a candidate Class A FM station and would like to know how this proposal may affect you, I would be more than happy to evaluate your station at no cost. Contact me, Matthew Wesolowski, at matt@wyab.com, or call (601) 201-2789, and perhaps we can change the status quo together.
 
Last, I thank those who helped me prepare this petition for rulemaking, including my business partner Mike Adkins, the Minority Media and Telecommunications Council, various members of the consulting engineering community and several former FCC staffers, all of whom went beyond the call of duty.
 
Matthew Wesolowski is chief executive officer of SSR Communications Inc. An Atlanta native and Georgia Tech graduate, he and his business partner Mike Adkins have owned and operated WYAB(FM) at 103.9 MHz, in Flora, Miss., since 2003. They have prepared upgrade applications for hundreds of broadcasters through the consulting side of their business since 1999.
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