17 Questions for the FCC About AM Class A Protections
far should the FCC go to protect “AM anchor stations” in the United States while
trying to help the band’s other operators?
want the FCC to change nighttime skywave protections for big Class A stations,
of which it owns 17 across the country. Most of these stations
operate on clear channels with 50 kW power non-directional full-time.
A change in nighttime skywave rules could let smaller stations boost power, a
change that might benefit them but eat into the effectiveness of big “boomers”
that have long enjoyed great geographic reach far beyond their cities of
Whether the commission is close to adopting
such a change is unclear; iHeart’s ongoing press at the FCC could be read to mean that
it thinks such action is pending, or maybe the company is simply making a preemptive strike against a remote possibility that was mentioned in passing in the NPRM. But its efforts
provide another window into ongoing debate in the halls of power about how to “revitalize”
According to an FCC filing, Sara Morris,
senior director of government affairs for iHeartCommunications, recently spoke
with Maria Kirby, legal advisor to Chairman Tom Wheeler, about the FCC’s
consideration of possible changes to nighttime skywave protections. Continuing
the company’s lobbying on this topic, she reiterated iHeart’s “serious concerns
about the harm to actual listeners,” including people in rural and remote
areas, that may result if the commission reduces Class A skywave protection to
Class B status.
She reminded Wheeler’s aide of an iHeart
analysis that identified more than a half-million existing listeners of
Class A stations, “accounting for 13 million listening hours per month,” who
would lose existing service. “Moreover, the AM stations that would be most
impacted by an abrupt dimunition of interference protection are the very
stations that have served to attract and retain listeners on the AM band,
similar to the way an anchor commercial tenant in a retail development serves
the critical role of attracting and retaining customers, thus promoting overall
Morris repeated iHeart’s theme that the commission
should “do no harm” and argued that a change in nighttime skywave protections “runs
directly counter to this goal.” This echoed arguments that the company has
brought to bear in previous conversations at the FCC and elsewhere.
In a letter summarizing the Sept. 29 conversation, iHeart also
listed questions it wants the commission to try to answer. The following bullet
points, comprising a total of 17 questions, are quoted directly from the
-To what extent do listeners go to the AM band
to receive content from Class A AM stations? Would a reduction in Class A
nighttime interference protections result in existing listeners of the AM band
leaving the service due to increased interference, thereby further weakening
the AM band and the ability of all AM stations to attract listeners? To what
extent to Class A AM listeners also listen to non-Class A AM stations once they
are tuned in to the AM dial? Will dimunition of AM “anchor stations” have an
overall chilling effect on the AM band?
-To what extent
does increased interference for Class A AM stations impact EAS Primary Entry
Point stations for Department of Homeland Security/FEMA alerts during
-What would be the effect on non-Class A AM
stations that do not increase power on their ability to reach existing
listeners, including their ability to provide local programming, public service
information and EAS notifications? Are listeners in rural, remote and/or tribal
areas disproportionately impacted?
-What are the
potential number of actual listeners who would lose access to an AM station
signal if changes to nighttime interference protections were adopted?
-Would listeners in rural or remove and/or tribal areas lose
access to nighttime news, information and sports that they currently receive?
-Would Class A nighttime interference protection changes
undermine the ability of these AM stations to continue to broadcast radio
programming content serving the public interest, such as news?
-What would be the impact of nighttime interference protection
reductions on Class A AM stations that qualify as small businesses?
-Would the rationale for modifying skywave protections remain
valid if the commission provides new opportunities for AM stations to increase
listenership through increased access to FM translators?
-Would power increases in nighttime coverage for Class B & D AM
stations increase noise in the band overall? To what extent would such an
increase in overall noise/interference negate any benefit from such power
increases? To what extent would Class B & D AM stations that do not
increase power be impacted by increased interference from those stations that
do increase power on the same channel? Would any of these impacted stations be
Small Business Entities? Would this increased interference impact the ability
of stations to perform EAS functions?
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