Several large-market and
large-signal broadcast owners oppose a proposal by station owner Matt
Wesolowski of SSR Communications that he says would make it easier for
short-spaced commercial FMs to upgrade their facilities.
NAB is opposing the idea as
In the petition, SSR seeks to eliminate
the need to specify theoretical fully-spaced allotment/assignment coordinates
for non-reserved FM minor modification applications; modify Section 73.215 of
the FCC rules to allow contour protection only to existing facilities, not
maximum class facilities, for all non-reserved FM band stations (not just those
authorized under 73.215); and eliminate the minimum spacing distances in
on RM-11643 were due Oct. 28.
Filing together, Beasley Broadcast Group, Bryan Broadcasting Corp.,
Clear Channel Communications, Delmarva Broadcasting Co., Merlin Media and
Radioactive oppose the changes, calling them detrimental to
the non-reserved FM band and the public interest.
proposals “will only serve to allow increased contours by existing stations,
particularly into metropolitan markets, while foreclosing opportunities for new
stations at unserved communities, low-power FMs and innovative uses of existing
spectrum,” the six radio groups wrote.
say a contour protection system is inefficient. “While more individual stations
serving a small area can be ‘squeezed in’ using contour protection as the
spacing scheme, the total area which receives productive service will be less
than under a system where stations are protected according to their class of
service, as with the current minimum distance spacing system,” they stated.
NAB said the FCC’s rules for minimum
distance separation for non-reserved FM radio “created a practical and flexible
licensing system.” Replacing these rules with contour protection standards
similar to those used for noncommercial services in the reserved FM band would
increase congestion in the band and prevent upgrades, power increases,
transmitter relocations and other station improvements, according to NAB.
More importantly, the proposed changes
could impede the development of HD Radio, NAB continued. It says
digital broadcasting must be allowed to develop in an environment that is as
free of interference as possible.
“Many broadcasters are still considering
the most economical way to deploy digital or expand radio services,” including
raising their digital power level. Any concerns over increased interference
from newly allocated or modified FMs using the proposed contour protection
methods “could significantly compromise those plans,” states NAB.
IBiquity Digital said SSR has not shown that the
proposed rule changes are compatible with digital broadcasting and until that
can be done, it opposes the petition.
Radio World has reported on
some filings that support the concept. More have since been filed.
Mississippi Association of Broadcasters supports the proposal, writing that the
system has worked well in the reserved portion of the FM band and would provide
commercial FMs “with much-needed flexibility to improve service to wider areas,
without causing interference to adjacent or co-channel stations.”
calls the FM band “mature” and says stations “have had ample time to reach full
So does KD Radio, licensee of KDSK(FM), Grants,
N.M., a Class C2 that has been trying for years to upgrade to a Class C1.
Haynes of Commander Communications in Jackson, Miss. called the rule change
my area there are stations that have been protected by the current rules that
have no intentions of taking advantage of the contours that other broadcasters
must protect. In one such case a station’s tower was destroyed and the
broadcaster rebuilt the new tower at the same height as the old one, yet other
broadcasters still protect this station’s maximum predicted contour,” wrote
taking sides, the Association of Federal Communications Consulting Engineers
suggests the FCC propose rule changes to address the issue and also consider