NAB to FCC: Address Translator Siting and Main Studio Rules
When industry comments to the FCC on matters of broadcast policy, comments from the NAB are among the most-watched. Never is this more apparent than with the AM revitalization debate.
Association of Broadcasters has offered several proposals about AM
revitalization on issues as diverse as siting cross-service FM translators and relaxing
main studio rules.
Most pressingly, the NAB said it sees
no reason for the Federal Communication Commission to set a special limit on
cross-service translators in its effort to revitalize the U.S. AM radio band.
“The ‘core market area’ for many AM stations continues to grow
and shift,” the NAB wrote in its filing. “It is critical that AM stations have
the flexibility to follow and serve these listeners.”
commission should revise the standards for locating FM cross-service
translators, saying that a new 40-mile cap being proposed may unnecessarily
hinder their use by some AMs. Existing rules require that the 60 dBµ contour of
an FM cross-service translator must be contained within the smaller of the
25-mile radius from the AM station’s transmitter site or the AM station’s
daytime 2 mV/m contour. The NAB said these criteria are too restrictive in
certain situations, such as where a station’s transmitter site is located far
from a population center because of land costs.
example, the rule can make it difficult for stations to cover a core service
area that is located beyond the 25-mile radius but within the 2 mV/m contour,
preventing stations from using an FM translator where it is needed the most,”
the association wrote. It also said the rule also does not take into account
the directionality of numerous AM stations and the possibility that a null in
the directional pattern of an AM station may exclude otherwise suitable
In a previous comment, the NAB
recommended that instead of limiting a translator’s 60 dBµ contour to the
smaller of an AM station’s 25-mile radius — with an emphasis on “smaller” — or
daytime 2 mV/m contour, the translator should be able to cover the “greater” of
these benchmarks, to increase the flexibility of AM stations in locating FM
translators. The FCC agreed to this recommendation in its Further Notice of
Proposed Rulemaking on AM revitalization, but proposed a new restriction that the translator’s
coverage contour may not extend beyond a 40-mile (64 km) radius centered at the
AM station’s transmitter site. The commission said this will provide useful
signal coverage without extending an AM radio station’s coverage beyond its
“core service area.”
the existing 2 mV/m contour cap effectively ensures this, the NAB said.
“The newly proposed 40-mile cap should be eliminated as
unnecessary because the existing 2 mV/m contour cap effectively constrains
operation to the station’s core service area,” the NAB said. The broadcast
association also questioned whether the new limit will raise similar concerns
as the previous standard, since a 40-mile maximum distance is no less arbitrary
than the 25-mile limit. “It will still disadvantage AM stations seeking to
reach listeners in a core area located 41 miles or more away from the station’s
transmitter site, but within the station’s 2 mV/m contour,” the NAB said.
NAB also pressed the FCC to consider its proposal of reducing the
daytime protected contour for Class B, C and D stations from the 0.5 to the 2
mV/m contour to allow AM stations to increase power and signal strength to
overcome increased levels of environmental noise.
modifying daytime protections for these stations is a complicated approach that
may benefit some stations, hurt others and produce unintentional consequences.
An NAB-commissioned study examined the potential changes in population and
geographic coverage of 14 AM “root” stations, as well as the impact on nearby
“affected” stations. The study found that when a root station increases signal
power, this higher power increases the population within the root station’s 2
mV/m contour and impacts the ability of nearby affected AM stations to do a
subsequent power increase.
While the study’s results cannot
be considered representative of the impact throughout the AM band, the NAB
said, “the primary conclusions to be drawn from the study are that when a
station increases its power under the proposed changes, it is likely to expand
its interference-free population … but in doing so the interference-free
population of nearby stations can be harmed.”
important step the commission can take to improve AM radio reception “is to
control and reduce the ever-increasing noise floor that degrades AM signal
quality,” the NAB said, asking the commission to more deeply review Part 15
rules and to take steps to clarify that all such devices fall under the commission’s
“The commission should undertake a two-pronged
approach of allowing AM stations to increase power to overcome environmental
noise — without harming or hindering other stations — while modernizing and
vigorously enforcing its Part 15 rules and other policies intended to constrain
undesired RF radiation,” the NAB said in its filing.
NAB supports relaxing the main studio requirements, saying this would allow
stations to redirect resources toward programming and public service. As it
stands, a station’s main studio must be located either within a station’s
principal community contour, within the contour of any other broadcast station
licensed to its community, or within 25 miles of the center of its community.
Benefits include eliminating personnel, facilities and
equipment costs, and promoting collaboration among station staff. “Today,
advances in technology have virtually eliminated the need for a local main
studio, as almost all audience contact with broadcasters is by email or
telephone,” the NAB said in its filing. As we have reported, the Multicultural
Media, Telecom and Internet Council this week called on the FCC to eliminate
the main studio rule entirely, calling it a relic.
The NAB also requested that the commission relax staffing requirements,
which currently require a broadcaster to maintain a full-time management and
full-time staff presence at their main studio.
Read the NAB’s
full comments, including a summary of the study commissioned by the
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