In this guest commentary, the author responds to the article “SBE Proposes Easing FCC’s FM Interference Rules” and its related story “Radio Seizes the Moment to Push for FCC Reforms.” Comment on this or any article. Email [email protected].
There are now more than 11,000 radio stations — a mature service under increasing pressure from internet and satellite delivered services. Market populations have shifted and many FM station locations originally dictated by 1960s rules and receiver technology can not adequately serve their markets.
The “Delete, Delete, Delete” proceeding provides an excellent opportunity to remove or modify many rules that impede the improvement and preservation of AM and FM services. A number of proposals filed in that proceeding are particularly worthy of implementation.
I’ll list out some courses of possible deregulatory action below.
FM
- Permit class upgrades for existing FMs based on contour protection without requiring a fully-spaced reference point if it results in a 25% increase in 60 dBu population or area served.
- Eliminate IF protections not needed for modern receivers. Canada does not require IF spacing.
- Reduce FM third-adjacent protection to the 70 dBu contour. Some proposed elimination. The 70 dBu contour is a reasonable compromise.
- Eliminate FM translator third-adjacent protection.
- Permit Raleigh Waivers, now permitted in the reserved band, for non-reserved band stations. Very small, theoretical areas of “new received interference” from second- and third-adjacent channel stations within an expanded service contour are more than offset by the increase in new population served, and in reality will likely not occur.
- Delete §73.215(e). This section is a major impediment to the use of existing tower sites. In one instance an FM operator was not granted a 400-foot waiver in order to use the station’s existing tower for an upgrade even though no contour overlap would have occurred.
- Permit deletion of any station’s allotment, as is the case in the reserved band, when the license is surrendered.
- Change Zone I pre-64 short-spaced stations’ adjacent channel protection to 60 dBu as it was originally designed. Many Class As are jammed in with no room for improvement.
AM
- Change the Class B, C and D AM day-protected contour to 1 mV/m, adjacent channel overlap to 1 mV/m, second-adjacent to 25 mV/m and eliminate third-adjacent protection. This is consistent with the commission’s own AM Revitalization proposal.
- Open another 250-mile translator window to permit AMs to obtain their first or second translator.
Also, delete the Rural Radio policy. §307(b) speaks to “demand” and does not differentiate between rural and urban.
Anderson’s complete comments can be found here.
