AM WINDOW APPLICATIONS
I agree with Mark Lipp (“Diversity Will Not Benefit from this Process,”radioworld.com, Nov. 11) on several points, but I feel some clarification is needed.
The re-farming of the TV Channel 5 and 6 spectrum, if it ever happens here, is going to be a very long process. AM broadcasters need some kind of relief that’s much more immediate. So let’s not take 5 and 6 off the table, but in the meantime let’s get some small daps of analog FM spectrum that can become very useful on a much shorter time frame. In smaller markets (full disclosure: I’m involved in a 250-watt daytimer in a small market), this can be a lifesaver … already has been in places I know about.
Only AM licensees can take part in these windows ordered in the R&O. This means that we’re not talking about thousands of applications like we experienced in the 2003 window. A lot of stations around here already have their translator via the usual process. I think we can expect something around a thousand applications in the total window run.
Some AM stations in larger markets are sited so that a translator meeting the fill-in requirements would not cover even a quarter of the market area. Other platforms (HD sub-channels, webcasts) begin to look more attractive at that point. So I question how many applications we’ll actually see. However, some stations may use the window to grab a second translator that they might not have been able to get otherwise.
Prices will go up — probably are going up as I write this. But applicants are going to be able to select from a potential pool of many more licenses and permits due to the 250-mile waiver, and also due to the FCC’s generous offer to grant waivers on the construction time for Window 83 permits acquired in the modification window. A lot of those permits were the result of pure speculation and were about to clock out unbuilt until this came along. Those speculators are standing by to take your call, I’m sure. So it’s not clear to me that prices will just go through the roof. I know our group isn’t going to just take the first deal we get. We’re going shopping.
Mark also warns us about applications that may be objected to by full-power operators “if interference is caused.” We need to clarify what he’s talking about; 47 CFR 74.1204(f) provides that a translator application, even if it clears all the protection requirements to all other records in the database, might still cause interference to existing listeners in an area beyond the protected contour of the station in question. This rule says that station can claim that audience as protected and block any proposal that would interfere.
That is true and could be a problem for AM applicants. However, in my experience, broadcasters seldom pursue complaints of this nature, even if they actually become aware of the applications. They must prove to the commission that the audience exists with letters from actual listeners in the affected area, for one thing, and they know that they’re just trying to paint outside the lines by trying to claim legal coverage outside the defined protected contour. Interference, including from IBOC, has increasingly wiped out that “fringe” coverage we used to covet when trying to DX that favorite FM from a big market. So enough already.
Small-market AMs like us should go forth and file, and try to get the best deal possible — if not in the modification window, then in the subsequent window for new permits.
Gary O. Keener
Keener Technical Services
San Antonio, Texas
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Palm Coast, Fla.
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