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This Process Has No Purpose

What do low-power FM radio, FM translators, FM boosters, noncommercial educational FM radio, AM radio and television all have in common?

When filing an application for a proposed station, a licensee in each of these services need only demonstrate that its transmitter and antenna location(s) do not interfere with the signal contours of neighboring stations. This policy is easy to understand and makes perfect sense.

This is not so in the commercial FM world. Licensees of commercial FM facilities alone must also provide a second, hypothetical FM allotment site to the FCC before a minor modification application may be granted. This second, hypothetical allotment site often is located quite far from the intended antenna location, and is afforded no protection in the FCC’s FM database against competing applications.

Using the FCC’s own standard contour prediction methodology, a licensee may file a proposal that does not interfere with any other station, yet if a fully spaced allotment site is not specified, the application will be dismissed. A fully spaced allotment site may not technically exist, even though the proposal provides no predicted interference. No matter; the licensee has almost certainly thrown away $940 in FCC application fees. The FCC must eliminate the continued requirement of a hypothetical allotment site. There are thousands of lower-class commercial FM radio stations that could upgrade to a higher power level were it not for this senseless rule, which is only applicable to the commercial FM service.

SSR Communications Inc. recently filed a petition for rulemaking with the FCC to end this purposeless process. Several similar proposals have been ignored by the commission in the past. Today, however, broadcasters need every possible advantage to compete and stay relevant in the modern arena of content delivery. The time is right for the FCC to move on this proposal.

Matthew Wesolowski
SSR Communications Inc.
WYAB(FM) Jackson, Miss.