You have probably read in Radio World that the Federal Communications Commission recently released a Notice Of Inquiry (MB 18-184) that addresses the MMTC and SSR Communications’ proposed new rural C4 12 kW station class, as well as the decades-long problem of big operators warehousing spectrum by not serving as large of an area as their licenses allow, even though smaller stations looking for an upgrade must pretend as if the big guys have larger signals than they really do for application purposes. In essence, the smallest broadcasters that want to upgrade now can’t, all to protect the biggest broadcasters who have taken advantage of this senseless FCC policy for, in some cases, over 50 years.
I have taken a keen personal interest in this proposal and have supported the plan since its beginning, more than five years ago now. I have even been to the FCC to make my case in person, so when I first heard in February that the commission was finally going to formalize the C4 idea with a Notice of Proposed Rule Making, I, along with many other small broadcasters, was overjoyed. It seemed as if all of our hard work since 2013 was finally going to pay some dividends. Small broadcasters all over the country would be able to upgrade by the end of this year, I had assumed.
Now, however, the scaled-back Notice of Inquiry just adds more years to a process that has already consumed a significant portion of my life (and bank account).
I cannot wait any longer for the FCC to take action. In today’s broadcast environment, my station’s very survival depends on reaching outlying populations, as well as solidifying coverage that I’m supposed to be getting within my 60 dBu contour.
A 3 decibel increase in coverage doesn’t sound like a whole lot if you’ve already got 100,000 Watts, but for the rest of us with Class A stations, we need every possible advantage that we can get just to keep the lights on. That is why I am asking the FCC to consider an immediate waiver-based FM Class C4 option for stations most in need.
The FCC’s Notice of Inquiry asks lots of questions and poses some alleged potential problems with the C4 idea. There is not one issue that the waiver-based approach fails to solve, nor one question raised in the notice that it does not answer.
For instance, the commission asks if there is a demand for a new station class. I think that we’ve seen in the dozens of positive comments already submitted in the MB 18-184 proceeding that there is, but going the extra steps of applying for a waiver proves the demand, as well as the urgency of it. That is certainly not all.
The notice asks if full power stations will be impacted somehow — the answer there is a resounding “no;”’ only stations that have been underbuilt for 30 years or more will be subject to 73.215 contour protection, which drastically exceeds the 10 years sought in the original C4 proposal. The issue of low-power FM and FM translator effects is also addressed, and again, a waiver-based option would guarantee no contour overlap with these vital services, though stopping short of giving them primary status. No FM station involved with a television Auction 1000 repack relocation tower would be involved, either.
Finally, the notice asks if minorities, women, and small broadcasters will benefit. I can say unequivocally that they will, and I am hardly alone in this opinion. Class A FM stations are the entry point for the little guy in almost every market in this business. How could we not benefit?
WRTM(FM) 100.5 is now on file with a waiver-based FM Class C4 application. I hope that the FCC will see it as a model and “proof of concept” that the C4 idea is not just worth considering, but implementing.
The commission needs to realize that there are no engineering-based obstacles to granting a C4 permit — it is all policy-based (and some really outdated policies at that). Small Class A stations cannot wait for this process to play out for another two to three years. We need relief right now.
The author is owner/general manager of WRTM(FM) and president of Commander Communications Corp. in Jackson, Miss.