24 Years Later, a Proof Pays Off

WFCR can claim an FM bidding credit
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It’s a case where good engineering record-keeping could end up helping a broadcaster obtain another license to expand regional service.

When FCC Auction 91 begins in late April, the WFCR Foundation will be able to claim a “new entrant” bidding credit of 25% when it goes for an FM allotment in Adams, Mass. This is a win for the organization, which convinced the Media Bureau to reconsider an earlier decision.

The FCC staff initially said that, based on the available ground conductivity data, the daytime principal community (5 mV/m) contour of WFCR’s sister AM station WNNZ overlaps the predicted principal community contour of the planned FM allotment.

The rules say an applicant in this situation is not entitled to a bidding credit if it has a sibling mass media facility serving the “same area.” So the commission told WFCR it was ineligible for a new entrant bidding credit.

WFCR argued there is no overlap between WNNZ’s daytime principal community contour and the predicted 70 dBµ contour of an FM in Adams, Mass. To make its case, it dug back 24 years. It presented its own study of the AM’s 5 mV/m contour, based on measured ground conductivity data from a full proof of performance done for the station in 1987.

The Media Bureau then reversed itself, saying its rules are clear: Measured conductivity data must be used when determining groundwave strength, and the “Figure M3” ground conductivity data are used only if actual measured data aren’t available.

— Paul McLane


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