The National Association of Broadcasters won’t make a recommendation yet about whether the FCC should create a new Class A10 for the FM band.
A new class could help some stations and listeners, NAB said, but may raise other problems.
The association filed comments with the FCC about the proposal by Carl Haynes of Commander Communication Corp. that we told you about earlier. Haynes believes a simpler version of the previously proposed Class C4 stands a better chance of winning FCC approval.
“NAB generally supports policy proposals intended to improve radio service and appreciates that allowing Class A stations to increase power up to 10 kW may benefit some listeners,” the organization told the commission.
“NAB is unable to weigh in comprehensively at this point, however, given that the petition lacks critical information to allow broadcasters to properly assess the potential benefits and harms of this new class of service.”
It did reiterate several concerns it raised previously about the Class C4 idea. It said the A10 petition appears to improve upon C4 in some ways but may make it more problematic in others.
“For instance, the A10 petition fortunately does not include the untenable proposal in the C4 petition that would have involuntarily locked a station into its current operating parameters instead of the maximum parameters for its station class,” NAB wrote.
“On the other hand, the A10 petition seeks nationwide implementation of A10 service while the C4 proposal was limited to Zone II. As a result, more stations may pursue an upgrade to A10 than C4, and notably in northeastern U.S. and California markets where the FM band is typically more crowded, potentially increasing the interference risk to more broadcasters than the C4 proposal.”
NAB said the FCC seems to have tabled the C4 petition, presumably due to such concerns, and it urged the commission to take into account any similar issues with A10 as it decides whether to advance the petition to a notice of inquiry or notice of proposed rulemaking.
(Read the comments in PDF format.)
Specifics
NAB said the benefits of introducing an FM Class A10 service would be limited.
“Commander provides no technical analysis, and no information on how many stations may be upgradable or where such stations are located, making it difficult for NAB to comment meaningfully on the benefits or costs of adopting the proposal.”
But it believes only a fraction of Class A stations may be able to fully upgrade to A10 due to terrain constraints or FM band allocation constraints under the FCC’s distance separation rules. A larger number of stations may be partially upgradeable with the use of a directional antenna to avoid interference to other stations.
“However, we believe that only a subset of stations that could potentially upgrade are likely to do so because of the expense,” NAB said.
“Upgrading to A10 could require additional costs associated with a higher-power transmitter, larger cooling systems and higher electrical power needs. Stations that would need a directional antenna would incur even higher costs given the added complexity of such antennas. Given that the average revenue (not profit) for commercial Class A stations is only about $400,000, or just $200,000 when noncommercial stations are included, it would appear that relatively few Class A stations would be able to afford to upgrade to A10.”
Class A stations would also have to balance these costs against the expected coverage a station may gain from increasing power by a few thousand watts. It said most Class A stations could extend their service contour by just 2.2 miles.
Interference
NAB also said that it has concerns about interference. It noted that six years ago, when the FCC issued an NOI about the C4 proposal, there were 10,866 FM stations and 7,721 FM translators and boosters. Today, there are 110 more FM stations and 1,185 more translators and boosters than in 2018.
It urged further study if the FCC decides to open a notice of inquiry.
“First, the lower proposed maximum power level for A10 could allow more Class A stations to upgrade, and while this could lead to improved service for additional listeners, it could also further squeeze the band in more markets and impact more FM services,” NAB wrote.
“Second, the C4 proposal was limited to Zone II while Commander seeks implementation of A10 across all zones, including in large Northeastern and California markets. Again, although stations in more areas may be able to pursue an upgrade to A10 than C4, the FM band is often more congested in markets outside Zone II, such that A10 upgrades could erode the quality of FM radio service in more markets.”
It noted that as the FM band becomes more crowded, any increase in power by one station can preclude opportunities by others.
“NAB questions whether introducing an A10 class could impede improvements by other FM stations because the additional band congestion would block them from increasing power, relocating an antenna or making other modifications. In general, other radio stations likely serve larger audiences than the Class A stations that may seek to upgrade to A10, and while all listeners are equally important, on balance, the FCC may want to consider if it would be more effective to not close the door to service improvements by other stations that could benefit more listeners.”
More concerns
NAB also said the petition lacks any technical analysis of the potential impact on FM translators, which have become particularly important to AM broadcasters but remain a secondary service, which would have to protect any full-power FM station, including a newly upgraded Class A10 station. “The Class A10 proposal would potentially enlarge the 40 dBu interference area of existing Class A FM stations by about 20% … potentially degrading the service provided by existing FM translators on co- and adjacent-channels.”
It also noted the “significant” economic and competitive challenges facing radio broadcasters that compete with “almost infinite” sources of online audio content.
“These marketplace changes have fundamentally affected broadcasters’ bottom lines, and although the A10 proposal could benefit certain Class A stations, NAB respectfully urges the commission to take these factors into account as it considers introducing the requested A10 class of service.”
