A new petition before the FCC seeks the elimination of a section of the rules that pertains to short-spaced FM assignments.
Consulting engineer Charles Anderson wants the FCC to be able to accept applications that specify a short-spaced antenna location for which minimum distance separations are not met.
Anderson says the current language is outdated given the maturity of the band. He thinks the FCC should shift its allocations priority to improving existing facilities.
The relevant part of the rule specifies an “absolute minimum distance” for commercial FM stations, below which no amount of power reduction or signal contour overlap protection may be used to site an antenna.
The rules allow commercial FMs to request sites that are “short-spaced” to other stations by protecting existing service from interference through specific “contour protection” requirements, ensuring the new station’s predicted interfering signals don’t overlap with protected contours of other stations.
Anderson says the rules often allow transmitter site flexibility, especially in congested areas, but that the troublesome subsection prohibits the FCC from accepting applications that specify a short-spaced location for which stated minimum distance separations are not met.
It’s a “strict go/no-go limitation,” he writes. But throughout his years assisting broadcasters to improve their facilities, the “limitations in subsection (e) to §73.215 are the major impediment to existing facilities utilizing directional antennas and contour protection to move to locations that better serve their market areas.”
In many cases, he continues, broadcasters are seeking to relocate to existing towers when sites are lost, or when it is not economically viable to replace aging towers or sustain existing land and tower leasing rates inflated by wireless services.
Andreson calls it noteworthy that reserved-band stations — some 41% of FMs in the country — have never been subject to the restriction on the use of contour spacing.
“While painfully obvious to broadcast engineering professionals, it is useful to observe that there is no inherent nor even significant difference in FM propagation and reception for radio stations in the 88 to 92 MHz reserved portion of the FM band for which the subsection (e) limitation does not apply, and for radio stations in the 92 to 108 MHz non-reserved portion of the FM band for which subsection (e) does apply.”
He says broadcasters are often faced with the difficulty and expense of constructing new towers, because the restrictions frequently have blocked the use of a station’s existing tower for upgrades or the use of other towers when sites are lost or become prohibitively expensive.
Anderson cited an example of a rural Alabama broadcaster being denied a 0.44 km (1,441 feet) waiver in order to upgrade from Class A to C3 at the station’s licensed site even though there was no prohibited overlap.
“Acquisition and tower construction for a new site were financially prohibitive and the expanded 60 dBu service to an additional 58,820 listeners, a 192% increase, was thwarted. In many other cases stations have lost tower sites and the availability of alternate towers was severely limited” by the subsection rule.
The directional antenna 15 dB maximum to minimum rule and the 70 dBμ city-grade coverage rule provide adequate protection from extreme short-spacings, he told the FCC.
In his filing Anderson describes himself as a “heritage” broadcast engineering consultant, adding in a footnote that he has prepared the engineering portions of more than 1,000 FCC applications, engineering exhibits and petitions over 45 years.
The timing of his petition coincides with Chairman Brendan Carr’s “Delete, Delete, Delete” initiative seeking to do away with outdated rules and regulations.
