The Society of Broadcast Engineers shared its recommendations during the FCC’s “Delete, Delete, Delete” deregulation open comment period.
The society filed comments in early April, submitting four proposals of its own. Then, the SBE expressed support for three proposals brought forth by the National Association of Broadcasters that are geared toward AM stations.
The comments were submitted by Ted Hand, SBE’s president, and Charles “Ched” Keiler, the chair of SBE’s government relations committee.
It also expressed support for NAB’s software-based EAS proposal, which Radio World has previously reported.
Major players in the industry have made sure to get their say in the open comment period for the “Delete Delete” proceeding, an initiative the commission put forth to remove burdensome rules and regulations. Replies were due on April 27.
[Related: “Radio Seizes the Moment to Push for FCC Reforms”]
The modernization of FM spacing
The SBE prefaced its own rule proposals by outlining the current technical and competitive landscape of the broadcast industry.
“FM broadcasters must be afforded the regulatory opportunity to maximize their reach,” SBE wrote.
It explained that certain current interference rules “have not kept pace” with modern radio receivers. The intermediate frequency contour rules, for example, date back to the 1960s. At the time, the concern was that the IF of radio receivers used 10.7 MHz as part of their demodulation scheme.
Stations or assignments separated in frequency by 10.6 or 10.8 MHz, according to the rule established in June 1965, are not authorized unless they conform to specific spacing by classes. The current implementation of those rules can be found here.
A radio tuned to 96.5 FM — in theory — could interfere with someone trying to receive a signal on 107.3 FM if the two receivers were close enough.
But the SBE argued that such concerns were based on the older models. “Today’s radio receivers offer significantly improved interference protections from high-power radio frequencies,” it wrote. The society proposed removing those requirements.
Additionally, it advocated for relaxing second- and third-adjacent spacing criteria.
The association said FCC and Congress have already recognized the need to peel back third-adjacents through LPFM rules, where such rules have been eliminated.
“Certainly, there is little reason why interference concerns among other secondary FM services should be treated differently from LPFM stations,” the SBE wrote.
It proposed eliminating the third-adjacency separation condition for boosters and translators. It also urged the commission to either eliminate or significantly reduce third-adjacent considerations for full-power FM stations, with the option to require case-by-case interference analysis, which falls in line with current LPFM rules.
For second-adjacents, SBE believed those separation considerations should be significantly reduced across the board.
“By reducing spacing requirements to appropriate levels based on modern receiver technology, the commission will again allow FM broadcasters to maximize their stations’ reach and service to their communities,” it wrote.
Flexible FM translator audio rules
The society also noted that a number of comments at large recommended the commission eliminate or revise its rules that require certain FM translators to be fed audio signals over the air.
The SBE generally supported giving broadcasters the flexibility to select and implement the most appropriate audio delivery mechanism. It said that policy reasons for limiting how translators are fed audio could be addressed in ways “that do not arbitrarily limit the flexibility of FM translator licenses” to use appropriate technical solutions.
At a minimum, the society advocated for licensees with an OTA restriction to be permitted to feed translators by any method so long as an OTA signal can be shown to be received at the translator location.
(Read the SBE’s comments filed during “Delete, Delete, Delete”.)
Remove AM minimum efficiency standards
The SBE backed the NAB’s “Delete Delete” comments that the minimum efficiency standards required of AM broadcast antennas create a barrier to entry. We reported on those sentiments that were in the NAB’s petition.
The society stated that the standards require stations to use large towers with extensive ground installations, particularly at lower frequencies. It argued that technology has improved to allow the design of smaller systems that provide sufficient coverage. Those designs do not all meet current efficiency standards and as a result the SBE felt they should be removed entirely.
It also concurred with the NAB’s point that AM stations’ community of license coverages are sufficient enough to serve the public interest.
Make the 1605–1705 kHz band accessible
The SBE also supported the NAB’s plea to remove the heightened authorization requirements for the 1605–1705 kHz expanded AM band. When the band was established, a process followed to allow existing AM operators with impaired signals to apply for access.
The commission, according to the SBE, has also expressed preference for nondirectional stations in the expanded band, a preference that the society said is no longer applicable today.
According to the NAB, the commission has not opened a filing window for the band in more than 20 years and there are only 53 stations currently authorized in the band.
“There is no practical or technical reason why applications for access to the expanded AM band should be treated differently from applications in the rest of the AM band,” the SBE wrote.
It urged the FCC to eliminate all alternate application requirements for the expanded band and noted the commission may wish to consider limited skywave protection for the band.
In closing, the society commended the commission’s deregulation-based efforts in its NAB reply comments.
(Read the SBE’s reply comments, which include its replies to the NAB proposals.)
