Commentary: Impact of a Class C4 Allocation on FM Translators

Of 217 found to be most likely to take advantage of the new power class, just 25 total FM translators would be subject to potential displacement
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The author is CEO of SSR Communications Inc.

The FM Class C4 Allocation (RM-11727) is now on the Federal Communications Commission’s agenda; but as with many initiatives, fear of what is new and the potential impact on the status quo often short-circuit logic, with panic supplanting common sense.

Such a scenario is now playing out with the controversy surrounding the proposal, which would create a 12 kW Zone II FM station power classification, nested between Class A and Class C3.

Although the initial petition for rulemaking received wide support within the broadcast community, particularly from those operators with Class A FM stations, a handful of high-profile objectors have made the unsupported allegation that hundreds of FM translator stations would somehow find themselves knocked off the air as a result of eligible Class A FM licensees taking advantage of turning up their transmitter power.

With the commission’s recent attention towards AM revitalization, it is understandable that several freshly-minted FM translator licensees have repeated similar comments. After all, what AM station would want to have their substantial investment in a new FM signal evaporate due to a primary Class A FM station in the “next town over” applying to upgrade?

The studies to support the conclusion that RM-11727 will force hundreds of translators from existence do not themselves exist. To that end, one of original petitioners in the Class C4 proposal, SSR Communications Inc., did a study, using publicly available FCC FM databases, to determine whether or not hundreds of translators would, in fact, be displaced by qualifying Class A stations taking benefit of the C4 allocation.

The study examined roughly 1,500 Zone II Class A stations for their Class C4 eligibility, and of the 217 found to be most likely to take advantage of the new power class, just 25 total FM translators would be subject to potential displacement from the C4 allocation.

Of those 25 affected translators, 24 of them had at least two available alternate FM frequencies at their licensed or permitted tower sites for relocation, while the average displaced translator had more than a dozen possible FM channels suitable for relocation.

The lone remaining FM translator station (in the whole nation) subject to a potential “kicked off of the air” scenario now has a valid FCC license on an alternate, unaffected frequency.

In summary, the study observed that there would be no net effect towards FM translator stations as a result of the proposed FM Class C4 station allocation.

Similar changes to the commission’s rules are not unprecedented, and the last time that FM broadcasters witnessed the creation of a new FM classification was more than 15 years ago (FM Class CO). Past allowances for FM Class C0, C3 and others have made it possible for hundreds of radio stations to better serve millions of potential listeners.

Why would FM Class C4 be any different?

The Class C4 FM Translator Impact Study, its methodology and summary thereof are available online to anyone who would like to verify its conclusions.

Those who are interested in the Class C4 Allocation are encouraged to visit the petitioner’s general information website at http://www.wyab.com/petition/.



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