Text has been updated to include the meeting with Commissioner Clyburn and to detail suggestions from NABOB about two filing windows.
A fresh idea involving FM translators is floating at the FCC as part of its AM revitalization discussions.
The commission staff appears to be considering a window or pre-approved waiver process during which stations could relocate FM translators up to 250 miles. This would be in lieu of a proposal that has circulated widely to create a filing window just for AM stations to apply for FM translators.
The Media Bureau’s Peter Doyle and Holly Saurer recently met with David Honig of the Multicultural Media, Telecommunications and Internet Council and, separately, with James Winston of the National Association of Black Owned Broadcasters, who in turn met with Commissioner Mignon Clyburn, according to two summary letters, one filed by Francisco Montero of law firm Fletcher, Heald and Hildreth on behalf of MMTC and NABOB, and a second filed by NABOB.
Doyle told Honig and Winston that key issues to be considered in analyzing this proposal would be the cost of translators, their availability and demand for them in various geographic locations, according to the summary. “Mr. Doyle showed us two spreadsheets and a table of data from which the Media Bureau appears to have tentatively concluded that the 250-mile proposal would be beneficial to AM licensees,” the letter states. Honig urged the staff to put this information into the public record and, if the FCC doesn’t open a translator window, to issue a further NPRM on this idea.
During the meeting with Clyburn, NABOB proposed that the commission consider opening two filing windows. The first would be limited to licensees of Class C and Class D AM stations, “because these stations operate with limited or no nighttime power,” NABOB said in a subsequent letter filed with the FCC. Second, after completion of selection of licensees in the first filing window, the commission should open a window for Class A and Class B licensees. According to the NABOB letter, each licensee should be permitted to obtain only one FM translator per AM station.
Contacted for further comment, Honig told Radio World that the new proposal, done right, would be a modest step forward. “But it would be a tragic mistake if the FCC did only 250-mile relocations. We need a big step forward, and only an AM-only translator window can deliver that,” he said. “Without an AM-only window, I fear for the survival of about half of the minority-owned AMs, especially the small-market Class C and D standalones and daytimers.”
The MMTC/NABOB letter listed other concerns and issues, should the idea be formally and publicly proposed. A 250-mile waiver for relocating translators “could be worse than doing nothing because it creates an opportunity for larger stations to corner the market on all the remaining translators,” which are relatively are expensive and often “out of the reach” of smaller AM stations. The result, Montero wrote in the letter, is that bidding wars would continue and translators become further out of reach to AM. “Instead of expanding the universe of available translators, the waiver will expand the universe of large stations with which the smaller operators will have to compete.”
As Radio World has reported, an AM Radio Revitalization Report and Order is on circulation at the commission, and the idea of a translator window has garnered more attention than any other proposal. Interested parties including members of Congress and individual broadcasters have filed with the commission to share opinions. Most recently the Congressional Black Caucus sent a letter to the FCC on Sept. 1 expressing concern that the FCC may not include a translator window.
Radio World has reached out to the FCC and to Fletcher, Heald and Hildreth for comment.
Let's Talk About Translators (A special Radio World series by John Garziglia)