The FCC received about 30 comments from radio industry stakeholders on the idea of creating a new FM Class A10.
We’ve reported that the NAB said it cannot issue a recommendation at this time, while Cumulus Media opposes the idea and REC Networks wants the FCC to pair it with a power increase for some LPFMs.
Here is a sampling of other comments, pro and con, and a link where you can read all of them:
- Consulting engineering firm Cohen, Dippel and Everist identified 16 stations in the country that it believes would be most likely to file for A10 because they are already operating at the maximum effective radiated power for Class A, which is 6 kW. It submitted two maps showing what it found, one of which is shown here. (Read its comments and view the maps.)
- Consulting engineer Timothy Sawyer “supports improvements to the listener reception experience when possible, but does not believe that the creation of an additional FM class of operation is the correct manner to do so at this time.” He urged the FCC “to consider alternative means to determine interference between proposed existing aural broadcast operations. In particular the procedures outlined in OET Bulletin Number 69 should be adopted.”
- The Multicultural Media, Telecom and Internet Council supports the petition. “This new Class A10 would potentially allow several Class A FM stations, many of them owned by small and minority broadcasters, to upgrade to the new A10 classification and broadcast a stronger, clearer signal, which will serve the public interest,” it wrote. “Since many of these stations are in rural areas this could mean a more reliable signal for news and emergency information. If adopted, MMTC believes the petition could contribute to the commission’s policy goal of spectrum efficiency. As the commission seeks solutions to increase the dwindling numbers of minorities and women owning commercial broadcast stations, implementing policy proposals like Commander’s can help ensure that the broadcasting industry does not lose even more of these stations.”
- Though Common Frequency believes the proposed rulemaking would allow “nominal signal upgrade,” it cited problems of potential extensive interference and/or displacement to LPFM and FM translators, “services that provide some of the bread and butter of broadcast localism nowadays.” It does not support the measure as proposed, saying it is not in the public interest. “If alongside the Class A10 proposal the FCC considered measures for LPFM licensees to address interference and displacements — such as LP-250 and ‘last chance’ migration to Class D service upon displacement — CFI would be potentially swayed to support a new Class A10 service,” it wrote.
- Matthew Wesolowski, CEO of SSR Communications and the driver behind the previously proposed Class C4, called on the FCC to approve the FM Class A10 allotment type without delay. “Although WYAB would not benefit from this proposal in any way whatsoever and could even be subjected to a potential ‘downgrade’ from its current Class C3 to the proposed Class A10, SSR nonetheless supports the concept as a more efficient use of broadcast spectrum than the current commission scheme affords and its opportunity for select FM Class A licensees to obtain more reliable signals inside of and just beyond their existing service areas.” He noted that SSR’s station WYAB recently had a class upgrade and “even this relatively small increase in power made a noticeable improvement in coverage and signal reliability.”
- Larry Fuss, president/CEO of Delta Radio Network, expressed support. “The A10 station upgrade option could potentially benefit several of my company’s Class A radio stations, almost all of which are located in rural communities that depend on the news and weather information that we provide,” he wrote.
- Also in support is Jeffrey M Andrulonis, president of Colonial Radio Group. Having the ability to increase power to 10 kW will be beneficial for small licensees like Colonial, he wrote. “Perhaps more importantly than the business reasons to support the Class A10 proposal, are the diversity reasons. Small licensees are small businesses and many of them are minority-owned. This diversity of viewpoint provides an independent voice in their communities, in some cases the only independent voice remaining. The power increase under consideration would allow more listeners to hear these independent voices, which can only serve to strengthen our democracy.”
- Total Media Group in south-central Ohio has been frustrated by coverage issues. It said many FM stations in rural Appalachia often suffer signal loss due to mountainous terrain. “While many stations might explore costly options to improve penetration with an FM booster, a more favorable solution would be a change in the station’s current class to the proposed Class A10 where the increases allowed would mitigate the coverage anomalies, while also allowing the licensee to allocate the cost of a booster and additional tower site toward a more local service.” The proposal would help small stations stay where they are rather than relocating to more populous areas, it wrote.
- Kaskaskia Broadcasting Inc. and Miller Communications Inc., licensees of 13 signals in Illinois, said A10 has a “laudable” goal but that the proposal “would wreak havoc with FM translator secondary service and diminish significantly the efforts the commission made with FM translators in connection with the AM Revitalization proceeding.” It said the proposal would help only certain Class A licensees while imposing a disadvantage on other Class A licensees who have no existing ability to increase power and would be subject to increased interference from new Class A10 facilities, as well as on AM licensees with secondary service FM translators that would be subject to new interference claims, “potentially causing reduction of translator power, channel relocations or license termination as secondary service.”
- Telecommunications consultant Doug Vernier expressed technical concerns with the proposal as submitted. “When we adapted our FMCommander frequency search program to the proposed separation table, we found irregularities in the minimum distance separation tables for Zone I comparisons that would result in increased interference. … The 10 kW separations should be greater than the 6 kW separations, but they are not. The petitioner’s class A10 to B1 followed with the same problems, Vernier wrote. “With further work on the Zone I tables the petition may become viable, but as it stands it will not work.”
- Alan L. Button, president of WLHC(FM) in Angier, N.C., asked the FCC to move forward with A10. “As for the technical implications … we have full confidence in the FCC’s track record of identifying and adopting minimum distance separation requirements and short-spacing tables that address potential interference issues and reasonably protect the interests of all concerned.”
You can view all filed comments at this link. Reply comments are due Aug. 21. Use the FCC’s online filing system. For “Proceeding” enter MB Docket No. 24-183.
