The National Association of Broadcasters laid three final requests at the door of the Federal Communications Commission as the next window of opportunity to comment about AM radio revitalization closed.
Monday the NAB submitted reply comments on three proposals raised in the commission’s Further Notice of Proposed Rulemaking: elimination of the 40-mile contour limit for cross-service FM translator location; relaxing main studio rules for AM broadcasters; and action on the part of the FCC to minimize ambient noise that is degrading AM radio reception.
The NAB said the proposed 40-mile limit on locating FM cross-service translators is unnecessary.
The NAB agrees with one provision related to cross-service siting: allowing the 60 dBμ contour of an FM cross-service translator to be contained within the larger of a 25-mile radius from the AM’s transmitter site or the AM’s daytime 2 mV/m contour (instead of the smaller of these criteria, as it currently stands).
But otherwise, the 40-mile limit is not necessary, the association said. The NAB argues that not only is this limit arbitrary, but any specific distance limit could still hinder access by listeners in areas beyond that limit.
The NAB also said the commission should relax its main studio requirements, which would help to improve the efficiency of AM stations without reducing localism. This is an issue within the revitalization proceeding that has received overwhelming support from broadcasters during the comment period, such as those submitted by the Multicultural, Media, Telecom and Internet Council.
The association also echoed others in the industry in pressing the FCC to take up the issue of interference. It said intra-service interference is not necessarily creating the biggest problems. “Rather it is manmade ambient noise caused by unintentional and incidental producers of RF radiation that often drives listeners away,” the NAB said. The association pressed the commission to conduct a thorough review of relevant Part 15 and Part 18 rules, and set up a plan of enforcement.