Insinuating a connection between Dr. Frankenstein’s monster, National Public Radio wants to see an end to low-power television Channel 6 stations using analog FM radio services and has asked the FCC to refuse future authorization of such use of what it calls Franken FM stations.
NPR filed its comments in response to the FCC Media Bureau’s request for feedback on whether analog LPTV stations should be able to continue to program an analog radio service — available on the FM dial (87.7) — after the final digital television conversion deadline.
NPR says that LPTVs’ use of radio airwaves can occupy 30x the spectrum a traditional FM station would use and would cause problems if permitted to continue to operate on analog.
“Franken FMs pose an ongoing threat of harmful interference to public radio stations operating in the immediately adjacent FM band reserved for noncommercial educational broadcast stations,” NPR’s comments to the FCC read. “Moreover, the grossly inefficient use of spectrum adjacent to the NCE reserved FM band ultimate prevents public radio stations from expanding their signal coverage or otherwise offering a multiplicity of additional public service programming for the American public.”
LPTVs believe that these concerns are exaggerated.
“There [are] currently over 20 LPTV stations transmitting analog audio carriers available on 87.7 FM, yet the LPTV-C is not aware of any outstanding (not resolved to satisfaction of the listener) complaints about actual interference between the audio signal transmitted by these analog LPTV stations and nearby FM stations on Channels 201 or 202,” the group told the FCC. “However, if the commission chooses to be overly cautious, it can adopt both contour overlap restrictions and prohibitions on actual interference that would eliminate any theoretical risk of interference between 87.7 FM audio carrier and nearby NCE FM stations. In everyday, real-world operating conditions, the current or proposed expanded 87.7 FM services will not cause impermissible interference to other broadcast licensees in their markets.”
LPTVs also have argued that their stations benefit unserved or underserved audiences, though NPR counters that these stations typically offer country, contemporary, Spanish language, religious and sports programming, areas that it says are well served by FM radio stations.
This can all be traced back to the digital conversion of 2009. At that time, full power stations were required to go all digital, but the FCC allowed LPTVs to continue to broadcast in analog until 12 months after the completion of the post-incentive auction repack. The auction is currently scheduled to be completed on July 3, 2020, giving LPTVs until July 3, 2021, to switch completely to digital.
NPR, in its argument, says that its position of ending operation of Franken FMs is supported by the Communications Act, FCC regulations and federal communications and spectrum policy. If LPTVs were allowed to continue Franken FM operations, “[the FCC] would have to develop additional rules to govern these Franken FM services to avoid interference to adjacent reserved band NCE FM stations and to assure reception of the LPTV’s primary video service by DTV receivers.”
NPR concludes the commission would better serve the public by reaffirming the DTV conversion deadline.