On Interference, “We Need a Better Solution”

RW asked Ed Henson to shed light on discussions about translators vs. full-power signals
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The following interview appeared in the recent Radio World eBook “AM Translators: What’s Next?” Ed Henson Jr. served on an NAB working group that proposed a rule change to facilitate resolution of interference complaints between translators — which are classified as a secondary service — and distant but full-power stations. We asked him about it.

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Ed Henson Jr.

Henson is president and owner of Henson Media, which has two AM stations (each with an FM translator) and two full-power FM stations, all in Kentucky. He is a media broker and valuation expert; member of the NAB Radio Board; board member and former president of the Kentucky Broadcasters Association; and son of a radio engineer.

RW: Has the AM translator regulatory strategy generally been successful?
Henson: This proceeding has done a lot to help revitalize AM broadcasters. And it helped to revitalize the AM band as well, because it makes those stations more viable and people will keep those AMs on the air. AM stations can now do [more] high school sports. A lot of stations are daytimers with no nighttime signal, or have highly directional nighttime signals; now they’re able to provide service to that community. I’ve been in towns in Kentucky where people are very grateful; they can hear their station on AM, and now they can also hear it on FM.

RW: You expressed concern that AM stations put in such effort to build and promote translators, yet with one interference complaint, all that can be lost.
Henson: I have a lot of respect for the way the allocation rules and policies work, except when it comes to translators. From my perspective, the way translator interference issues are resolved is like the Wild West.

There were already many translators on the air prior to the 250-mile waiver move window last year, and there were about 1,000 filed to move translators; and there were 1,081 [applications] filed in the July window this year. So there are a lot of translators coming on the air. [Interference] is only going to get more prevalent. We need a better solution for it.

Among the 1,081 applications filed in July by Class Cs and Ds, there were 93 groups of mutually exclusive applications involving 201 applications. But that would leave 880 singleton applications, and those stations are probably coming on the air pretty soon. And then of course the next window will open up in 2018.

I know of cases where stations had to hire a private investigator to investigate the person making the complaint to prove whether or not that person is a disinterested listener, or whether they have any ties to the complaining station.

I’ve heard people say, “There are only 25 or 30 complaints with the FCC involving interference with translators; how big an issue is this?” But whatever that number is, on both sides of the equation, the full-powers and the translator operators, it’s a huge issue. They deserve a better system.

I represent broadcasters in Kentucky and West Virginia on the NAB Board. I approached the staff at the NAB because I’m getting a lot of comments from broadcasters in my district that we need a better system of resolving these complaints.

RW: So where does that effort stand?
Henson: We had a committee of eight people. We had [engineers] Jeff Littlejohn from iHeartMedia, Sam Wallington from EMF, Mike Cooney from Beasley, Sam Caputa from Emmis; but then you also had Bud Walters, who is a small-market broadcaster; Bruce Goldsen, an NAB board member and a small-market broadcaster in Michigan; and Dr. Chuck Anderson, a consulting engineer who is very knowledgeable about translators.

We made three proposals in January. The board adopted one and asked the NAB staff to file a request for rule-making at the commission. That request is pending at the FCC.

Currently, if a translator is on the air and a full-power station comes on the air and displaces it, that translator can move anywhere in the band to find a new home as a way to resolve that interference.

But say a translator is on the air and a full power comes and complains, “Hey, you’re interfering with me,” the only flexibility a translator has in that case — not displacement, but interference issues — is to move three channels up and three channels down. So if you’re 101.1, you can go to 101.3, 101.5, 101.7 — or three the other way.

What we proposed is that the FCC would allow that translator to move anywhere on the band. Of course, it’s going to have to prove that the new frequency won’t cause interference; but this gives it more flexibility in finding a new home.

It won’t be a panacea, especially in larger markets, because it may be hard to find additional frequencies in larger markets; but in small and medium markets, in most of the country, you could probably find another frequency.

That helps full-power stations, because they get rid of the interference more quickly; it helps the translator because it can have more options to stay on the air; and it helps the public, who continue to get the service of the translator.

My personal view — and this is only Ed Henson Jr. talking — is that we also may need some kind of contour. We’d say, “Within that contour, we’re going to be very diligent about protecting full-power stations, resolving interference complaints, making sure these things don’t drag on; but at some point, beyond that contour, before it becomes totally unreasonable, full powers are no longer protected.”

Translators are secondary services and they must remain secondary services. But they’re also rebroadcasting a primary service. We don’t want to lose sight of that, either. So the question becomes, at what contour do you have that cutoff? If you get 10 broadcasters in a room, you’ll get 10 answers.

My own view is that full powers should be protected beyond their FCC-protected contours. When you calculate HAAT for protected contours, the calculation is only done from two to 10 miles. Beyond 10 miles, it takes into account nothing about terrain, which can change dramatically. I think you need to go beyond protected contours. My own personal feeling is somewhere, at least 6 dBu more than in the protected contours — or you can make somewhat a good case for a 48 dBu contour — beyond that, full powers would no longer be protected.

Some of the great stations in my area are big Class C FMs, and they need to be protected. They provide a real service for people. [But] if you have a thousand people listening to the FM translator, and maybe two or three people complaining they can’t hear the full-power station 100 miles away, at some point I think the translator deserves — I think the FCC needs to look at it and say, “Where is the public being served the most?”

RW: Is there anything else you would want AM broadcasters to know to maximize a translator opportunity?
Henson: Not all translators are created equal. Any money spent on good engineering even before you file is money well spent. Make sure you get a competent engineer to design your translator.

The best way to avoid interference complaints is to make sure, when designing it, that you’re looking for the frequency you want to be on; make that extra effort to look at the Longley-Rice studies; drive your signals and see where you don’t hear other stations. Put a lot of effort into finding the right frequency for your translator.

Also, I don’t even call it a translator, I just say WSON(AM), and WSON(FM). We embrace the fact that you can now hear our signal on FM.

Maximize it like you do any other station. Put good programming on there, of local interest. Don’t just flip whatever syndicated programming on it. You’ve got to stay local. You’ve got to be involved.