The FCC is now accepting public comments on a proposal by Ron Rackley and Ben Dawson to ditch the so-called "Ratchet Clause" that affects AM station nighttime operations.
Comments about RM-11560 are due quickly — Oct. 9.
In their filing, the prominent broadcast engineering consultants state: "This proposal seeks to eliminate the following words, commonly referred to as the 'ratchet clause,' from footnote 1 of 73.182(q): Those interferers that contribute to another station's RSS using the 50% exclusion method are required to either reduce their contributions to that RSS by 10%, or to a level at which their contributions no longer enter into the 50% RSS value, whichever is the lesser amount of reduction."
The engineers say the requirement, added to the rules in 1991, does not accomplish what it was intended to do, and in fact, is a serious impediment for stations. Because of the rule, many AMs have to take a severe hit in power reduction if they want to improve facilities "to alleviate nighttime coverage difficulties as a result of noise and man-made interference," they write.
It seems the FCC has many ratchet clause waiver requests pending, making at least one interested observer believe that's why it's focusing on the petition.