Support for C4: The Engineering Logic Is “Quite Sound”

One in a series of articles exploring comments about the proposed C4 Class
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We reported last week that an FCC Notice of Inquiry about the Class 4 station proposal triggered a commentary period, and supporters have been quick to share their thoughts about Docket 18-184.

To date, the majority of the comments have been positive. Read on for a sampling of why some advocates say the commission should move forward with this idea. Submit your own comment before Aug. 13.

[Read: Support for C4: Small Stations as First — and Only — Informers]

Some commenters expressed support for primarily technical reasons.

For example, Commander Communications Corp Pres. Carl Haynes of Jackson, Miss., commented, “I have done many studies and this proposal will not force any low power stations or translators to go off the air. There seems to be an engineering solution in which all parties can coexist even in the worst case scenarios. The 73.215 portion of RM-11727 only asks the giant broadcasters to cease warehousing of the public spectrum. Even with this proposal, contour protection will continue, and only those station involved in a triggering application will be converted to 73.215 stations. This is not a downgrade of class. Their class of station remains the same. Many of these stations have warehoused this spectrum for over 30 years. This is not in the public interest. The AM translator initiative made many giant broadcasters even larger, yet there seems to be an objection from this very group for the small Class A broadcasters to just give their listeners a decent signal.”

Haynes added, “Over 700 mostly small and minority stations will benefit from this proposal. We need help with our terrible signals, just to survive in today’s highly competitive marketplace. We are primary stations not secondary stations that need help now.”

Haynes concluded, “Many Class A broadcasters are America's last direct contact to the communities we serve, because we live and work in those communities. ... These changes are very much needed for survival of America’s final source of local broadcasters, the Class A operators, and the 73.215 portion of RM-11727 addresses the issue of no longer warehousing of the public spectrum which is no longer in the public interest.”

Elm City, N.C., WRSV(FM) licensee Charles Johnson wrote, “Atmospheric conditions make reception of WRSV quite terrible in the mornings. Ducting is a serious problem for Class As. In WRSV’s case, the approval of C4/73.215 would help the station overcome consistent co-channel interference, sometimes inside WRSV’s 70 dBu. This interference is from stations whose transmitter sites are well over 160 miles from WRSV’s. By allowing Class As to upgrade to 12,000 watts, WRSV could offer a better signal to its current listeners and provide programming to additional listeners outside WRSV’s current coverage area. The upgrade would help Class As provide a dependable signal in the areas we already serve.”

Johnny Boswell, licensee of Durant, Miss. station WLIN(FM) and owner of Boswell Media, commented briefly: “Where it can be shown that this rule making does not impede existing signals. I think it is a good idea. This is a 3 dB boost. All other classes have a 3 dB gap except class A to C3 which is currently 6dB.” Separately, he wrote, “I think the engineering logic for this rule making is quite sound.”

Alexandra Communications Pres. Thomas Hodgins commented, “A sliding scale type of system for all classes of commercial service whereby the limited factor was contour protection only would result in better service throughout.”

Dallas-based QXZ MediaWorks Pres. Robert Lee wrote to express hopes that the C4 class would mitigate the priority conflicts between new translators and Class A stations. In his comments, he said, “As for the current debate over the ‘C4’ proposal, how is it fair or rational policy to give newfound priority to a thousand-plus new secondary-service translators over already operating primary service Class A FM stations, whose owners spent hundreds of thousands or millions of dollars to purchase or get their full-power stations on the air? At the FCC, have ‘primary’ and ‘secondary’ substantially or entirely lost their respective meanings? ... The option of an FM Class C4 has real-world benefits and meaning. These Class A FM owners are operating in an increasingly competitive business landscape, where an upgrade to Class C4 could well be one option to allow them to better serve their local communities.”

Lake Area Educational Broadcasting Foundation President and Chief Engineer James McDermott also commented, “This is a very common sense proposal that would allow for the upgrade of certain facilities without increasing interference.”

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