It’s not over until the fat lady sings. Or, in the case of the “C4” FM class proposal, until the FCC sings, and maybe not even then.
We’ve reported that SSR Communications CEO Matt Wesolowski would like the FCC to create a new FM class; he also asks that the commission, via a “triggering” application mechanism, direct “overprotected” stations that have been “underbuilt” for at least 10 years to either construct full facilities or take a Section 73.215 designation. He believes the changes would “enable upgrade-minded stations to protect each other to their actual contours, rather than hypothetical maximum facilities, paving the way for hundreds of specific FM service improvements.” It’s unclear whether his idea, first noted by the blog of law firm Fletcher Heald & Hildreth, will have traction. But it did generate a quick reply from another prominent communications attorney, John Garziglia, who wrote a response in Radio World calling this a bad idea.
Now we hear from Georgia-Carolina Radiocasting President and CEO Art Sutton, who advises the industry not to make a quick judgment.
Sutton tells Radio World, “It’s not often I disagree with my communications attorney,” but he’d like the commission at least to take comments.
GA-Carolina owns a dozen small-market stations in Georgia, South Carolina and North Carolina. “Our company has FM translators being used by AM stations so I can relate to the concern of translators being displaced, but we all understand that they are secondary services. I don’t want to lose any of my translator frequencies but at the same time I don’t want to cast any water on the C4 concept. While I was not aware of the proposal beforehand, to provide full disclosure, I have at least one station on the list SSR says would qualify for C4 status.”
Sutton thinks there might be a middle ground. “From a spectrum standpoint, it does appear there is a gaping hole between a 6,000 watt FM station at 100 meters, which is a Class A, and a C3 which is 25,000 watts at 100 meters. It would seem that if some Class As could increase to 12,000 or 12,500 watts it would provide a greater degree of opportunity for full-power Class A FM stations, of which the greatest majority of Class A FM stations are located in rural areas. LPFM and translator frequencies are not as limited in rural areas as they would be in larger populated areas.”
He reminds everyone that translator assignments are flexible. “The FCC allows displaced translators to move to any open channel if frequencies are not available as a minor change to the existing channel.”
Sutton concludes, “I encourage the FCC to ask for comments on the proposal. It doesn’t hurt to study it closer. If nothing else, maybe the FCC will consider letting nonreserved band FM stations switch to contour spacing instead of the current mileage spacing. It works for reserved band FM stations, so it can work in rest of the FM band, too.”
