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Upsurge of Comments Ahead of Deadline

Hot AM revitalization topics include support for relaxed main studio rules and local station power increases

A few business days before the close of the submission deadline, comments have begun to really pour in to the Federal Communications Commission on the AM radio revitalization order.

Issues up for debate include improvements for traveler’s information stations, support for relaxed main studio rules, local station power increases and allowing dual-band licensees to keep both licenses.

Others are less convinced on the necessity of revitalizing AM radio at all. As it stands, AM radio retains a beauty and simplicity that can’t be duplicated, as such should not be interfered with, says Chris Campbell, a listener in Traverse City, Mich., who seems a stalwart AM radio devotee.

“So I’m driving down the road at night. There are times when the public radio FM broadcasters seem to have conspired to play stuff I’m not inclined to hear, and I’ll flip to AM,” he said in his comment filing. “There’s something magic about driving down the road in the dark, listening to radio stations from across the continent. Maybe a ball game, maybe some news, maybe (sadly, less commonly) some music. Oh, here’s a Canadian station, in French! Do I want to hear the same lowest‐common denominator junk that’s on the local FM stations? No! No way!”

The FCC’s revitalization proposals, Campbell said, “will not improve local AM broadcasting; it will remain the equivalent of local commercial FM broadcasting, a lowest‐common‐denominator undertaking, just with less fidelity.” Instead, he said, “what you will do is to kill off the really useful and unique service remaining on AM radio, which is those big high‐powered stations that can and do offer some unique and desirable programming.”

“This seems to be a solution in search of a problem,” he said. “Kill it.”

Most are offering specific suggestions to revitalize the band, including allowing dual-band licensees to retain both authorizations. James Coloff of Sturgis Falls Broadcasting said that the good-faith construction investment it made in expanded band station KCNZ(AM) offered improved AM service to Cedar Falls, Iowa, its city of license, and that its standard band station KCFI(AM) currently offers programming for minorities and other underserved audience segments. He requests that both stations retain established service while simultaneously working with the FCC to remove any objectionable congestion and interference.

Others expounded on the benefits of more flexible siting of cross-service fill-in translators.

“As a single-station small business operating with a current FM translator, this expanded coverage contour will allow us to expand our service to a larger number of listeners, to provide the additional service area with access to WPKZ programming, including local and regional news and public service information, and would enhance WPKZ’s commitment to public service,” said K-Zone Media, licensee of WPKZ in Fitchburg, Mass.

“Our opportunity to take advantage of this rule is limited as a Class B AM with an existing translator, and we would strongly encourage the commission to consider allowing stations meeting the SBA designation of small business to both participate in the second Class C/D translator window, and to allow us to site a second translator on our existing channel anywhere within the greater of our 2 mV/m daytime contour or a 15-mile radius centered at the AM transmitter site,” the licensee said in its filing.

“In our case, this would allow a much better fill-in to the north or south where our FM coverage is compromised by terrain and limits of our current signal power,” the licensee said in its comment filing.

Others offer specific suggestions on relaxing studio rules, including Blount Masscom, a licensee of five AM stations in several New England states. “The commission should immediately begin to grant waivers of the main studio rules for certain AM stations to provide significant and much-needed financial relief to AM broadcasters,” the filing said. “Blount continues to strongly believe that relaxation of the main studio requirement for AM stations is vital and necessary to the continued longevity of AM radio.”

The pending Further Notice of Proposed Rulemaking is soliciting comments until Monday, March 21. Comments are being accepted via the ECFS database. Comments can be made using proceeding number 13-249.