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Wesolowski, Garziglia Propose C4 Amendment

They say “elegant” engineering solution handles potential impact of new C4 allocation for small, large broadcasters

As the comment deadline in the C4 proposal approaches, proponent for the new FM class Matt Wesolowski has joined with Womble Carlyle attorney John Garziglia to amend the proposal.

The SSR Communications CEO Wesolowski and the Media and Minority Telecommunications Council had earlier petitioned the commission to create a “C4” FM Class. SSR owns WYAB(FM), a 5 kW Class A in Flora, Miss. They say the new FM class would enable many Class A facilities to upgrade to a maximum effective radiated power of 12 kW from a reference antenna height of 100 meters above average terrain.

The concept is the subject of an ongoing proceeding, RM-11727, to add a new FM 12 kW “C4” allocation power class in between FM Class A and FM Class C3 for commercial stations in Zone II.

Now, Wesolowski and Garziglia tell the agency their amended proposal would provide some measure of stability for fill-in FM translators by allowing them to enjoy many of the engineering flexibilities afforded to LPFMs.

Currently, a translator is at risk of interference complaints from any listener at any time, and from any location (no matter how distant). Wesolowski and Garziglia believe their proposed rule change would give translator licensees some assurance in reliability of their service.

“It is exceedingly difficult to displace an LPFM operation altogether, but quite a bit easier to force a translator to leave the air. From an engineering perspective, we are trying to align some of the interference standards between the two secondary services,” Wesolowski tells Radio World.

Among other changes contemplated in the comments, full-power stations would only be able to allege interference from fill-in FM translators within the translator’s first year of operation, and only inside of the full power station’s protected contour. They believe these amendments would address the issue of fill-in FM translators and the potential impact of the FM C4 allocation.

“I believe that we have an elegant engineering solution” that contains incentives for both small and large broadcasters, says Wesolowski.

Comments are due Aug. 18 on the C4 petition, RM-11727.