In this series, we’re sharing articles about trends in FM translators and how to get the most out of them.
Terry Cowan has been installing and maintaining translators since 1986. He is the founder and general manager of KNLR(FM) in Bend, Ore., and KNLX(FM) in Prineville, Ore., which have several translators.
Radio World: How can a broadcaster go about deciding whether a translator would help them?
Terry Cowan: I can’t think of a situation where a translator would “hurt” a broadcaster unless they are unable to afford the cost of installation and the operating costs. Having said that, the first consideration is: Does the signal from my radio station adequately serve my listeners? If there is terrain that blocks the signal to any part of my listeners, a translator is a valuable tool to fill in the area where the signal may be weak.
The application process has become more difficult over the years, usually requiring a consulting engineer and FCC attorney to develop the paperwork. And of course waiting for the FCC to open a window for applications.
Unfortunately, this is a huge change from the early days of translators. Before the proliferation of translators and “application mills,” one could sit down at a kitchen table, fill out FCC form 349 and in about six months receive a construction permit — no engineering fees, no attorney fees and no FCC fees.
RW: What are the key rules or restrictions?
Cowan: I won’t pretend to know all of the rules, and many are dependent upon the situation. Some are the same for commercial and non-commercial, for fill-in and non-fill in.
Let’s start with fill-in. A fill-in translator is one in which the translator’s 60 dBu contour is totally inside the 60 dBu contour of the primary or parent FM station. The 60 dBu contour of a fill-in translator for an AM station is permitted within the 2 mV/m contour or 25 miles from the AM station, whichever is greater.
A fill-in translator may receive its signal from “off-air” or any other method such as STL, telephone line or internet.
A non-fill in translator is one whose signal falls outside of the primary station’s contour. Non-fill in translators may be owned and operated by non-commercial broadcasters or by third-party licensees.
A commercial broadcaster is generally prevented from owning and operating a translator outside the contour of the primary station, although there is an exception. If the non-fill in translator is serving a “white area” the FCC may accept a waiver request and permit the primary station licensee to own and operate a translator. A “white area” is one in which no commercial station is providing a AM 2 mV/m or FM 60 dBu contour.
Generally speaking, a fill-in translator may operate with a maximum power of 250 watts ERP, provided it meets certain co-channel and adjacent-channel requirements and its contour is fully contained within the requisite contour of the primary station. Non-fill in stations must meet both co-channel and adjacent-channel protection requirements and the ERP may be up to 250 watts ERP, but there may be a reduction of ERP based upon the height above average terrain of the antenna. Again, the FCC will entertain waivers for powers up to 250 watts for “white areas.”
The only restriction on broadcast content is that it may not originate programming but must broadcast the same programming as the primary or parent station. There are exceptions. A translator may broadcast a message in the event of an emergency of imminent danger; and a translator may broadcast an announcement seeking or acknowledging financial support for no more than 30 seconds per hour.
The FCC requires that a translator be identified. There are two ways. You can announce the call letters of the translator three times per day — once between 7 and 9 a.m.; once between 12:55 and 1:05 p.m.; and once between 4 and 6 p.m. This is done by the primary station announcing the call letters of the translator.
Another option is to give the call letters of the translator every hour using Morse Code by frequency shift keying or FSK. It transmits the call letters by shifting the output frequency of the translator slightly but it is not audible or discernible to the listener. Some current transmitters have this option built in.
To learn the rules, become familiar with the Code of Federal Regulations, Title 47 Part 74 Subpart L.
[Check Out More of Radio World’s Tech Tips]
RW: What are the key components of an installation?
Cowan: In its simplest form a translator station consists of a receive antenna, a receiver, a transmitter and a transmitting antenna. In the early days of translators the receiver and antenna were in the same “box.” The receiver board received the incoming signal and sent it to the transmitter board, which mixed it with a local oscillator that changed the output frequency and amplified it before sending it to the transmit antenna. Many translators today consist of separate receivers and transmitters.
The simplest form of remote control is “squelch.” When the primary station goes off the air or there’s some other failure to receive the primary station signal, the translator output also ceases. However, there’s nothing to prevent more exotic control systems, and many of the new transmitters and receivers may be connected to the internet for control. Nautel transmitters and Inovonics receivers not only provide control but other information useful for troubleshooting and maintenance — other manufacturers no doubt provide the same, those are the ones with which I’m familiar.
With the advent of RDS there came an interesting control feature that guards against “hijacking” by a distant co-channel station during a ducting event or someone initiating malicious interference. A receiver that can decode RDS can be set up to shut down a translator if the receiver does not receive the unique RDS code from the parent station. Or for an emergency shut down of the translator, temporarily suspend transmitting RDS.
RW: Translators are a secondary service; what complications has that caused?
Cowan: I can relate one personally. We had a translator station licensed that I wanted to move, and it involved a frequency change, which was granted. Before we were able to move it, another station came on the air on a frequency considerably removed from the frequency of our new translator CP. However, the new station caused interference — likely not the station’s fault — to an FAA installation. The FAA succeeded in getting the FCC to rescind the license of the station.
To resolve the case, the FCC reassigned the station a frequency near the frequency of our construction permit, resulting in our CP being unusable. We asked the FCC to change our CP to a new channel, which they denied. Their reason was that our translator was on the air at the licensed frequency, which was not a conflict with the new station and therefore not displaced. They would not consider that the CP was displaced.
We asked another broadcaster to change the frequency of their translator a couple of channels, which they graciously did, and allowed us to reapply for a channel that was permitted. In the end we got what we needed, but it would have been more efficient to permit the change without asking another broadcaster to move.
RW: Any best practices to suggest?
Cowan: The transmitter site is critical. If you are utilizing the signals of the primary station directly for programming, you must have a location that can receive the signal reliably without interference. Here in the west, we are sometimes able to take advantage of signals refracting over a mountain range — knife edge refraction — but it is always better if you have line of sight.
The second part of site selection is to get as close to the people you want to serve. Translators typically have much lower output than full-service stations, so it’s important to get close to the population to achieve building penetration.
RW: What are the challenges of operating older translator infrastructure?
Cowan: One challenge is the proliferation of new stations. In one case, a station came on that was co-channel with our primary station. Even though it was some distance away, it caused interference. Naturally as a secondary device it was incumbent upon us to fix it, which we did by moving the receive antenna off the supporting structure on top of the mountain and put it around the side of the mountain below the rim, shielding the desired signal from the offending signal.
The normal maintenance issues are pretty much the same as with full-power stations. Electronic devices will fail at some point!
RW: What other concerns do operators face in 2024?
Cowan: Third-party translators are probably the most vulnerable. In the past there were groups that would install translators (both FM and TV) to serve their communities. The original “pioneers” are dying and newer generations are not as eager to keep things going.
RW: Are there other questions we should be exploring?
Cowan: I would like to see the FCC make it easier for primary stations to file for new FM translators. Who knows when the next window will open? But there are some of us who want to provide additional services, particularly to “white areas.”
I recently asked about a process for applications to serve white areas and was told the only way for a new FM translator was in a window. That’s not right. People in a white area deserve service as well. And white areas typically have a lot of unused frequencies, so there is no need for a competitive process. “First-come first-served” is reasonable for white areas. By restricting applications to primary stations only the FCC could avoid applications from organizations whose primary business is not to broadcast but to “flip” CPs for profit.
Also, in my opinion there is inequity between commercial and non-comm. While a commercial broadcaster is generally limited to operating a translator within the specified contours of its station, a noncom broadcaster may establish a translator wherever it wishes, providing there is a frequency. Non-coms may not take our ad revenue but they take listeners.
But speaking generally, translators in many ways are not unlike full-power stations; they just operate under different rules. To the listener it is just another station to which they listen. In many cases a translator fills an empty niche.
One of our stations operates in HD Radio; its HD-2 channel is Spanish but is also heard on an FM translator. The translator serves listeners that otherwise would not have a local station in their language. And a translator can typically be “shoe-horned” into a space that a Class A couldn’t, without the time and expense of adding a new channel to a community.
Read more on this topic in the free ebook “What to Know About FM Translators.”
