Graham Brock, Inc.
Broadcast Technical Consultants
Vol. IX, No. 9
September 2002
Last month the FCC issued a letter requesting an amendment to a pending application. This in itself is not unusual since pending applications require amendments from time-to-time. However, what distinguishes this letter from others is that the applicant had demonstrated coverage to its community of license using a supplemental propagation model, Longley-Rice. In order to do so, they showed the Commission’s staff that the “terrain varied widely” from the FCC propagation standard of 50 meters and the distance to the actual city grade contour was greater than 10% more than the standard FCC methods. Normally, the staff would then forward the study over to its Office of Engineering Technology for review and confirmation. In this case, the Audio Division staff indicated that the terrain did not vary “widely” and, therefore, they did not refer the study. This same letter set out the amount of variation needed to show that terrain varies widely. Previously, there was no defined limit and the Commission was hesitant to set one in previous rule making cases.
The restrictions on the definition of widely does limit cases where a supplemental study can be submitted, but does not eliminate the practice entirely. This type of showing can still be used to show compliance with coverage requirements for communities of license and main studio compliance. The Commission’s own point-to-point propagation model, which would be used as an automatic alternate method, presumably without the need to demonstrate terrain variations or contour extension percentages, is part of the Technical Streamlining rules that has been deferred (along with negotiated interference). Stay tuned.
During the first two LPFM filing windows, applicants were allowed to submit requests without consideration of 3rd adjacent channel spacing issues. Following those windows, the rules were changed requiring LPFM’s to protect 3rd adjacent full-service stations. A Public Notice was issued in April 2001 indicating applications filed in the first or second window that did not meet the 3rd adjacent rules would have the opportunity to submit a major change amendment to change channels in order to remove the conflict. A window for filing this amendment will open October 28th and close on November 1, 2002. Only those applicants that filed in the first or second LPFM windows are eligible and must demonstrate that their present application has a 3rd adjacent issue in order to submit the amendment. A list of those applications that are eligible for this window was released as part of the Second Report and Order (creation of the LPFM service) on April 2, 2001. Some additional applications were listed with the recently issued notice regarding the window.
During the preparation of a minor change application, we noted the existence of a new LPFM station operating on a 1st adjacent channel to the full-service station. Since this application was being submitted to implement a change in community of license, the LPFM permit was apparently granted during the pendency of the community of license change, without protecting the potential new channel. The existence of this low power station would have caused interference to the full power station within its city grade contour. In another case, a new station commenced operation, but did not have the expected signal around a specific area in its primary coverage area. As it turned out, there was an operating FM translator on a 3rd adjacent channel with sufficient power to cause signal drop out on receivers trying to pick up the full-service station in a radius around the translator site. Full-service stations are not required to protect translators or LPFM stations and they can go unnoticed until the new station begins operation or the FM translator or LPFM station begins authorized operation. Translators and LPFM stations, however, are required to protect full-service stations and must cease operation if interference occurs. As such, if your facility has been involved in a lengthy rule making, make sure no recently authorized LPFM stations or pre-existing translators have an impact on your relocated station.
A station owner in Virginia was recently fined $12,000 for failure to post tower registrations for five towers associated with its AM tower site and failure to maintain the required marking of the towers. In response, the station owner, who indicated the AM station was dark and that the Commission was aware of this, said the towers had been removed and, therefore, the problem was solved. The Commission noted that the towers were in existence when the inspection occurred in February 2002 and, as such, the station was in violation. Removing the towers did not change the violations. The station has now been transferred to a new owner.
Has your address, phone number, email, etc., changed in the past year? If so, please let us know so we can update our records. For your convenience, you can email us at kewanna@grahambrock.com.