Graham Brock, Inc.
Broadcast Technical Consultants
Vol. X, No. 3
March 2003
Following the announcement last month of the first translator window to be opened in nearly six years, commercial and non-commercial stations have been searching for options for their respective stations. The translator window was limited to only the commercial portion of the FM band (92.1 MHz to 107.9 MHz). However, the filing of applications for non-commercial translators was not precluded. In the non-commercial or reserved portion of the band, non-commercial stations are free to deliver programing to the translators off the air, microwave, satellite or other means, whether the translators are fill-in or not. In the commercial band, non fill-in translators must pick up the stations they are proposing to translate off the air or through an intermediate translator. Microwave or satellite feeds are prohibited, except for fill-in translators, totally encompassed by the primary station’s protected service contour. We have heard from various sources that hundreds of applications were in preparation to be filed during the window that was scheduled to close on Monday, March 17th. The Commission extended the window since the CDBS filing system was off-line for a portion of the weekend prior to the scheduled opening, thus preventing early preparation and uploading of the applications. It may be a week or two before the number of filings will be known.
The FCC has noted in several tower registration publications that towers less than 200 feet generally do not require registration. As such, many tower owners with short towers for high band AM stations or with towers located on substantial hills have not concerned themselves with tower registration. However, in the last several months, we have come across many towers less than 200 feet tall that did not comply with the FCC registration rules. The FCC generally performs a “slope test,” considering the height of a tower, height above ground and height above mean sea level, in comparison to nearby airports. They also factor in the elevation of the airport runways. Even if the tower is less than 200 feet, based on its height above mean sea level, the FCC may still require the owner to register the tower. Registration requires an FAA Determination, thus the filing of an application with the FAA for clearance analysis. In many cases, older towers were previously reviewed and found not to be a hazard to air navigation, but without a copy of that determination, you cannot register the structure. The FAA generally does not
keep a copy of determinations for more than a year or two once the tower has been built or abandoned. A quick check of your tower can be made to determine if registration is needed. Also, please remember to compare the tower registration data against your station license to make sure the data matches. If not, an application to correct the coordinates may need to be submitted to the FCC to update your license.
As we reported some time ago, the FCC was proposing a reallocation of a portion of the 2 gHz band, generally between 1990 MHz and 2025 MHz, for other than broadcast auxiliary uses. Last month, the Commission released two separate Report and Orders in which several changes were ordered. First, the FCC took 15 MHz of space that had been reserved for mobile satellite services and re-allotted it for the use of advance wireless services. This apparently was based on the required spectrum for the satellite services. However, three entities will now share this band. Some relocation of broadcasters’ auxiliary stations will still need to be undertaken and will be addressed in an upcoming proceeding.
On some recent inspections of AM stations, several did not have a copy of their last NRSC measurements available for review. The FCC still requires AM stations to take annual (at periods not longer than 14 months) NRSC emission measurements to show that the AM station is not exceeding their limits. These measurements generally take about 30 minutes to perform for each mode of operation. In some cases, the measurements show compliance issues, usually for second or third harmonics of the transmitter that require component repair or replacement, and then a re-measurement. Are your measurements current?
For those of you who will be making the annual trek to Las Vegas, Stu and Jeff will also be attending the convention. If you would like to schedule some time to talk about an upcoming project or just to say hello, please let them know. The spring convention is a good time to get together for engineering issues, and Stu and Jeff look forward to hearing from you.