Graham Brock, Inc.
Broadcast Technical Consultants
Vol. X, No. 11
November 2003
For the first time in three years, the FCC is opening a window allowing applicants to apply for new AM broadcast stations and submit applications for existing stations to make major changes. A new AM station must request daytime AND nighttime operation with a minimum power of 0.25 kilowatt both day and night. A major change for an AM station would be a change to its city of license and/or a frequency change greater than +/- 30 kHz from its present frequency. The window will open January 26, 2004, and close five days later on January 30, 2004. In preparation for this window, the Commission will not accept minor change applications by AM stations between January 12 - 30, 2004. The whole procedure is similar to the window three years ago when the Commission allowed new and major change applications for AM stations to be filed. AM applications filed in the window, while not needing to be detailed, must be complete and it is a complicated process. If you are interested, get started early.
Choosing not to act on a last minute request to extend the deadline, the Commission enacted new rules requiring frequency analysis and coordination of all proposed or changed stations before an application can be submitted to the Commission. Once a frequency has been selected, it has to be reviewed for interference to other existing stations in the same frequency band. Then, all potentially impacted stations within a 125 mile radius, or 250 miles in the direction of the antenna azimuth, must be notified by letter advising them of the proposed station. A 30 day response time is provided to the notified facilities to allow sufficient time for them to review the proposal and indicate whether they believe the proposal might cause interference to their stations. The Commission’s auxiliary database, which has been the subject of many newsletter items, is to be used to identify which stations/frequencies should be considered. If you are operating an STL or RPU on a different frequency than authorized, you will not be adequately protected in the new process. Because of the additional analysis and coordination, it is no longer a simple matter to file for an auxiliary service.
The FCC’s field bureaus have been active recently involving tower registration issues and RFR exposure problems. In North Carolina, a tower owner has been notified of a forfeiture of $120,500 for failing to register all of its towers and light the structures properly. This same non-broadcast owner has been fined thirteen times over the last three years for other compliance issues. In California, four FM stations have been accessed $10,000 each for excessive radio frequency radiation emissions near a local post office. FCC field agents took measurements and found the four stations to be exceeding the uncontrolled population levels by some 60%. The stations have since addressed the issue and have marked the area to ensure no persons traverse through the high RF areas.
The Commission has announced that over 1000 TV stations are now operating with digital service, representing 81% of the commercial TV stations in the country. Some of the remaining stations have requested their third extensions of time for the DTV build-out. Of these, seven stations failed to adequately demonstrate why they needed additional time. These stations have been admonished by the FCC and have been required to complete construction within six months or face potential action by the Commission.
Several months ago, we noted that license renewal has begun for radio stations around the country, staggered based on the states where the stations are licensed. In many cases, the radio frequency radiation rules have changed since the station’s last renewal. In some cases, this requires a more formal radio frequency radiation analysis than simply filling out the worksheets associated with the renewal applications. If your FM station is co-located with a TV station, the worksheet cannot be used. Multi-station sites also can prove to be difficult to certify using the worksheets. In some cases, even a formal computer analysis cannot certify compliance, thus requiring measurements. So don’t wait till the last minute to review your situation.