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Graham Brock, Inc. |
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Broadcast Technical Consultants |
| Vol. XVI, No. 9 |
R. Stuart Graham, Jr. |
| September 2009 |
Jefferson G. Brock |
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AM on FM Translator Rules |
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Several months ago, the Federal
Communications Commission adopted a Rule Making allowing
the re-transmission of AM stations on FM translators.
The effective date of the rule change was to take place
thirty days after the publication of the Order in the
Federal Register. The Order was published, and the
effective date should be October 1, 2009. We have,
however, heard from at least one attorney that this date
may be misleading. As part of the rule change, FCC Form
349, the application for a new or modified FM
translator, must also be updated to include the AM
station particulars. The government’s Office of
Management and Budget must approve the new form after it
is revised, which may not occur by the effective date.
Therefore, formal filings may have to await the
completion of the updated form. For those who simply
want to change the re-transmitted station to an AM
facility, the submission of FCC Form 349 is not required
as the change can be made in a letter. The letter must
include the data regarding the AM station to be
re-transmitted, including a statement that the
translator would meet the criteria regarding keeping the
60 dBu contour of the translator within the 2.0 mV/m
contour (daytime) of the AM station, or within 25 miles,
whichever is less. We recommend including a map to
visually demonstrate compliance with this requirement.
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AM Interference Reduction Requirement May Change |
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In 1991, the FCC required AM stations making
voluntary changes to reduce their interference to
other stations if they contributed interference
above the 50% RSS levels to another station. In some
cases, this has required stations wishing to make
changes to significantly reduce the power of the
proposed facility. A possible change to provide for
improved coverage may not be possible if the station
is old enough to be considered a major contributor
to another station’s interference levels under the
1991 rules. Any possible gain or additional service
created may be lost. Two engineering firms have
taken up the torch and asked the Commission to
change the so called “Ratchet Rule”. The FCC has
issued a Public Notice seeking comments for and
against the request to eliminate the “Ratchet Rule”.
Comments are due by October 9th. The proceeding has
been designated Rule Making #11560. |
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Just a little more than five months after April
15th, it is time to pay the government again.
Annual regulatory fees for broadcasters are due
September 22nd. The fees must be paid for full
service stations, secondary stations such as FM
translators, LPTV stations, etc., and auxiliary
stations such as STL’s, RPU’s, etc. The
regulatory fees for TV stations are based on
market size. The regulatory fees for radio
stations are based on a station’s classification
and the population within the protected contour
of the station. Outstanding construction permits
also have to pay regulatory fees. The lowest
fees are for STL’s and other auxiliary services
which are just $10 per license. |
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Just Days Away... |
Stu and Jeff will be
attending the National Association of Broadcasters
Radio Show in Philadelphia, Pennsylvania September
23 - September 25. If you or someone with your
organization will be in Philadelphia, please let
them know so a meeting can be arranged.
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If
you have a suggestion for a topic for an
upcoming newsletter, just send us a note
or email. To receive the newsletter via
email please send an email to
cathy@grahambrock.com. |
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