[grc] FCC releases preliminary decision on AM revitalization

[Michelle Bradley]

http://recnet.com/node/2147

In an unprecedented move which appears to now be new policy, FCC 
Chairman Ajit Pai released the circulation version of 
the<http://transition.fcc.gov/Daily_Releases/Daily_Business/2017/db0202/DOC-343304A1.pdf>/Second 
Report and Order 
<http://transition.fcc.gov/Daily_Releases/Daily_Business/2017/db0202/DOC-343304A1.pdf> 
/on the Revitalization of the AM Radio Service.  Under the circulated 
document which will be under consideration at the FCC's February open 
meeting, the Commission would amend §74.1201(g) of the rules to extend 
the area of which a translator that is rebroadcasting an AM station is 
located.

Under the current rules, the proposed 60 dBu protected contour of the 
translator must remain within the 2 millivolt per meter (2 mV/m) daytime 
contour of the AM station and in no case shall extend further than 25 
miles from the AM transmitter location.

The FCC proposed to change the rule to state that the 60 dBu contour can 
be located within 25 miles of the AM station and for stations with 2 
mV/m contours extending past 25 miles, out to the 2 mV/m contour but in 
no case past 40 miles.

REC supported a maximum limit of 25 miles except in situations where the 
AM station's community of license is more than 25 miles away, if the 
area is not served by a local FM broadcast station or the station was 
within the state of Alaska.  Other broadcasters supported the 
elimination of the proposed 40 mile outer limit.

In the circulation version of the order, the Commission is proposed to 
amend the rules to allow the 60 dBu contour to extend to any part of the 
AM station's 2 mV/m contour without the 40 mile outer limit.  In 
addition, there will be a minimum reach of 25 miles from the AM station 
allowed.  The latter rule will greatly benefit most Class-C and some 
Class-D AM stations which have very small 2 mV/m contours.  Rural AM 
stations would not necessarily be required to invest in more expensive 
directional antennas for the sole purpose of keeping the translator 
signal within the 2 mV/m contour.

REC does support issues that positively impact rural Class C and D AM 
stations as most of these stations are owned by "mom and pop" or 
minority entities and in some cases are still an entry level into 
broadcasting.  These stations are much more likely to focus on their 
local community than urban Class A and B stations owned by major 
corporations.

LPFM stations concerned about future applications being filed by AM 
stations can consult various REC resources includingFCCdata.org 
<http://fccdata.org/>which will show an AM station's 2 mV/m contour and 
our system that allows you to seeAM stations with FM stations 
<http://recnet.com/am-with-translators>in your local area.  It is 
important to remember that AM stations that participated in the 2016 
major move (250 mile) opportunity will not be able to participate in the 
2017 filing windows.  There will be two windows planned. The first will 
be for Class C and D AM stations and the second for all other AM 
stations that did not participate in the first (C & D) window and did 
not take a 250-mile opportunity in 2016.  It is also important to 
remember that this window is open only to AM licensees and that any 
translator granted in this window must remain associated with that AM 
station on a permanent basis.  The translator will not be able to be 
split off.  AM stations that are eligible to participate in the 2017 
window may only apply for one station during this window series.

LPFM stations should also be advised that even though the Commission has 
not announced the dates of the windows yet, when they do, there may be 
the possibility of an application freeze where modification applications 
could not be filed so translator proponents can prepare their 
applications for the window. If there is no application freeze, it may 
be possible that LPFM modifications filed after the announcement of the 
window may not receive cut-off protections.  Once we have some more 
insight on how this window will be handled, we will let you know.

The preliminary release of this Report and Order is a part of apilot 
program established by Chairman Pai 
<http://transition.fcc.gov/Daily_Releases/Daily_Business/2017/db0202/DOC-343303A1.pdf>to 
make the agency more transparent by allowing the public to view what the 
Commission will be voting on before the Commission reaches a decision. 
  While REC will be disagreeing with some items that Chairman Pai will 
be supporting in the months to come, we do support the Chairman's 
decision to open up proposed decisions prior to vote.

Until the document is voted on, it is not a final action therefore a 
Petition for Reconsideration can not be filed until after the final 
action  For more information on filing Petitions for Reconsideration, 
see§1.429 <https://www.law.cornell.edu/cfr/text/47/1.429>of the FCC rules.

Please note that even though the Commission may release these documents 
prior to the open meeting, presentations made after the Commission's 
agenda is released (the so-called "Sunshine Period") may be restricted 
under§1.1203 <https://www.law.cornell.edu/cfr/text/47/1.1203>of the FCC 
rules.