[grc] Fwd: Release: Prometheus Petitions FCC to Protect LPFMs from Big-AM-Station Translators

Sat Jan 20 09:03:15 PST 2018

This specific type of issue has come up with staff in the past.

The general consensus is that the FCC would allow a silent station to 
apply for a translator however the final grant will not take place until 
the AM station has resumed operations.

In this case, WONA-AM (now WBTL) was involved in a sale from Delmarva to 
Mobile Radio Partners and under Mobile, they have filed a modification 
to move the AM to a new single-tower site with 1kW day and 8 watts at 
night.  (All stations on 1540 are very limited on nighttime power due to 
being on a Bahamas clear channel).  This station is currently on an STA 
to run reduced power of 700 watts day on a single tower at the current 
site.

This brings us to the protections of the translator towards the LPFM 
station.  In the case of a first-adjacent channel, a translator's 54 dBu 
interfering contour can not overlap the LPFM's 60 dBu contour. In this 
case, the proposal meets that requirement.

At this time, it is too late to file a Petition to Deny.  It is not too 
late to file an informal objection.  If you can identify listeners 
within the 60 dBu contour* of the proposed translator and those 
listeners can give you a signed statement that they listen to your 
station from inside that area, you can make a showing that the proposed 
translator will interfere with their ability to listen. Your listeners 
need to be aware that their information will go on the public record and 
that they may be contacted by the applicant to resolve the issue.

If this gets granted, you may have another chance to address the 
interference if/when they build this and file their form 350.

For now, I would suggest checking on the AM station's status but going 
to a location much closer to the AM station.  The AM station may be on 
the air but you are not hearing it because of the massively reduced 
power due to the STA.   If the station is silent but not reported, then 
you may have grounds on that leg but for now, the only true recourse you 
may have is to (quickly) get statements from listeners in the 60 dBu 
contour who claim their reception of the LPFM may be impacted.

Michelle Bradley
Founder
REC Networks
1-844-REC-LPFM

=m

On 1/20/2018 8:54 AM, Max via grc wrote:
> I see that we have a translator applicant that is on our immediate adjacent
> Channel!
>
> My station, WRWK-LP 93.9 now faces a translator application THE NEXT
> adjacent over at 94.1!
>
> EVEN STRANGER, THE A.M. RADIO STATION APPLYING FOR IT IS SILENT!
>
> WONA AM is off the air and listed as "silent" ... So ... What signal is
> that tanslator going to "translate"?
>
> What do y'all think we can do?
>
> Sincerely, Max
>
>
> On Apr 18, 2017 3:55 AM, "Frieda Werden via grc" <grc at maillist.peak.org>
> wrote:
>
> ---------- Forwarded message ---------
> From: Prometheus Radio Project <info at prometheusradio.org>
> Date: Mon, Apr 17, 2017 at 4:44 PM
> Subject: Release: Prometheus Petitions FCC to Protect LPFMs from
> Big-AM-Station Translators
> To: Women's International News Gathering Service <wings at wings.org>
>
>
> [image: Prometheus Radio Project]
>
> Prometheus Radio Project
> P.O. Box 42158
> Philadelphia, PA 19101
> 215.727.9620
>
> *For Immediate Release*
> April 17, 2017
>
> PHILADELPHIA-- The Prometheus Radio Project is challenging an FCC handout
> to the biggest AM stations because it will harm low-power FM (LPFM)
> stations without affording them protections guaranteed under the Local
> Community Radio Act (LCRA). Last week, Prometheus filed a petition with the
> FCC seeking reconsideration of new rules released in January that allow the
> largest commercial AM stations to place more FM translators near LPFM
> stations.
>
> The January FCC ruling, a part of their AM Revitalization effort, allows AM
> stations to locate translators -- small radio stations which repeat the AM
> station on the FM band -- within either 25 miles of their station, or
> within their daily broadcast area (2 mV/m contour), whichever is larger.
> Formerly, AM stations were limited to staying within the smaller of those
> areas, a restriction that smaller AM stations contested. Prometheus did not
> file opposition to that part of the FCC ruling.
>
> Initially, the FCC proposed that translators must keep their broadcast to
> within 40 miles of the AM station, which was consistent with helping
> smaller AM stations. However, the January ruling removed this 40-mile
> limit, allowing the largest commercial AM stations to place FM translators
> far away from their core service area. At least 1,644 large AM stations
> stand to benefit from removal of the limit, subjecting most of the land
> area of the US to extra demand for translators, which compete with LPFMs
> for space on the FM dial and can box them in.
>
> Radio stations in general, and LPFMs more than most, need to periodically
> relocate for financial and practical reasons, and are allowed to move
> within 3.5 miles of their location, or within a circle 7 miles in diameter.
> FCC rules allow a translator to move closer to an LPFM than an LPFM can
> move toward the translator, and prevent the LPFM from thereafter moving any
> closer to the translator. It is as if the translator draws a line in the
> sand which the LPFM cannot cross. When an LPFM is located between two
> nearby translators in different directions, or “short spaced,” the LPFM is
> boxed in between two lines it cannot cross, which can remove the vast
> majority of its relocation area. As a result, LPFMs may be forced to move
> away from their audiences when they inevitably relocate, or may be unable
> to move and lose their transmission site.
>
> Section 5(3) of the Local Community Radio Act (LCRA) says that LPFM
> stations and FM translators are to "remain equal in status” and the
> Commission enacted rules to protect this equality prior to the 2013 LPFM
> application period. The “boxing-in” problem is one of several LCRA equality
> issues that the FCC must address especially with increasing demand for, and
> possible increased supply of FM translators.
> Figure - 1: Land Area Affected by FCC 40-Mile Limit Removal
>
> The pink and red areas below show where one or more translators could be
> placed by AM stations, due to the FCC's recent removal of the 40-mile limit
> described above. Each pink/red area is the daytime (2mV/m) contour of an AM
> station minus the portion less than 40 miles from the respective AM
> station. Darker pink/red indicates more AM stations could place translators
> there.
>
> A live map
> <http://forms.prometheusradio.org/sites/all/modules/civicrm/
> extern/url.php?u=10809&qid=1016180>
> is also available, but beware it is a very large map and may cause trouble
> in some browsers.
> Figure - 2: How an LPFM gets “Boxed In”
>
> LPFM radio station KBLT-LP below is shown with the push pin, and the two
> red-shaded areas are where it is now prohibited from moving because of the
> two recent translators for AM stations named in the figure. The clear
> circle is where KBLT-LP could normally relocate.
> References
>
>     - (PDF) Prometheus Petition to FCC
>     <http:///sites/default/files/17-04-10-Prometheus-Petition-
> for-Reconsideration-of-AMR-Order-AS-FILED.pdf>
>     - FCCs AM Revitalizion page
>     <http://forms.prometheusradio.org/sites/all/modules/civicrm/
> extern/url.php?u=10810&qid=1016180>
>     - The Local Community Radio Act
>     <http://forms.prometheusradio.org/sites/all/modules/civicrm/
> extern/url.php?u=10811&qid=1016180>
>     - FCC general information about translators
>     <http://forms.prometheusradio.org/sites/all/modules/civicrm/
> extern/url.php?u=10812&qid=1016180>
>     - FCC Low-Power FM (LPFM) page
>     <http://forms.prometheusradio.org/sites/all/modules/civicrm/
> extern/url.php?u=10813&qid=1016180>
>     - A History of Encroachment upon LPFMs
>     <http://forms.prometheusradio.org/sites/all/modules/civicrm/
> extern/url.php?u=10814&qid=1016180>
>
> Press Contact
>
> Please email info (at) prometheusradio.org
>
>
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> PO Box 42158
> Philadelphia, PA 19101
> United States
> --
> Frieda Werden, Series Producer
> WINGS: Women's International News Gathering Service www.wings.org
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