Translators for LPFM can be helpful but at the same time, they can also be restrictive, especially if the LPFM is commonly owned by the LPFM station.
For LPFM, we will talk about two different translator types, commonly owned and not-commonly owned.
The Commonly-owned translator is actually licensed to the same organization that is licensed to operate the LPFM station. For Commonly-owned translators, the FCC has established several restrictions that only apply to LPFM commonly-owned translator stations:
- An LPFM station is limited to owning only two commonly-owned translators.
- The commonly-owned translator must be located within 20 miles of the LPFM station's transmitter location or the reference coordinates for the city of license (The latter part is exclusive to LPFM translators). This distance is 10 miles when the LPFM station is in one of the Neilsen Audio top-50 media markets.
- The commonly-owned translator must receive the LPFM station directly over the air. You can not use microwave or the internet to feed the translator. This also means that a commonly-owned translator can not be used to feed another commonly-owned translator ("daisy chaining").
- If the LPFM station is operating HD Radio, then the translator must rebroadcast the main HD1 program stream. You can not use a commonly-owned translator to introduce a second audio program by analog using a translator.
- There must be some overlap of the 60 dBu service contour of the LPFM station with the 60 dBu contour of the commonly-owned translator. (REC has filed a Petition for Rulemaking to remove this restriction.)
Not-commonly owned translators
The not-commonly owned translator is one that is licensed to anyone other than the LPFM licensee or any of the board members of the LPFM's organization. In this case, translators can be owned to individuals (as long as they are not on the board of the LPFM organization), non-profit organizations, for-profit organizations and even individuals and corporations that have other broadcast holdings. The differences between the commonly-owned and not-commonly owned translator are as follows:
- There is no limit to the number of not-commonly owned translators a single entity can hold.
- There is no mileage restriction to where a not-commonly owned translator is placed in respect to the LPFM station.
- A not-commonly owned translator must still receive the LPFM station over the air and not though alternate means such as microwave or the internet however the not-commonly owned translator can receive a signal from another translator to daisy-chain the signal, even if the other translator is commonly-owned.
- While this practice is not supported by REC, it is legal for a not-commonly owned translator to rebroadcast the HD2 stream of an LPFM station operating in a digital hybrid mode.
- There is no requirement that there must be an overlap between the LPFM station and a not-commonly owned translator.
There are some unique differences between the LPFM rules and the rules for LPFM translators:
|Low Power FM||FM Translators|
|73.805 - LPFM stations can operate on any of the 100 channels (88.1 through 107.9)||74.1202 - Translators rebroadcasting a non-commercial educational station (including LPFM) can operate on any of the 100 channels however it may be likely that the filing window will only be for the non-reserved band (92.1 through 107.9).|
|73.807 - LPFM stations are spaced using a strict distance spacing chart based on a maximum hypothetical facility for each station class. LP-100 stations must protect co-channel, first-adjacent and second-adjacent channels.||74.1204 - FM translators use a prohibited overlap model to protect other stations. For all stations except LPFM, they must protect co-channel, first-adjacent, second-adjacent and third-adjcent channels. Translators operating at least 100 watts ERP must also protect intermediate frequencies (+/- 10.6 and 10.8 MHz). Translators are only required to protect the co-channel and first-adjacent channel of LPFM stations.|
|73.807 - LPFM stations that are second adjacent channel short spaced can make a showing that based on the field strength of the short spaced station along with the lack of population around the transmitter site and/or the lack of downward radiation by the proposed antenna that there will be no interference to potential listeners of the second-adjacent channel station.||FM translators that are second or third adjacent channel short spaced can make a showing that based on the field strength of the short spaced station along with the lack of population around the transmitter site and/or the lack of downward radiation by the proposed antenna that there will be no interference to potential listeners of the second or third-adjacent channel station.|
|73.807 - LPFM stations must also third-adjacent channel protection to FM stations carrying radio reading services.||While there is no specific radio reading service provision in the translator rules like there is with LPFM. Translators are already required to protect third-adjacent channel stations and are subject to an objection if there is a suspicion that the operation of the station would create interference to a subcarrier service. Translators can also be subject to closure in the event of actual interference to a full-service station.|
|73.807 - LPFM stations must protect foreign FM stations by a distance separation chart for co-, first-, second- and third-adjacent channels as well as IF.||74.1235 - FM translators have specific rules for protection towards foreign stations which include contour overlap and restrictions on contour sizes.|
|73.809 - LPFM interference happens when a subsequent full-service filing results in interference happening in the city grade contour, the community of license, any area of the community of license where the LPFM station is predicted to receive a 60 dBu signal as well as any actual interference caused by IF overlap (91 dBu).||74.1203 - FM translators may not continue to operate if they cause actual interference to the transmission of any authorized FM broadcast station.|
|73.810 - LPFM has a specific process for addressing third-adjacent channel interference in accordance with the LCRA.||74.1203 - FM translators may not continue to operate if they cause actual interference to the transmission of any authorized FM broadcast station.|
|73.810 - LPFM stations are required to make announcements for the closest third-adjacent channel station(s) that is/are past the formerly required distance but within 100 km.||No such rule exists for FM translators.|
|73.811 - LPFM stations are limited to 100 watts at 30 meters HAAT or its equivilient at 5.6 km. Minimum facilities are 50 watts at 30 meters HAAT or 4.7 km.||74.1235 - FM translators can operate at a maximum of 250 watts at 32 meters HAAT (7.3 km service contour). In areas west of the Mississippi River except in the state of California south of 40 degrees latitude, FM translators can operate at a maximum of 250 watts at 107 meters HAAT (13.3 km service contour). Power reductions can be made in order to achieve lack of contour overlap.|
|73.813 - Height above average terrain (HAAT) is calculated using 8 equally spaced radials at 45 degrees.||74.1235 - HAAT for translators is calculated using 12 equally spaced radials at 30 degrees.|
|73.816 - LPFM stations are mainly required to operate non-directional antennas. Exceptions to use directional antennas are made for certain public safety operations and for accommodating a second-adjacent channel waiver.||74.1235 - Directional antennas may be utilized and in many cases will be necessary in order to protect all other stations.|
|73.825 - LPFM stations operating in the reserved band are required to protect TV channel 6 stations using a distance separation chart.||74.1205 - FM translators in the reserved band first use a distance separation chart to determine if a study is necessary. If a study is required, the translator can use a contour overlap model shown in 74.1205 of the rules to show lack of interference.|
|73.827 - LPFM stations can not interfere with the input signals of an already operating FM translator.||74.1203 - FM translators can not interfere with the reception of the input signal of a FM translator, FM booster, TV translator or booster.|
|73.840 - The transmitter power output (TPO) must be within 90% and 105% of the authorized TPO. (TPO is the power from the transmitter before going through the feedline and the antenna.)||74.1235 - A translator can not exceed 105% of its authorized TPO.|
|73.845 - If an LPFM station is operating out of compliance, it must be shut down within 3 hours.||While there is no specific rule for translators, it is an expectation that once non-compliant operation is determined, the station should be brought into compliance or shut down.|
|73.850 - LPFM stations have a minimum operating schedule.||74.1234 - The translator must be equipped with suitable automatic circuits that will place it in a non-radiating condition in the absence of a signal on the input channel.|
|73.853 - LPFM stations are licensed only to non-commercial educational institutions, associations and tribal entities. In addition, government and non-goverment organizations with a public safety purpose may hold an LPFM authorization.||There is no specific rule for holding a FM translator license. Translators should not be held by individuals with an attributable interest in the LPFM station (it should be licensed to the LPFM organization and subject to the commonly-owned rules listed above).|
|73.854 - LPFM stations can not be held by any party who engaged in unauthorized operations.||While translators do not have a specific rule, the overall FCC character qualification criteria may be used to determine whether an individual or a corporation is qualified to be or remain a Commission licensee.|
|73.855 - LPFM stations are limited to one per entity. Tribal entities may own two. Public safety entities may own a unlimited number of stations within their operating jurisdiction.||There are no specific ownership limits on translators other than for organizations that hold an LPFM authorization are limited to two translators per station operating under the "commonly-owned" limitations we discuss on this page.|
|73.858 - LPFM stations can not be owned by those who have attributable interests in other broadcast entities and that there is no attributable interest from a larger organization that may have broadcast holdings.||There are no restrictions for translators other than the rules around translator/LPFM cross-ownership.|
|73.860 - LPFM stations (or any party on the board) can not hold an ownership stake in any other broadcast station or other media regulated by the FCC (including daily newspapers). LPFM stations may own up to two translators per station.||There are no restrictions for translators other than the rules around translator/LPFM cross-ownership.|
|73.865 - LPFM stations can not be assigned to any other entity until licensed for three years. LPFM stations can not be sold for a profit. Unbuilt construction permits can not be transferred.||FM translators can be assigned or transferred to any party (given the LPFM ownership restrictions) at any time, hey can be sold for any amount and there is no restriction on the transfer of unbuilt construction permits.|
|73.870 - LPFM stations can be moved up to 5.6 km from their currently authorized location as a minor move.||74.1233 - FM translators can be moved to any location as a minor move as long as there is some overlap between the 60 dBu service contours of the current location and the proposed location.|
|73.870 - LPFM stations may change to any adjacent channel (+/- 1, 2 or 3) or to an IF channel (+/- 53 or 54) or upon technical showing of reduced interference, to any channel.||74.1233 - Translators may change to any adjacent channel (+/- 1, 2 or 3) or to an IF channel (+/- 53 or 54) or upon technical showing of reduced interference (displacement), to any channel. Unbuilt translators changing from the reserved to non-reserved band (or vice versa) are considered major.|
|73.872 - LPFM stations that are mutually exclusive during the filing window will go thorugh a process that assigns points for various factors. Time sharing is an option to resolve and if no resultion can be made, the most qualified applicants may be subject to involuntary time sharing.||In MX situations, commercial translators that can otherwise not settle or come up with alternative spectrum will be subject to auction. Non-commercial applicants that are MX with commercial applicants will automatically be trumped by commercial applicants as non-commercial applicants can't participate in auctions. In situations where a MX group is all non-commercial applicants, a comparative review process will be used. There is no time-sharing in the FM translator service.|
|73.873 - LPFM licenses are for 8 years and expire at the same time for all licenses in a particular state.||Translators follow the same renewal cycle as LPFM.|
|73.879 - LPFM stations may not retransmit, either terrestrially or via satellite, the signal of a full-power radio broadcast station.||FM translators may rebroadcast a primary AM or FM radio station received over the air or via another translator (except for commonly-owned translators). FM translators can not use alternate means such as microwave or the internet to receive the primary station with the following exception: If the primary station is commonly owned by the translator licensee and the translator operates in the reserved band (88.1-91.9). There are rules that specifically require LPFM commonly-owned translators to receive the input signal over the air.|
|LPFM stations can originate non-commercial programming with underwriter acknowledgements in accordance with Section 399b of the Communications Act.||FM translators operating as a fill in for an AM station that operates daytime only can originate programming during the times when the AM station is off the air. Otherwise, messages originated on translators are limited to emergency messages (imminent danger) and messages acknowledging financial support of the operation of the translator. Such support messages are limited to "installation, operation and maintenance" of the translator. In other words, no "for-profit" advertising.|
|73.1201 - LPFM follows the commercial and non-commercial rules for station identification. Identification is done once per hour as close to the top of the hour as possible and must include the station's call sign (with the -LP suffix) and the city of license. A station may also insert their channel number, frequency, licensee name or network affilliation between the call letters and the city of license. Additional cities may be added after the city of license.||
74.1283 - Translators must be identified in one of the following ways:
Obtaining a translator
At this time, the only way to obtain a translator is through acquiring one from an existing licensee. When looking at purchasing a translator, there are a few things that you need to take into consideration:
- Is the translator authorized at a site that you will be able to use? If not, the translator will have to be moved.
- If the translator is moved, is there a site that it can be moved to where the 60 dBu service contours of the existing translator and the new site have any kind of overlap? Also, will the translator meet all co-channel, first, second and third-adjacent channel spacing as well as IF protection at the new location?
- Wherever I put the translator, will it be able to receive the primary station over the air? Remember you can't use microwave links or the internet.
- For a translator that will be commonly-owned by the LPFM station, is there going to be an overlap of the 60 dBu service contours of the LPFM station and the translator?
- If the translator is currently operating as a "fill-in" for a full power FM or AM station (including translators that are rebroadcasting the HD2 stream of the full-powerstation), that translator may operate up to 250 watts at any height. If the translator is now going to rebroadcast an LPFM station, it is no longer eligible for that loophole. Instead, the field strength of the station is limited to 250 watts at 32m HAAT (7.3km) east of the Mississippi and in most of California and 250 watts at 107m HAAT (13.3 km) elsewhere in the west.
For assistance on filing the applications for acquiring and moving a translator, please contact REC at 1-844-REC-LPFM.