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The author is membership program director of the National Federation of Community Broadcasters. NFCB commentaries are featured regularly at www.radioworld.com.

Commercial and noncommercial stations alike recently celebrated National Radio Day. Where we in radio sometimes get sectioned off into our own little silos — community radio, commercial radio, sports radio, college radio, religious broadcasting and music stations, among them — National Radio Day is our annual day to unite, and to tell a great story.

This year, National Radio Day was Tuesday, Aug. 20. The annual recognition is not really a holiday in the Labor Day or Fourth of July tradition. Rather, National Radio Day is among those days that gives us all a chance to pause and appreciate the art form of radio and its impact on our communities.

[Read: Community Broadcaster: Joining Forces]

Just as people played the funeral dirge for broadcast television when VHS came along, so have naysayers been predicting radio’s passing for decades. Nevertheless, radio still enjoys massive listenership, and trust from audiences. Radio today sees tremendous reach, with some 200 million Americans listening anytime any given week. Its penetration into U.S homes is why it is the go-to for emergency preparedness and a host of other services. As the Federal Emergency Management Administration tweeted, “Radios are a great resource during disasters. When cell towers and internet are down, radios will continue to receive emergency alerts and weather alerts.”

Beyond the urgent moments, National Radio Day is a yearly chance to highlight our medium’s other value propositions. For instance, there are the journalistic, musical and cultural services that radio provides. For some, radio is the first place where they discovered any number of musical genres or heard music in another language. For other Americans, radio informs them on their commutes about the matters of the day. For still other people, radio provides a little bit of home, no matter where that home may be anywhere around the planet. These explorations provide our intellects and imaginations fertile grounds upon which to grow ideas and engagement. Because the voices we hear allow us to conjure up our own visuals, radio taps into a mental space no other medium can.

Radio has been a launchpad for many famous names. A few of them took a moment to appreciate the influence of the medium, in cities and towns everywhere as well as in their own lives. Sportscaster and media personality Joy Taylor tweeted, “Radio was my first love in media, I always wanted to host a radio show, ‘theater of the mind.’” Television host Janice Dean added, “I started out in radio, and so … I look back fondly on the place where my broadcasting career began. I never thought I would end up in television, but I wouldn’t be where I am today without the experience I had behind just a microphone.” British radio host Sean Goldsmith called radio “a wonderful medium that’s given me 27 years of doing something I never thought I’d actually do. I used to sit there in a factory in Leicester putting stickers on beer trays listening to the radio wanting to be [U.K. radio legend] Simon Mayo.”

Radio has also been a message-based medium, giving people with ideas a place to share them with many people. Franklin Graham tweeted, “My father, Billy Graham, used radio as a way to share the Gospel w/millions worldwide.”

If your station did not take advantage of National Radio Day this year to talk up all your station brings to your city or town, check out the National Radio Day hashtag across social media for ideas to use next year. Or, better yet, make National Radio Day every day and testify to your local voices and community service right now.

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The post Community Broadcaster: Turning It Up appeared first on Radio World.

An FCC order that took effect in August provides for non-adjacent channel changes for FM translators that are experiencing interference issues caused or received.

Charles M. Anderson

This will be very helpful in smaller markets to resolve interference complaints and where excessive incoming interference seriously limits coverage. Unfortunately, there are no available frequencies in most medium and large markets.

On the other hand, the final rules provide protection from translator interference to existing facilities out to their 45 dBµ contour, an increase beyond their defined maximum class protected contours from 17.6 miles to 35.2 miles for a Class A, 40.4 miles to 53.6 miles for a Class B and 57.1 to 83.5 miles for a Class C.

When combined with the procedures whereby complaints may not be challenged, as few as six determined complainants at the edge of those contours (and only three for an LPFM) can cripple or kill a translator — a powerful weapon in the hands of overzealous stations seeking to protect the “owner’s contour” or eliminate competition.

BIG RADIO SPOKE UP

In its original Notice of Proposed Rulemaking, the commission presented a very well reasoned and balanced proposal to limit interference complaints to the 54 dBµ contour, which appeared to recognize the changed role of FM translators in the modern broadcast radio landscape, where some 8,000 FM translators are operating or authorized, many serving to sustain local service of AM stations.

The commission stated in that proposal that its goal was to “provide translator licensees [with] additional investment clarity.” The commission asserted that it was (emphasis added):

[c]larifying the process and balancing the interests of the various services involved … we must not only balance the needs of translator, low-power FM and full-service licensees, but also [the technical integrity of the FM band]. We believe that the measures adopted herein strike a balance between managing FM band spectrum, providing greater certainty for translator operators, and preserving existing protections for full-service stations … .

However, like the cattle barons of the Old West defending grazing rights to the open range and opposing homesteads, Big Radio once again came forward in full turf protection mode, opposing the commission’s proposal (just as they have opposed and stalled the FCC’s very reasonable and rational proposed modification of AM daytime allocations, which were supported by some of the industry’s most respected engineers).

“Big Radio once again came forward in full turf protection mode,” the author writes, “opposing the commission’s proposal.”

They advocated an incredible 39 dBµ contour limit, citing interference concerns for audiences well beyond their protected contours with purported radio listening data. It is noteworthy that their audience data was based on “cume” (five minutes listening per week) and ZIP code centroids for “panelists home addresses” (see Beasley Media Corp., et al, comments at footnote 13).

Such data is at best exaggerated and misleading given the size of ZIP code areas, many extending across a 6 dB contour span, and the presumption that the home address represented the location of a significant portion of their listening. Since these data are from the larger PPM markets, it seems reasonable to expect that much of the five-minute “cume” listening is spent in transit to those markets at contours far greater than 45 dBµ.

The commission relied heavily on this data, and in doing so failed to achieve its stated goal of balancing the interests of translator audiences.

GAMING THE SYSTEM

To actually effectuate the balancing that the NPRM proclaimed was taking place between the interests of FM translator listeners and other station listeners, it would have been necessary for the commission to do a comprehensive engineering study of all authorized FM translators determining the impact of limiting their interference contours (25 dBµ co-channel and 39 dBµ first-adjacent channel) to the new 45 dBµ protected contours for FM stations.

That data could have informed a fair and balanced evaluation of the alternatives weighing the relative impacts on translators and FM stations, something the current FCC decision failed to do.

I studied the potential impact of the new rules on the Louisville, Ky., market. The 45 dBµ limit would put into jeopardy the continued, viable service from nine of the 10 currently authorized Louisville market FM translator stations.

If interference complaints were pursued under the FCC’s strict, no-recourse procedures, six would be ordered to discontinue operations. Three would be forced to power levels ranging from 5 to 21 watts ERP. Only one would not be in jeopardy from a full-service station interference complaint (see my ex parte comments in docket 18-119). I have since evaluated a number of small- and medium-market translators with similar results.

Under the combined effects of the extreme 45 dBµ contour limit and the new non-recourse complaint procedures, some full-service stations will “game” the system to obtain complaints that once established are not subject to challenge.

Now, a full-service station or existing translator or LPFM wishing to eliminate an FM translator for any reason will be able to work backwards by first identifying the area in which there will be, as an engineering matter, predicted interference. Then the full-service station simply identifies listeners who, at least twice a month, drive or travel through that predicted interference area, and obtains from such listeners the required signed form.

If, after signing the form the listeners are instructed to say nothing more and accept no interference remediation, then under the FCC’s new strict procedures, the only interference remediation possible where alternate frequencies are not available is a substantial facility impairment or cessation in operations for the besieged FM translator.

Allocated service areas have been clearly differentiated in the longstanding processes developing the FM allocations system. The dramatic extension of those service areas out to 45 dBµ is clearly inconsistent with the dictates of §307(b) of the Communications Act, which requires that the FCC “provide a fair, efficient and equitable distribution of radio service” to each of the states and communities. It could be argued that translators also represent an efficient use of the spectrum for communities using the unallocated, open grazing areas of the FM band.

The 45 dBµ contour is neither fair nor balanced. After all, authorized LPFMs only have to protect stations’ 70 dBµ or in some cases the 60 dBµ contour, and are effectively immune from interference complaints. LPFMs may defend their 45 dBµ contour from translator interference but are themselves de jure exempt from the reverse.

The 45 dBµ limit is also at odds with the Local Community Radio Act, which requires equal treatment of translators and LPFMs. Since translators are clearly not intended to be “secondary” to LPFMs, it does not seem defensible to extend 45 dBµ protection to them or currently operating translators for that matter.

It all comes down to what is best overall for today’s radio listeners. The FCC only considered a discrete, small number of radio listeners well outside the allocated coverage contours of existing stations in its decision. It wholly ignored FM translator radio listeners. Perhaps there was a compromise contour that was fair and balanced; 45 dBµ is neither, nor supportable as such as the commission lacked the data with which to make a reasoned decision. As shown with the Louisville example above, the new interference rules have the potential for dramatic and unintended consequences.

Charles M. “Chuck” Anderson is a broadcast engineering consultant with more than 35 years experience. He owns FM stations and FM translators.

Comment on this or any story. Email radioworld@futurenet.com with “Letter to the Editor” in the subject field.

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This document announces that the Federal Communications Commission granted a motion filed by the Multicultural Media, Telecom and internet Council (MMTC) in MB Docket No. 19-177 to extend the deadlines for filing comments and replies in response to the Commission's document on possible improvements to equal employment opportunity (EEO) compliance and enforcement.

At the request of Xana HD Solutions, LLC., the Audio Division amends the FM Table of Allotments, by allotting Channel 283A at Kahlotus, Washington, as the first local service. A staff engineering analysis indicates that Channel 283A can be allotted to Kahlotus, Washington, consistent with the minimum distance separation requirements of the Commission's rules with a site restriction of 6.2 kilometers (3.88 miles) southeast of Kahlotus. The reference coordinates are 46-38-00 NL 118-38-10 WL. Channel 283A at Kahlotus, Washington is located within 320 kilometers (199 miles) of the U.S.- Canadian border. Canadian concurrence has been received.

In this document, the Commission seeks further comment on the creation of a framework under which a broadcaster could satisfy its children's programming obligations by relying in part on special efforts to produce or support Core Programming aired on another station or stations in the market. The Children's Television Act (CTA) permits the Commission to consider special sponsorship efforts, in addition to consideration of a licensee's programming, in evaluating whether a licensee has served the educational and informational needs of children. The Commission invites commenters to submit proposals detailing a specific framework under which special sponsorship efforts may be considered as part of a broadcaster's license renewal.

In this document, the Commission updates the children's television programming rules to reflect the changes to the media landscape since these rules were first adopted in the 1990s following passage of the Children's Television Act of 1990 (CTA). The revised rules will give broadcasters greater flexibility in serving the educational and informational needs of children, allow broadcasters to offer more diverse and innovative educational programming, and relieve unnecessary burdens on broadcasters, while also ensuring that high quality educational programming remains available to all children.

In this document, the Federal Communications Commission (Commission) announces that the Office of Management and Budget (OMB) has approved, for a period of three years, information collection requirements adopted in FCC 19-21. This document is consistent with the Report and Order, which stated that the Commission would publish a document in the Federal Register announcing the compliance date.

In this document, the Federal Communications Commission (FCC or Commission) proposes to require that cable operators use email to deliver certain written notices to broadcast television stations. The proposal would require cable operators to email the notices to a designated inbox in the station's online public inspection file (OPIF). The FCC seeks comment on whether satellite TV providers should similarly be required to use email to deliver certain written notices to broadcast TV stations. In addition, the FCC also seeks comment on whether and how the proposal to require electronic delivery of notices can be applied to certain low power TV and noncommercial translator stations that are not required to maintain an OPIF.

In this document, the Federal Communications Commission (Commission) announces that the Office of Management and Budget (OMB) has approved, for a period of three years, information collection requirements adopted in the Commission's Amendment of Part 74 of the Commission's Rules Regarding FM Translator Interference, MB Dkt. No. 18-119, FCC 19-40, (FM Translator Interference Report and Order). This document is consistent with the FM Translator Interference Report and Order, which stated that the Commission would publish a document in the Federal Register announcing OMB approval and the effective date of the rules.

This document summarizes the procedures, terms and conditions, together with the upfront payment amounts and minimum opening bid amounts, for an upcoming auction of construction permits for low power television station (LPTV) and TV translator stations. The Public Notice summarized here also provides an overview of the post-auction application and payment processes governing Auction 104.

Petitions for Reconsideration (Petitions) have been filed in the Commission's proceeding by Louis P. Vito, on behalf of V-Tech Communications, Inc.; by Brad Johnson, on behalf of KGIG-LP; by Michael W. Richards, on behalf of LPFM Coalition; by David J. Doherty, on behalf of Skywaves Communications LLC; and by Charles M. Anderson, on behalf of Charles M. Anderson.

This Proposed Rule seeks comment on how the Commission can make improvements to equal employment opportunity (EEO) compliance and enforcement and responds to issues raised in comments filed in a recent proceeding to eliminate the obligation to file the Broadcast Mid-term Report (FCC Form 397). In that proceeding, the Commission committed to seek comment on these issues.

In the Report and Order, the Federal Communications Commission (Commission) takes steps to improve the accuracy and reliability of fixed white space device data recorded in the white space databases and assure that the potential for these devices to cause interference to protected services is minimized. In the Order on Reconsideration, the Commission modifies the white space device antenna height rules to allow improved broadband coverage in rural areas, and resolves certain outstanding white space reconsideration issues. White space devices are used to provide a variety of wireless services, including broadband data.

At the request of Nexstar Broadcasting, Inc. (Nexstar), licensee of television station WNLO(TV) channel 32, Buffalo, New York (WNLO), and WUTV Licensee, LLC (WUTV Licensee), the licensee of television station WUTV(TV), channel 36, Buffalo, New York, the Commission has before it a notice of proposed rulemaking proposing the substitution of channels for DTV station WNLO (currently channel 32) and WUTV (currently channel 36). WUTV would continue to operate from its existing pre-auction location and WNLO would move the Nexstar shared facilities in the site previously vacated by WIVB-TV (Buffalo, New York (CBS) (WIVB), the station with which it is sharing. The channel substitution serves the public interest because it would allow for a more efficient allocation of UHF television channels and resolve significant over-the-air reception problems in WIVB's prior service area.