AM revitalization filing window opens this Friday
|EAS: The FCC is asking all broadcast stations to file ETRS Form One by August 27. REC is pushing for 100% LPFM participation. If you need help, please let us know. Filing services available for all three ETRS Forms. Retain REC now! 1-844-REC-LPFM. Participation is mandatory whether you do it yourself or we do it..|
Starting Friday, January 29 and running for six months until July 28, 2016, the FCC is opening an opportunity for AM stations to be able to obtain existing FM translators and be able to move them to their area. The parameters for this window are as follows:
- This is for existing FM translators only. No new translators. There will be an filing window for new FM translators for AM stations in 2017.
- The AM station being rebroadcast on the translator must be a Class C or D AM station. There will a similar opportunity for Class A and B AM stations for three months following the close of this opportunity window.
- A translator may be moved up to 250 miles and can specify any channel from 221 to 300 (92.1~107.9).
- The 60 dBu (1mV/m) protected contour of the proposed translator must be entirely within the 2 mV/m daytime contour of the AM station being rebroadcasted but in no case more than 25 miles away from the AM station.
- Since this is considered a "fill-in" service, ERP up to 250 watts is permitted at any height above average terrain.
- If the translator is not going to be owned by the AM licensee, there must be an acknowledgement of a rebroadcast agreement with the AM station and once constructed, the FM translator is obligated to rebroadcasting the AM station for a period of at least 4 years.
- AM stations are limited to being rebroadcasted over one translator changed in this window. If an AM station gains a translator in this window, they are prohibited from participating in the late 2016 window for 250-mile moves for any AM station class and they are prohibited from participating in the 2017 auction window for new FM translators.
- AM stations that have already obtained a translator in the past may still participate in this opportunity subject to the limit in the previous bullet point.
Advice for potential FM translator applicants
REC wishes to remind potential translator applicants and their engineering firms that under §74.1204(a)(4) of the FCC rules, the 60 dBu (1 mV/m) service contour of an LPFM station must be protected by translators by the 40 dBu (0.1 mV/m) interfering contour on co-channel and by the 54 dBu (0.5 mV/m) contour on the first-adjacent channels. FM translators are not required to protect the second or third adjacent channels of LPFM stations.
Advice for LPFM licensees/permittees
REC advises LPFM stations to be aware of potential FM translator applications that may operate near their location. Unlike LPFM, FM translators have much more flexibility to be able to place their stations close to LPFM stations while still protecting them. This is normally done through directional antennas that can be used to "null out" the signal towards the co-channel or first-adjacent channel LPFM.
See REC FAQ: Are translators required to protect LPFM stations?
Also, unlike in the translator rules, LPFM uses minimum distance separation to protect translators. The amount of distance required is based on the distance to the translator's protected contour based on power and height above average terrain divided into three tiers. Once a translator is moved close to an LPFM station, it could create a short spacing under the LPFM rules. This does not mean that you are interfering with the translator (remember, you were there first) but it will impact your ability to move the LPFM station in the future to any location that would be closer to the translator.
We do ask LPFM stations to not file informal objections unless there is positive evidence that the rules are being violated. LPFM stations should contact REC by e-mail or through Facebook prior to filing an objection for a second opinion. Even though some may not agree with the ability for AM stations to have translators, the fact is that we share the band with FM translators and they are equal in status to LPFM and we are receptive to assuring that translators are able to select a channel and location that would permit the most maximum service possible by both the translator and the existing LPFM. Please note that in this window, filing a petition to deny is never an appropriate step as those are done normally in the case of new stations or renewals.
Please note that REC is also assisting AM licensees and translator license holders in moving translators under this window of opportunity. Those wishing to move a translator can contact 1-844-732-5736 for assistance.
Note that many Class D AM stations are closer to their community that you think. Class D AM stations are more likely to be licensed to "mom and pop" and minority operated companies. These stations already suffer extremely limited coverage due to very limited night time service, lack of night time protections and the ongoing increase in unintentional radiators that further hinder their ability to provide daytime and nighttime service. Many Class C AM stations are also "mom and pop" and minority owned. The design of the Class C service limits their nighttime abilities, especially now compounded with modern electronic devices in the home. REC sees FM translators for Class D and C AM stations as a temporary measure with the permanent solution being the extension of the FM broadcast band to include 76~88 MHz, spectrum currently be used by TV channels 5 and 6.