Editor’s Note: Common Frequency is one of three LPFM advocacy groups that on May 16 filed informal objections with the FCC against 998 FM translator applications. CF’s technical director Todd Urick was a guest on episode #144 of our podcast to explain some of the reasoning behind this controversial action. He follows up with this guest editorial. -P.R.
When three LPFM advocacy groups recently filed 998 objections against pending translator applications, proponents on both sides had divided opinions. However, the petition was not intended to be a foray on individual translator applicants. It was a needed pause interjected into a spectrum mob-haul where hundreds of applications were fast-tracked to seal an uncertain fate for the FM band.
The Local Community Radio Act (LCRA) Section 5 is a Congressional mandate directing the FCC to assure LPFM and translator spectrum availability, “based upon the needs of the community.” Yet, in virtually every market, translator deployment has grossly surpassed LPFM coverage. For instance, in terms of coverage area, in Atlanta translators cover twenty times more area than LFPMs. In San Antonio it’s 16.3x, Raleigh-Durham is 24.1x and Scranton, PA is 39x.
What happened to balanced usage based upon community input? It is not difficult to assess what is happening here. Take for example 250-watt/1196 m HAAT translator K288GY. Repeating KUDD HD-2, it effectively creates a new station that has equivalent coverage to a full-powered Class C2 (50 kW) FM station for Salt Lake City, comparable to 65 LPFM stations. But there are repercussions from squeezing blood from a turnip.
Translator proposals are permitted to accept incoming interference. In the past this option was conservatively negotiated. But engineering best-practice has been disregarded with most new translator applications. It’s a race to direct the consultant engineer to grab any channel that works “on-paper.”
An example from Portland, OR includes a 2-watt directionally-proposed translator shoehorned in between two minimally-spaced co-channel LPFMs, amidst additional co-channel full power interference. Upon propagation modeling, the effective interference-free coverage reaches 64 persons, and the rest is an interference slurry of four stations. One San Francisco applicant proposes pointing a highly directional antenna into the Pacific Ocean at the expense of short-spacing multiple co-channel LPFMs.
A Camas, WA LPFM – surrounded on both sides by full-power stations and with no viable channels to move to – is also wedged in, between two translators that have equivalent coverages of Class A (6 kW) full power stations, in additional to co-channel interference. Two non-commercial educational (NCE) Christian network licensees profit from leasing these translators to commercial HD2-fed licensees to create two new commercial stations.
In Sacramento, a LPFM had to go silent shortly after start-up because it was inundated with copious (60dBu) incoming co-channel fill-in translator interference. Another Sacramento LPFM was rendered unviable via newly-introduced first adjacent HD radio interference.
There are many other LPFM operators that need to modify their sites but are locked to one utilizable spot due to new translator “short-spacing.” Many new translators have employed tight directional antennas to propose wrapping around LPFM primary (60 dBu) coverage areas, allowing the translator to commandeer 75% of the city coverage, relegating the LPFM to a sliver of coverage. Recourse for these LPFMs will get worse under the FCC’s proposed liberalized translator remediation rules.
LPFM services, with shrinking coverage, spend their savings on hiring lawyers and engineers simply to maintain their paltry coverage. Many LPFM operators are on the verge of just throwing-in the towel. They view the new massive footprints of adjacent 250-watt translators on huge mountains and towers and ask me why their LPFM is relegated to an inference-laden spectrum corner.
The industry’s solution has been just to move all AM stations to FM with full power… and FM translators… and LPFMs… and HD Radio. The master plan is: “Let’s see if it works, and fix the problems later. Just get me this translator license first.”
Years of industry counsel-led regulation concerning FM band capacity is poised to receive a bite-back from physics and the reality of spatial listener habits. Who is going to listen to two different AM stations on FM translators jammed onto one co-channel with a LPFM in one metro, while commuting? A third of the reception area will be dedicated co-channel interference and HD noise.
The industry hobbled LPFM with the Radio Broadcasting Preservation Act of 2000 (RBPA), and again lobbied against the service prior to the passage of the LCRA. The industry originally deep-sixed community ascertainment through the deregulation of radio, disabled localism via the elimination of the local content requirement, then decimated ownership caps via the Telecommunications Act of 1996, followed by the rescinding of the main studio requirement. This all served to minimize any public interest requirement so it could bolster profits, consolidate, then bankrupt themselves.
With LPFM advocates now drawing attention to the LCRA being neglected by the FCC, select industry advocates posit that these objectors are now not playing nicely. Wait, what? Who’s been the victim here?
Public interest advocates have a communications challenge within a system that is predicated on pay-to-play. Today’s growth of LPFM as brought on by the LCRA was the product of community radio spending hundreds of thousands of dollars to gain that to Congress, on order to reverse the technically-erroneous RBPA rules. How do listeners and community radio participate in the conversation without full-time lawyers, lobbyists, and money?
It is not going to happen by submitting novel proposals and writing thousands of letters to the FCC. LPFM subjugation and LCRA Section 5 abandonment has been so pervasive it is unclear how or where to pick up the conversation. Filed objections are an only recourse in a broadcast regime with a withered public interest component.
Translators were never meant to create new HD2-fed “full power station” equivalents playing MP3 playlists to pad corporate radio incomes at the expense of new local community radio. That privilege was bought from the FCC.
I sympathize with independently-owned AM broadcasters. But there should be some empathy concerning LPFMs facing a similar predicament AM broadcasters are trying to escape from. The central quandary is, how does the FCC assess the “the needs of the community” when it had exited the business of public interest arbitration years ago. Surveys? A point system?
FM stakeholders need to converge on discussion over managing resources fairly, anchored to engineering reality. But how does that happen within a system where the people who pay the most make the spectrum laws?
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