Posts Categorised: FM translator
He says 48 dBµ would be a more appropriate value than 54 dBµ
WASHINGTON — In comments to the FCC, Crawford Broadcasting Director of Engineering W. Cris Alexander argued that the broadcaster “has interests on both sides of the FM translator interference issue” — meaning that the company and its affiliates currently are licensees of 15 AM and nine FM commercial stations plus nine FM translators. This, Crawford says, means they have a “unique perspective on the issue and perhaps a more balanced view.”
In light of that, Alexander submitted comments on behalf of Crawford regarding the proposed amendment of Part 74 of the Commission’s Rules Regarding FM Translator Interference (MB Docket No. 18-119). He expressed support for the commission’s reform efforts and offered additional suggestions. (Cris Alexander also is a contributor to Radio World, which was not involved in the filing.)
First, Alexander, writes: “We believe that the provisions of §74.1203(a) and §74.1204(f) should be harmonized so that predicted interference to existing listeners outside the translator 60 dBµ contour can be addressed prior to grant of the translator application. What constitutes ‘interference’ is well defined in the FCC’s rules by means of codified protection ratios, and we believe these ratios should be applied to predicted interference cases prior to grant of a legitimately-objected translator application.”
He notes that this is advantageous because it would help to prevent “drawn-out and often expensive interference complaint prosecution” by eliminating cases in which “a proposed translator will ‘pass the test’ provided by §74.1204(f) because there is no predicted interference to existing full-power station listeners within the translator 60 dBµ contour, but after operation commences, existing listeners located outside the translator 60 dBµ contour begin receiving interference.”
Additionally, this is important, Alexander says, because ofen “the damage is done in fairly short order after the translator signs on — those existing listeners displaced by the translator interference often tune elsewhere and may not ever return.”
Alexander also supports “the proposed modification of Section 74.1233(a)(1) of the Rules to define an FM translator’s change to any available channel as a minor change as a means of mitigating legitimate interference to an existing full-power broadcast station.” This is consistent with the idea that it’s important to offer “fast and complete resolution of interference issues.”
He also concurs that six is a good minimum number of listener complaints to be used to claim translator interference, saying that a “station bringing this many complaints undoubtedly has a real interference issue.”
Regarding the complaints themselves, Alexander agrees that listener complaints should include sufficient information “for the translator licensee to follow up… determine the listener’s exact location, and make measurements and tests at that location.” He notes that this would also ensure that the complainant is not affiliated with the full-power station.
In fact, Alexander writes that it would be bettter to remove the middleman — the complaining listener — from the process as soon as possible because complaining listeners “ may be uncooperative,” hard to contact or could even be bribed to withdraw their complaint.
Instead, he suggests, the resolution should be determined through “a technical showing that all interference has been eliminated.” Specifically, he writes, “any showing by the translator licensee should include a U/D study based upon the F(50, 50) and F(50, 10) field strength charts contained in Section 73.333, unless the use of the Longley-Rice propagation model is indicated based upon established criteria.”
Also, Alexander argues “there should be a full-power station field strength value beyond which no complaint of actual or predicted interference will be considered actionable.” However, he says that they do not “believe that 54 dBµ is the appropriate value for this cutoff field strength.” Rather, Crawford says, “a better compromise would be 48 dBµ, which represents an electric field strength value of 250 µV/m. We believe this value to be appropriate for all classes of FM stations and do not recommend that a different value be adopted for class B or B1 stations.”
He explains that a recent listener survey indicated that “92% of the respondents regularly listen in areas beyond the 54 dBµ contour and with predicted field strengths well below that value;” and he said the same is likely the case for class B1 stations which are protected to 57 dBµ, “it is likely that there are listeners to even lower field strength signals than to those with a 60 dBµ protected contour.” He cited also cited a 1975 study and report that indicated there was “some argument for a value of 47 dBu” field strength as a cutoff for interference complaints.
Read his comments online here. Comments on MB Docket No. 18-119 are due July 6 and reply comments are due Aug. 6.
More translators means more interference complaints. Here’s how the commission plans to address the issue
WASHINGTON — As most of you know, translators on the FM band are authorized on a secondary basis and have no protection against subsequently authorized full-service FM facilities.
Overall, the number of licensed FM translators has grown from approximately 1,850 in 1990 to approximately 7,575 in 2017, according to the FCC, and there are more than 700 new translator construction permits authorized and 1100 applications for new translator construction permits pending.
“The growth in the number of translator stations has led to an increasing number of interference disputes between translator stations and full-service stations. However, resolving these fact-intensive disputes can currently be quite time-consuming,” according to the commission, and on April 19, it published an NPRM that seeks to “streamline the resolution of such interference complaints, strike an appropriate balance between the interests of translator stations and other licensees, and conserve licensee resources.”
The Notice of Proposed Rulemaking – MB Docket No. 18-119 , would do the following:
- Propose to allow FM translators the flexibility, upon a showing of interference to or from any other broadcast station, to change channels to any available same-band channel using a minor modification application.
- Propose to improve the commission’s FM translator interference complaint and resolution process by requiring a minimum number of listener complaints to be included with any interference claim, clarifying the required content of each listener complaint, and streamlining and expediting interference resolution procedures by reducing listener involvement in favor of a clear, quick, and technically-based process.
- Propose to align the criteria used to assess actual and predicted interference from translator stations.
- Seek comment on a contour limit containing most of the listeners for the affected station beyond which listener complaints would not be actionable.
One of the FCC’s proposals in the NPRM is that it will require at least six complaints from listeners unaffiliated with any complaining station (e.g. not employees, owners, or contractors of the complaining station or their family members) before such as complaint will be considered valid.
“The idea is to make sure that there is a real widespread interference issue — so that a unique listener with some unusual affinity for a distant station can’t block the service from a new translator,” writes David Oxenford in broadcastlawblog.com .
The FCC tentatively finds that a listener will need to state that they have listened to the complaining station at least twice in the month before the complaint to be considered a regular listener. The FCC also tentatively finds that stations can reach out to its listeners to see if they are getting complaints from new translators; it does not need to “sit back and wait for complaints to roll in.”
“The FCC also is ready to propose that, instead of interference being determined subjectively by the ears of a listener, interference would be measured by objective criteria. Interference that occurs outside a station’s 54 dbu contour would not be protected at all,” according to Oxenford.
Other complaints would be resolved through the application of formulas that the FCC already uses to determine interference based on the ratio between desired and undesired signal levels, and potentially, with “on/off” tests of the translator, to see if complainants can distinguish that condition.
If you find yourself involved in an interference fight, you should definitely read the NPRM and comment, or instruct your communications attorney to do so. See the NPRM here .
Next steps in Auction 99 process
WASHINGTON — A window will open in March for filing new FM translator construction permit applications. But this particular window is for a select 165 “singleton” applications — those not mutually exclusive to other applicants — that are part of the FCC’s Auction 99.
The auction, as previously reported, is a “closed” process, with bidding in May to resolve 12 groups of pending MX applications for “cross-service” FM translator CPs. It is part of the broader AM revitalization initiative.
But the singleton list, being processed separately, has applicants from over the country, including 25 from North Carolina, 15 from Virginia, nine from Texas, and one each from Oregon, Oklahoma and Vermont, among others. Large corporate entities like Cumulus Licensing are on the list, as are educational organizations like South Carolina State University.
The first step is for these applicants to file a long-form Form 349 application through the commission’s online electronic filing system. Once there, applicants will find a few hoops to jump through, such as tagging a specific long-form box and entering a previously issued CDBS file number.
The window will run March 14 to March 28. During that time, staff will study the submitted long-form applications and subsequently issue a public notice in CDBS for those applications that have been accepted.