LPFMs operating translators

[RF101]

Michi wrote a useful FAQ on LPFMs operating FM translators. It's titled "FAQ: How can I get a translator for an LPFM station?"

The FAQ states "The protected contour of the FM translator must overlap the protected contour of the LPFM station."

So the question involves that keyword "overlap". With commercial FMs the fill-in translator must have a contour that are "contained within" the protected contour of the primary station. So, did the Commission throw a nice bone to the LPFM community? "Overlap" is a much lower criterion.
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What caused this question is that KXCJ-LP in little Cave Junction, Oregon , is acquiring the translator K267AD for $10,000. This will given the LPFM more coverage along US-199 towards Selma and Grants Pass. Sounds good. (The translator was carrying KURY-FM Brookings.)

 

[DaveBayArea]

I've often wondered why LPFM's can't have the same rules as translators regarding ERP and HAAT. Translators can be as high as they want to above average terrain but don't have to decrease power below 10 watts if they meet interference criteria. Not so with LPFM's. This allows a translator in a rural area with no interference to actually serve a fairly large geographical area. The situation described here is ideal for KXCJ-LP, but most LPFM's aren't so lucky.

WRT the "overlap" vs "contained within" observation, it's not really throwing a bone. If KXCJ were a full-power NCE station they could actually have a translator licensed as far away as Grants Pass as long as they could pick up the primary station off-air. This would be true even if the translator was totally outside the protected contour of the primary.

Dave B.

 

[radiorobert]

I’ve often thought this as well. Allowing LPFMs to have up to 250 watts and go as high as they can per interference rules would address a lot of issues and requests in the LPFM world and it would also be neat to have a standalone class of station in addition to all that to be able to be licensed. Maybe at 500 watts or something?

 

[RF101]

The FCC just approved KXCJ-LP being relayed on a nearby translator.

https://fccdata.org/?facid=76887

 

[The Beat]

Legal ID for WRTH-LP/W299BO: https://syndicated.audio/KOOL FM WRTH - LEGAL ID.wav

 

[Michi]

So the question involves that keyword "overlap". With commercial FMs the fill-in translator must have a contour that are "contained within" the protected contour of the primary station. So, did the Commission throw a nice bone to the LPFM community? "Overlap" is a much lower criterion.

Actually, when you take the translator rules into consideration, the overlap requirement for LPFM commonly-owned translators is actually very restrictive.

It is important to remember that in the noncommercial educational rules, the service contour of the FM translator may be outside the service contour of the primary station (which is different than commercial) and that the translator must be able to "hear" the source station over the air (not through internet/microwave, etc.). (There are provisions that permit full-power NCE stations in the 88~92 reserved band to use those methods to feed commonly-owned translators as long as the translator is also in the reserved band.)

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What caused this question is that KXCJ-LP in little Cave Junction, Oregon , is acquiring the translator K267AD for $10,000. This will given the LPFM more coverage along US-199 towards Selma and Grants Pass. Sounds good. (The translator was carrying KURY-FM Brookings.)

This is a very smart move on their part. It pretty much gives them a "LP-3000" station (0.01 kW @ 562m HAAT = 13.222 km 60 dBu service contour, 3 kW @ 30m HAAT is ironically the same value).

 

[Michi]

I've often wondered why LPFM's can't have the same rules as translators regarding ERP and HAAT.

1. Local Community Radio Act of 2010 requires the use of distance separation protections towards full-service stations. (LCRA §3(b)(1)).
2. The FCC wants to keep LPFM to remain "non-complex". (Report and Order in MB Docket 19-193 (2020).

The big problem with using the translator rules for LPFM would be the Maximum HAAT (MHAAT) provisions of §74.1235(b). Currently, LPFM station's HAAT is based on the average of 8 radials. Under MHAAT, which is used for non-fill in translators, for a nondirectional antenna, the HAAT is based on the highest of 12 radials which could reduce the ERP of many LPFM stations that just happen to have one of the 12 radials (every 30 degrees) with a HAAT higher than 30 meters in that direction.

I asked for conventional contour protections between LPFMs and FM Translators (since translators are not considered "full-service" stations for the purposes of the LCRA). FCC said no.. too complex for LPFMers. (R&O MB Dkt. 19-193)

If KXCJ were a full-power NCE station they could actually have a translator licensed as far away as Grants Pass as long as they could pick up the primary station off-air. This would be true even if the translator was totally outside the protected contour of the primary.

The other option is for the translator to not be licensed to the LPFM organization but instead to a friendly third-party who wants to bring that station into their local community. That way, the overlap and 10/20 mile requirements do not apply. Yes, you do not have to be an LPFM licensee in order to have a translator rebroadcasting an LPFM.

 

[Michi]

I’ve often thought this as well. Allowing LPFMs to have up to 250 watts and go as high as they can per interference rules would address a lot of issues and requests in the LPFM world and it would also be neat to have a standalone class of station in addition to all that to be able to be licensed. Maybe at 500 watts or something?

This would not be practical as long as we are tied into the LCRA (which requires Congress, not the FCC to do something about). For now, all LPFM supporters should get behind RM-11910, a simplified plan to be able to upgrade many LPFM stations to a 250 watt class of service.