PETITION FOR RULEMAKING TO STOP OVERPROTECTING STATIONS

[Casual_Observer]

Hey all -

Looking for comments on the link below:

http://www.rbr.com/radio/broadcaster-wants-to-stop-overprotecting-stations.html

The article outlines a petition for rulemaking that, if adopted, would end the current FCC practice of commercial broadcasters overprotecting other commercial FM facilities when there is absolutely no technical reason to do so. Noncommercial stations have been operating like this for decades, so the petition seeks to eliminate the "double standard" between the non-comm and commercial FM contour overlap models.

I filed the above-referenced request with the FCC last week and would like some feedback.

--- Casual Observer

 

[TexasTom]

I've thought this is something that should have been done long ago -- so I hope that it gets to the point where the FCC issues an NPRM and accepts comments towards making this change.

 

[w9wi]

Hey all -

Looking for comments on the link below:

http://www.rbr.com/radio/broadcaster-wants-to-stop-overprotecting-stations.html

The article outlines a petition for rulemaking that, if adopted, would end the current FCC practice of commercial broadcasters overprotecting other commercial FM facilities when there is absolutely no technical reason to do so. Noncommercial stations have been operating like this for decades, so the petition seeks to eliminate the "double standard" between the non-comm and commercial FM contour overlap models.

Hard to argue with -- obviously written by an engineer who knows what he's doing. (unlike most complaints of overprotection we see on this board!)

I'm not generally fond of proposals to relax FM protection requirements but it's hard to find a problem with this one.

Just don't mess with the DA rules please. That's a large part of what's ruining AM, and we sure don't want to see it hit FM!

 

[radioboy]

It appears to be a common-sense, reasonable request.

 

[Casual_Observer]

Hey all -

Thank you for the kind words of support for this petition. Hopefully, the Commission will at least give it some consideration. If anyone has any suggestions or wants to know more, then do not hesitate to call me at WYAB 103.9 FM - 601-879-0093.

--- Casual Observer

 

[wilson1000]

Rules were set forth for a reason. It's obvious that you have some agenda involved. I think there should be more protections. There's too many translators now, not to mention too many stations on the fm band. This just gives some engineering firm the need to shoehorn more stations on to the dial that no one is listening to. I hope the FCC laughs at this and denies.

 

[Ai4i]

Can't the guy just make a deal with the CO owner, throw him a few bucks in lieu of running to big bro, and the two will agree to accept mutual QRM which may never actually happen?
My big issue is with third (and even second) channel adjacency protection.
These are not the nineteen forties and radios do not drift all over the band as their tubes heat up, and need MHz-wide AFC's to stay tuned in.

 

[Tom Wells]

Did not have time to read the petition, but with such a suggestion comes a definite risk.

Are you hoping to reproduce the success of overfilling the AM band?

Or hoping to reproduce the sucess of the "italian" method?

Next you are going to ask for special translators for power device noise harmonics that gives them frequency deviation
and products between 88 and 108 mhz.

That said, there are probably some really useless signals in this person's area.
This sword has two edges and what seems to help you today will let another station give you an interference headace in the future.

Seems to me iboc on FM ought to be enough additional disruptive noise to satisfy anyone.

 

[w9wi]

Did not have time to read the petition, but with such a suggestion comes a definite risk.

Are you hoping to reproduce the success of overfilling the AM band?
...

The subject of this thread may be misleading, in that it closely resembles subjects posted by some people on this board with no engineering knowledge whatsoever.

This is not one of those.

Basically, what this petition seeks to do is to protect FM stations to their licensed facilities, not the maximum facilities for their class.

Consider, for example, WAEZ. (94.9 Greeneville, Tennessee) This is a Class C0 station; such stations are protected from interference on the assumption they're running 100kw to an antenna 450m high. Thing is, WAEZ's antenna is nowhere near 450m high. It's at 332m. This means WAEZ is protected from interference on the assumption their antenna is some 400 feet higher than it actually is -- there is an area around the tower where WAEZ's signal is protected from interference -- but where that signal is so weak that it cannot be received.

The petition calls for WAEZ to be protected within the area where the station's actual 332m signal delivers service.

The existing rules went into effect in a time when FM was getting off the ground. It was difficult to economically justify a full 100kw/600m facility -- but the FCC didn't want to see the operator who couldn't afford that 600m tower to be locked in permanently to a 8kw/120m interim operation. Today, as the petition says, anyone who wants to operate at class maximum facilities is already doing so.

In practice this petition will have little effect in the more heavily-populated areas within Class B territory. The vast majority of Class B and B1 stations are already operating at class maximum facilities; their protection parameters will not change if this goes into effect.

 

[Ai4i]

Interesting sidenote, WAEZ was on 94.9 when the call letters were on Miami Beach, also.

 

[TexasTom]

Rules were set forth for a reason. It's obvious that you have some agenda involved. I think there should be more protections. There's too many translators now, not to mention too many stations on the fm band. This just gives some engineering firm the need to shoehorn more stations on to the dial that no one is listening to. I hope the FCC laughs at this and denies.

The "reason" for the rules breaking FM stations into discrete classes was probably just to simplify the spacing requirements between FM stations and make it easier to allot FM channels without having to run complex calculations. Back in the eighties (when the current classes were put in place), that probably made sense.

Today, it wouldn't be that difficult to do these calculations based on the actual coverage contours of stations. While I don't think this rule change would make a huge difference in the number of alloted FM stations, it does seem like an idea whose time has come.

 

[TheBigA]

From what I can see, a lot of this probably goes back to docket 80-90, that allowed for the licensing of lots of new radio stations. Now that we're a generation or so removed from that ruling, it seems that some of those stations would like to move in or expand their power or coverage. In the non-com side, the purpose of relaxing those rules was to cram in more stations. If that's the purpose here, it comes at a bad time. Between LPFM, HD radio, translators wanting to operate as stations, not to mention all the pirates, there is already an assalt on the existing spectrum. With an FCC that seems hell-bent on killing OTA broadcasting (TV as well as radio), it seems to me there's no such thing as "overprotecting" ones' frequency.

 

[Casual_Observer]

Hey all -

I believe that one of the earlier posters noted that I have a hidden agenda behind submitting this PRM. My sole agenda is to help smaller single-station operators, such as myself, to serve their communities better. There is no technical reason why the PRM could not be accomodated, even if we may have philosophical differences. The PRM essentially proposes that the engineering practices enjoyed by noncommercial stations apply to the commercial band. The PRM does a concise job explaining everything:

http://fjallfoss.fcc.gov/ecfs/comment/view?id=6016836612

--- Casual Observer

 

[Bongwater]

Anybody who has any questions about overprotecting stations needs to come up to Skagit County in NW Washington State.

There was a time when it was an AWESOME place to listen to FM. Every second adjacent channel had a station and it was spread out fairly evenly across the spectrum from the Seattle, Vancouver, Victoria and Bellingham in almost every format imaginable. With very little - if ANY interference.

Now the FIRST adjacents are crowded with new stations, translators, relocated translators, more powerful signals from Canada, IBOC and the problem is just going to get worse. I'll even dare say it's more crowded than New England

I'm actually pondering even the NEED for translators today (for FM as well as AM stations - don't EVEN get me started on the Jesuscasters) when we have mobile apps and the internet.

Skagit County sits in a sort of FM no-man's land in regards to Seattle stations (their protected contours end pretty much at the county line and the Canadian stations aren't really protected at all unless they blast an unavoidable signal in the area. And even that's being eroded - CBU-FM 105.7 Vancouver now has a new neighbor here, the translator for KPLU Tacoma -on 105.5 - yes, that's right. Did I mention the interference from KCMS 105.3 from Seattle? The translator moved from 91.1 a few weeks ago to make way for a 1,100 watt religious station in Port Townsend, WA. Prior to that, the translator was moved down from 91.3 after a Victoria station moved from AM to FM. Now KPLU wants to set up a more powerful repeater station on 88.9, which is already occupied by a Victoria station powerful enough to cause mass interference on that frequency, no matter what's on it in the local area.

I think this is where KPLU should just give up and accept that there's just no more room on the FM band in the area and either buy an existing translator or let the internet take it from here.....

 

[Tom Wells]

Bongwater illustrates perfectly my concern. He cites an example of how much more useful the
FM was to listeners "in the good ol' days" in a certain area.

This is the "real" AM-ization of the FM dial.


The only reason FM is able to have so many stations on one frequency is that 100 mhz behaves much more like
optics than 1 mhz, and the handy "capture" effect.

That doesn't mean it is immune to the same degradation AM has suffered for the refusal to respect
technical standards or even pretend they exist any more. Yes, the FCC "tests" many things for
EMI/RFI interference, while permitting 40 years of cheap lamp dimmers.

The 2 most critical crippling blows to AM were the elimination of the clear and regional status with too many stations
rendering huge areas unserved by ANY signal, and 60 hz AC-chopping devices that are not Pt 15 compliant.

I believe that in not-too many years there will be enough noise and digital hash around to make people think
the same about FM as they now do about AM.


Those who want OTA to end are only too happy to help add more of everything that will help bury it with noise.
We just cut off about a quarter of our population from one, more, or all OTA television by adopting
a system with lots of "virtual" bandwidth due to compression schemes, but with a severe cliff effect.

It's not a particularly useful behavior for communications.
Most would rather have a slightly mangled message than none at all.

 

[TheBigA]

The PRM essentially proposes that the engineering practices enjoyed by noncommercial stations apply to the commercial band.

Why? I think if you'd talk with some of the engineering folks in non-commercial radio, they'd suggest those practices aren't a positive.

 

[Ai4i]

I think if you'd talk with some of the engineering folks in non-commercial radio, they'd suggest those practices aren't a positive.

Ones with an old station, a new one comes on, and the old one can never upgrade, but the new station would not complain.

 

[TheBigA]

I think what I'm saying is that broadcasters right now feel they're under seige. From all sides. This PRM isn't going to ease those feelings.

There are a lot of single station owners stuck with a low power AM right now, trying to serve their community. What do you say to them? You knew the rules when you bought the facility.

 

[DavidEduardo]

Hey all -

I believe that one of the earlier posters noted that I have a hidden agenda behind submitting this PRM. My sole agenda is to help smaller single-station operators, such as myself, to serve their communities better.

IIRC, your community is Flora, MS, not Jackson. Your current power level and height seems more than enough to cover a town of 1,600 people. Or is it that you really don't want to serve Flora and wish to serve Jackson? I'd think, if anything, Michael Savage and Dennis Miller would be even more appealing in the full metro than in Flora's sprawling metropolis.

 

[Casual_Observer]

Hey all -

David, I respect your opinions and am glad that you have entered the conversation on this topic, as I had hoped you would. There may be a better forum for a discussion related to WYAB's dedication to its community of license, however. Perhaps you could visit me at WYAB's office in Flora one day, for instance.

I believe that this conversation has veered off into many tangents and there is quite a bit of conjecture going around at the moment. At the heart of the PRM: the FCC Notice in 1987 clearly stated that applicants need to protect the contours of other facilities based on the presumption that any sub-maximum class station would need the opportunity to build out full facilities in the future. The future, from 1987's perspective, has arrived. The PRM says that any operator intent on building out full facilities would have done so by now, hence, the argument that applicants are over-protecting those sub-maximum class facilities for no technical reason.

--- Casual Observer