The Next Phase of AM Revitalization

FCC announced its third set of AM modernization rules revisions in September October 13, 2017

The Federal Communications Commission announced its third set of AM modernization rules revisions in September, this time focusing on reducing the obligations associated with conducting proofs of performance measurements and updating the requirements for Method of Moment proof of performance studies. The commission tabled the still-unresolved issues relating to the reduction of daytime and nighttime interference protections, skywave interference rules and legacy expanded-band AM licensees.

The commission revised its AM service rules in 2015 and 2017 as part of its effort to reinvigorate the AM service. To that end, the commission’s 2015 First Report and Order modified the community coverage standards, eliminated the AM Ratchet Rule and established the rules to guide future FM translator filing windows for AM stations. Subsequently, the commission modified its rules in February 2017 to relax the siting restrictions for new FM Translators to be used to rebroadcast AM stations.

TECHNICAL RULE UPDATES

The new rules adopted in September 2017 address several technical rules. First, the commission eliminated the requirement that partial proof of performance studies must include measurements on radials that do not contain a monitoring point specified on the station’s license authorization. The FCC agreed with commenters who argued that taking measurements on only the radials with monitoring points will demonstrate that the station is operating within licensed parameters.

Next, the commission made several changes to the requirements associated with Method of Moments proof of performance studies. The commission noted that it had received over 220 MoM studies since 2008, and the computer modeling approach to verifying a station’s compliance with its licensed directional antenna pattern was successful. As a result, the commission eliminated its rule requiring biennial recertification of MoM studies and, instead, will only require recertification if system components have been repaired or replaced.

Additionally, the commission eliminated the requirement that stations submit new reference field strength measurements when submitting new license applications with MoM proof of performance studies. Instead, the commission determined that the requirement for field strength measurements taken to confirm an initially licensed MoM-proofed directional pattern is sufficient.

The commission also eliminated the requirement that a MoM-proofed station obtain a new surveyor’s certificate each time it is relicensed, except in those cases where the towers’ geometry has been altered or additional towers have been added to the array. The commission also clarified that its rules establishing the criteria for when new MoM proofs must be prepared and submitted also apply when adding antennas to AM towers, and eliminated the requirement of submitting current distribution measurements for top-loaded antennas as a condition of obtaining a license authorization.

On the other hand, the commission declined to permit stations with “skirt-fed” AM towers to use MoM modeling. The commission determined that AM towers that do not utilize simple, series-fed towers raise different concerns than those currently authorized to use MoM modeling, and there remain concerns that the standards for using MoM modeling software with skirt-fed towers have yet to be fully tested and verified.

As noted above, the commission did not address the pending, and much more controversial, proposals regarding changes to the interference protection requirements. Given Chairman Pai’s strong interest in the AM modernization movement, one can expect that these issues will be addressed in a subsequent order.

FCC DEADLINES:

Oct. 10 – Issues/Programs List must be placed in stations’ public inspection file.

Nov. 13 – EAS Participants must file ETRS Form Three regarding the National EAS Test held on Sept. 27.

Nov. 13 – Rules requiring On-Air Disclosures for Third-Party Fundraising commences.

Dec. 1 – Stations with five or more full-time employees in Alabama, Colorado, Connecticut, Georgia, Maine, Massachusetts, Minnesota, Montana, New Hampshire, North Dakota, Rhode Island, South Dakota, and Vermont place Annual EEO Public File Report in public inspection file.

Dec. 1 – Stations with 11 or more full-time employees in Connecticut, Maine, Massachusetts, New Hampshire, Rhode Island, and Vermont file Broadcast Mid-Term Report (FCC Form 397) with FCC and place in public inspection file.

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