In September, the FCC sought comment on a bevy of proposed rule changes intended to revitalize the AM broadcast service. With comments due Jan. 21, 2014, and reply comments due Feb. 18, 2014, here are the major proposed rule changes.
Exclusive FM translator window for AM Stations: The NPRM proposes the opening of an exclusive filing window to provide the opportunity for AM licensees to file for a new FM translator to pair with an existing AM license. The FM translator would run with the AM station and could not be assigned separate from the AM station with which it is paired.
The FCC noted that the exclusive filing window raises questions whether it provides an unfair opportunity for AM licensees to the detriment of other broadcasters, and sought comment on the impact of the exclusive filing window on the future availability of spectrum for LPFM and FM translator windows. Finally, the FCC sought comment on whether the creation of a limited filing window would eliminate the need for “Matoon” waivers, conserving limited FCC staff resources.
Modification of Community of License Coverage Standards: Next, the NPRM sought comment on proposals to relax the community of license coverage requirements for daytime and nighttime facilities of an AM station. Currently, the daytime AM facilities must serve 80 percent of the community with at least a 5mV/m contour, and the nighttime facilities must serve 80 percent of the community with the higher of its 5mV/m contour, or its nighttime interference-free contour.
The FCC noted that many existing AM stations were licensed with facilities that may no longer serve their community of license due to changes in population and changes in community boundaries. On the other hand, the FCC is interested in maintaining viable service to communities, and new and community of license change applicants have the ability to design its facility with available tower sites, whereas minor change applicants do not have the same level of flexibility.
Thus, the FCC wants to reduce the daytime coverage requirements for existing licensees, so that, in the event of a minor change application is filed, it must only specify daytime coverage to 50 percent of the population or area of the community, but new and community of license change applicants must continue to show 80 percent coverage. It also proposed to eliminate the nighttime coverage requirements for existing AM licensees, and require only 50 percent coverage for new and community of license change applications.
Elimination of the AM Ratchet Rule: The last time the FCC attempted large-scale revision of its AM technical rules, it adopted a requirement that AM stations reduce its interference should it seek to make other modifications. While the rule was intended to reduce the overall interference in the AM band, the FCC noted that approximately 60 percent of existing AM stations were effectively frozen at their current site locations and patterns, else they be required to reduce their power.
Thus, the FCC proposed to eliminate the ratchet rule, but raised a number of questions to determine how this rule revision could be made. The FCC also sought comment on whether there were any aspects to the rule that should remain in place, and, if so, what specific modifications could be made.
Modification of AM Antenna Efficiency Standards: The FCC also sought comment on whether it should reduce the minimum effective field strength values to permit AM licensees to take advantage of shorter antennas. The FCC believes that the use of shorter antennas, in combination with the other proposed changes, would provide additional flexibility for existing AM stations to make modifications, especially those stations operating in the lower frequencies. As such, the FCC is proposing to reduce the minimum field strength values by 25 percent.
Interested parties can either file electronically through the ECFS website, or they may file on paper. In either case, the heading of the submission should reference MB Docket No. 13-249.
January: Stations in New Jersey and New York run License Renewal Pre-Filing Announcements on Jan. 16.
February: Stations in New Jersey and New York file License Renewal Application and EEO Program Report, and Noncommercial radio stations file Ownership Report (323-E) on Feb. 3. Commence running License Renewal Post-Filing Announcements, continuing on Feb. 16, March 1 and 16. Stations in Delaware and Pennsylvania commence running License Renewal Pre-Filing Announcements, continue running on Feb. 16, March 1 and 16.
Petro is of counsel at Drinker Biddle & Reath, LLP. Email: firstname.lastname@example.org.