Revitalized AM Translators

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RodeoJack
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Revitalized AM Translators

Post by RodeoJack » Sun Jan 14, 2018 10:09 pm

Those of you who haven't yet built an "AM on FM" translator that was acquired under the "AM Revitalization Act" might find the following interesting.

Having repurposed a few of these, pre-revitalization, I've run into some creative ideas from broadcast owners, revolving around what they can play, whether they can separate the programming between AM & FM, raising power to qualify with AM contours, then repurposing the translator to support an FM... etc.

It seems clear the FCC has been watching. Below is some text from a "revitalized" construction permit that I was handed to build last week. Pretty much all of the shenanigans I've run into appear to be addressed:

---------------------------------------------------------------------

Special operating conditions or restrictions:

Pursuant to Revitalization of the AM Radio Service, Notice of Proposed
Rule Making, 28 FCC Rcd 15221, 15227, para. 14 (2013), and First Report
and Order, 30 FCC Rcd 12145, 12154, para. 17 and n. 43 (2015), the
permittee and any successor in interest (licensee, transferee, or
assignee) shall be subject to the following restrictions:

(1) this facility may only, in perpetuity, be used to rebroadcast the authorized
facilities of the AM primary station set forth in this construction
permit, except that it may also originate nighttime programming if the
AM primary station set forth in this construction permit is not
authorized regular nighttime service, and then only during periods of
the broadcast day when the primary AM station is not regularly
authorized to operate;

(2) if the AM primary station is operating withreduced facilities, this cross-service FM translator facility may only
operate if its coverage contour conforms to the limits set forth in 47
CFR Section 74.1201(g) as applied to the reduced facilities of the AM
primary station;

(3) the authorization for this facility may not be
assigned or transferred except in conjunction with the primary AM
station set forth in this construction permit; and

(4) if the authorization of the AM primary station set forth in this construction
permit is rescinded, revoked, surrendered, subject to special temporary
authorization (STA) to remain silent, or is otherwise suspended from
operation, the authorization of this cross-service FM translator
station shall likewise be rescinded, revoked, surrendered, silent for
the duration of the AM primary station’s STA to remain silent, or
suspended from operation. Minor modifications of this authorization
are permitted, provided that the translator meets all of the preceding
conditions.

TPT
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Re: Revitalized AM Translators

Post by TPT » Mon Jan 15, 2018 7:12 am

Something does not jibe here. Look at 47 CFR 1201 (g). A translator may be licensed anywhere within the greater of either the daytime 2 mv/m contour or a 25 mile radius of the AM transmitter site--providing that the translator's 60 dbu doesn't extend beyond either the contour or 25 mile circle.

So, if the AM is operating at reduced power due to an STA--and the translator is outside of the (reduced power) 2 mv/m contour--but inside of 25 miles--this would indicate the translator has to be turned off?

I just received a CP that has this provision. The translator is partially inside and partially outside the M-3 2 mv/m contour of the AM station but inside the 25 mile circle. Now consider two different situations:

A. The AM station suffers storm damage and must operate at 250 watts (licensed power is 1 kw)--translator must sign off?
B. The AM station licensee obtains a new license at 250 watts, but since the translator is inside the 25 mile circle therefore it can still operate?

Someone at the Commission is thinking too much.

(Even more interesting--the station in my example is not mine--but I put it on 25 years ago. Was measured in as the M3 indicated overlap with a first adjacent. Measurements toward the the present proposed site of the translator, however, indicates the 2 mv/m extends about 4 miles beyond the M-3 predictions.)

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Re: Revitalized AM Translators

Post by TPT » Mon Jan 15, 2018 7:29 am

Ah, hill country thinking.... I am used to our poor conductivity. Though the wording is confusing and subject to two different interpretations.

Section 1201(g) would allow an FM translator for an AM to be built 50 miles away from the AM transmitter site...IF this translator site was within the 2 mv/m daytime contour of the station. So, if your station was located in an area with high conductivity, this might apply. Example: WSPD's daytime 2m/m contour extends 32 miles to Port Clinton, Ohio. If they had a translator there licensed under this condition, they would have to kill the translator if they were running under reduced power STA.

Still leaves ambiguity where the translator is inside the 25 mile circle but on the edge of the full-power daytime contour.

w9wi
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Re: Revitalized AM Translators

Post by w9wi » Mon Jan 15, 2018 9:54 am

This rule has recently changed. (last spring IIRC)

Originally the translator's coverage area had to be within 25 miles of the AM station *and* the 2mV/m contour.
It was changed to with 25 miles of the AM station *or* the 2mV/m.

I'm betting the translator in question was authorized before the rules changed?

========================

We had one about 30 miles from here that was briefly programmed separately from the AM. They seem to have cleaned up their act -- haven't heard them doing that in the last year. No, they *weren't* relaying some FM station's HD sub.
--
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Re: Revitalized AM Translators

Post by NECRAT » Mon Jan 15, 2018 11:07 am

We have two AM on FM translators in Providence, which have nearly 100% overlap of their signals. IIRC that's not legal either. Two translators carrying the same signal aren't supposed to overlap more than a minimal percentage. Correct?
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Deep Thought
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Re: Revitalized AM Translators

Post by Deep Thought » Mon Jan 15, 2018 11:34 am

The overlap policy is less than 50%, but it isn't spelled out in the rules.

That CP condition only applies if the AM station is operating with "reduced facilities" and is only on the newly-minted Auction 99 facilities which are forever married to the AM.

Section §74.1201 states:
(g) Translator coverage contour. [...]The coverage contour of an FM translator rebroadcasting an AM radio broadcast station as its primary station must be contained within the greater of either the 2 mV/m daytime contour of the AM station or a 25-mile (40 km) radius centered at the AM transmitter site. The protected contour for an FM translator station is its predicted 1 mV/m contour.

That will only come into play if the FX contour extends outside the 25 mile circle but is inside the licensed 2 mV/m of the AM. If the AM does something that reduces its 2 mV/m such that the FX contour now extends beyond both the operational 2 mV/m and the 25 mile radius it must reduce power or modify its facility so it is in compliance. In other words, don't expect to use that 50 KW daytime to get a translator in the "big city" 30 miles away and then back the AM off to 250 watts.
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Shane
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Re: Revitalized AM Translators

Post by Shane » Mon Jan 15, 2018 11:58 am

That’s right, Doug. Apparently the actual wording changed to “the greater of” the two contours, yet a couple of paragraphs down (sub paragraph j) reference is still made to the lesser of the two contours being the definition of the AM fill-in area.

I’m not sure what significance that subgraf has.

But condition 2 of the aforementioned authorization is just not rational, although I offer that if the licensee has the means to reduce the power to fit the translator coverage into what he might guess what the AM reduced coverage is, it could stay on. The question is: how does one determine the actual 2mV/m coverage of the AM station at whatever reduced parameters it is operating under? That isn’t normally something the licensee is expected to know, is it? Plus, what is the difference if the mother AM station operating with the reduced parameters normally signs off at night? That would be greatly reduced coverage! Under the terms of that condition one could conclude that once the AM signs off, the translator can either come back on or be restored to its full coverage.

Makes no sense.

That whole condition is made moot if the translator is at the AM site and has a normal coverage area of 25 or less miles radius.

But one does wonder why they would include that piece of, as Tom rightly called it, overthinking.

P.S.: A couple of posts were made while I was writing this. I did not consider the possibility of a 50kw AM and cheating in the way described. However, if the power reduction is only temporary, why strain at THAT gnat? It would make better sense, only IMHO, to make that provision enforceable when the first request for extension of the STA comes over the transom. In any event, how is the public interest served by reducing the coverage of a duly-licensed fully functioning FM translator because the mother ship is having problems? Bureaucracy at its best.
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Deep Thought
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Re: Revitalized AM Translators

Post by Deep Thought » Mon Jan 15, 2018 1:47 pm

how does one determine the actual 2mV/m coverage of the AM station at whatever reduced parameters it is operating under? That isn’t normally something the licensee is expected to know, is it?
It's about a ten second calculation and if you don't know it you aren't fit to be a licensee. Pick up the phone and call someone like me who will tell you without a fee.
what is the difference if the mother AM station operating with the reduced parameters normally signs off at night? That would be greatly reduced coverage! Under the terms of that condition one could conclude that once the AM signs off, the translator can either come back on or be restored to its full coverage.
Translators which are retransmitting daytime-only AMs have been allowed to "originate" since the first day of cross-service translators, so I'm not sure what you are trying to get at with that one, and the contour limits have always been calculated using the daytime facility.
It would make better sense, only IMHO, to make that provision enforceable when the first request for extension of the STA comes over the transom. In any event, how is the public interest served by reducing the coverage of a duly-licensed fully functioning FM translator because the mother ship is having problems?
That's the intent...if you file for an STA you'll need to make sure the translator is still compliant. The public interest is served by making it harder for scumbag operators to "accidentally" reduce the primary station's 2 mV/m contour for long periods of time. There are already bottom feeders out there trying this with the "move-in" translators.
Mark Mueller • Mueller Broadcast Design • La Grange, IL • http://www.muellerbroadcastdesign.com

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Re: Revitalized AM Translators

Post by TPT » Mon Jan 15, 2018 5:38 pm

In answer to W9WI's post--the C.P. I was looking at with this condition was issued last Friday.

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Re: Revitalized AM Translators

Post by Ray » Tue Jan 16, 2018 12:12 pm

I've been listening to a new translator that just signed on.

It appears that the licensee on the CP must have sold the CP to another local station.

The translator is repeating another local AM station different than that on the CP.
The owners of two stations are also different.

It seems to me that a change in ownership and a CP modification would be in order before going on the air.

Is there some way to do all this with a form 350?

I'm no expert on translator licensing, it just seems strange that the conditions of the CP seemed to have changed and the translator is on the air.

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Re: Revitalized AM Translators

Post by Deep Thought » Tue Jan 16, 2018 1:44 pm

A translator obtained under one of the move-in windows cannot change the primary station until four years of continuous operation (FX and AM) have passed, and can never be changed if it was obtained via an Auction 99 or 100 new station filing.

It is possible that the one you hear is not part of the "AM revitalization" program, which would not have those restrictions. What is the callsign or FID of the translator?
Mark Mueller • Mueller Broadcast Design • La Grange, IL • http://www.muellerbroadcastdesign.com

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Re: Revitalized AM Translators

Post by TPT » Tue Jan 16, 2018 4:42 pm

If the CP was issued under the 250 mile move-in window from 2016, that translator is tied to the AM for a 4 year period. If the CP was granted before this window, there is nothing to prevent another station from buying the CP and changing the primary station. Same would be true if a translator was granted a minor change CP (e.g.--only short distance move) that was issued in 2016 but separate from the 2016 move-in window.

The specific language in the construction permits under the 250 mile move-in waiver follows:

"Pursuant to Revitalization of the AM Radio Service, First Report and Order, 30 FCC Rcd 12145, 12153 para. 16 (2015), the permittee/licensee and any successor in interest (licensee) shall be subject to the following restrictions. From the grant of the construction permit and continuing until the facility has achieved four years of on-air operations rebroadcasting the primary AM station identified on this authorization, the licensee may NOT change such primary station being rebroadcast by this translator, nor may it rebroadcast another station when the primary station identified on this authorization is silent."

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Re: Revitalized AM Translators

Post by Shane » Wed Jan 17, 2018 1:09 am

1) I needed to re-read this:
That CP condition only applies if the AM station is operating with "reduced facilities" and is only on the newly-minted Auction 99 facilities which are forever married to the AM. (My emphasis added)
and 2) of course, it’s a math calculation (computing the 2mV/m reduced-power contour and the translator coverage to match. Duh on me.)

I do understand needing to head off the cheaters, but it does seem a little ridiculous (to me) to penalize the listeners of the station needing to run reduced power on the AM with matching reduced coverage on the translator. Delaying enforcement until a request for extension of the STA would keep the clowns from gaming the system and not penalize the listeners of the guy trying to be honest. Just sayin’.
Mike Shane, CBRE
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Re: Revitalized AM Translators

Post by kkiddkkidd » Wed Jan 17, 2018 7:42 am

Shane wrote:
Wed Jan 17, 2018 1:09 am
1) I needed to re-read this:
That CP condition only applies if the AM station is operating with "reduced facilities" and is only on the newly-minted Auction 99 facilities which are forever married to the AM. (My emphasis added)
and 2) of course, it’s a math calculation (computing the 2mV/m reduced-power contour and the translator coverage to match. Duh on me.)

I do understand needing to head off the cheaters, but it does seem a little ridiculous (to me) to penalize the listeners of the station needing to run reduced power on the AM with matching reduced coverage on the translator. Delaying enforcement until a request for extension of the STA would keep the clowns from gaming the system and not penalize the listeners of the guy trying to be honest. Just sayin’.
I have a sometimes customer that I will guarantee would "permanently" STA his AM's to flea power and keep the xlators on WFO if he could.... One is regularly on and off low power STA's due to junk tx problems anyway.
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Deep Thought
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Re: Revitalized AM Translators

Post by Deep Thought » Wed Jan 17, 2018 12:05 pm

Shane wrote:
Wed Jan 17, 2018 1:09 am
Delaying enforcement until a request for extension of the STA would keep the clowns from gaming the system and not penalize the listeners of the guy trying to be honest. Just sayin’.
The Commission is generally lenient in genuine out-of-the-control-of-the-licensee situations IF you don't lie about it and IF you make an honest effort to resolve the problem and get back to licensed facilities ASAP. A "guy trying to be honest" would not let the AM sit around on a 10 watt STA for a year. If you don't have enough money to fix the transmitter then you really need to get out of the business and off the air. It is extremely unfair to those who *are* honest and are stuck protecting these zombie stations to let them get away with this shit. The FCC is FINALLY addressing it.
Mark Mueller • Mueller Broadcast Design • La Grange, IL • http://www.muellerbroadcastdesign.com

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