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FCC Plans to Cap New NCE FM Applications
The FCC is expecting a rush next year when it opens a window for applications for new FM stations on the lower end of the U.S. radio band. So it is planning to cap the number of applications per entity and is asking for comment.
The commission confirmed it will open a filing window for new FM reserved band applications in 2021. Dates will be announced later. The reserved band is 88.1 to 91.9 MHz. Individuals cannot apply for NCEs.
[Read RW’s story this week about this planned window, “NCE Filing Window Likely in Early 2021”]
In a 2007 window, the commission capped the number of NCE FM new station applications per entity at 10. That cap was prompted in part by the massive response to a 2003 FM translator window, in which the commission got approximately 13,000 applications, many from “speculative filers.” The commission ended up getting about 3,600 in the capped 2007 window. It said the cap allowed it “to expeditiously process and grant thousands of applications to a wide range of local and diverse applicants, therefore promoting the rapid expansion of new NCE FM service throughout the country.”
Even though almost half of those 3,600 were mutually exclusive with at least one other application, it said that the cap helped restrict the number of MX applications, including “daisy chains,” situations in which proposals contain service areas that don’t directly overlap but are linked into a chain by the overlapping proposals of others.
Daisy chains are where things get really messy. “Applications for full-service stations present a prospect of ‘daisy chains’ of conflicting applications due to the size of the proposed service areas and the interference protection provided to full-service stations,” the commission wrote. “A limit on applications will reduce the number and complexity of such situations.” It wants to avoid a large number of speculative filings and the potential for “extraordinary procedural delays.”
A window in 2010 didn’t involve a cap but that was for a limited number of vacant allotments on the non-reserved band that had been reserved for NCE FM use, and generated only about 300 applications.
[Read: FCC Nixes Call to Tweak NCE Licensing Rules]
The FCC said it is expecting a lot of interest in 2021 for several reasons: There’s no application filing fee; there are no ownership limits in the reserved band; there has not been a filing window for new NCE FM applications for over a decade; and the commission recently simplified and clarified the rules and procedures including how it treats competing applications.
It invited comment on this cap, and added that its goal is to “give interested parties the opportunity to apply for local and regional NCE FM outlets.” Read the details here.
The number of FM educational stations has almost doubled in two decades, from 2,140 in the year 2000 to just under 4,200 at the most recent count. But if there is a rush of applications, they probably will be focused on smaller markets. John Garziglia, communications law attorney for Womble Bond Dickinson, told RW recently that he expects most new full-service NCE licenses will be awarded outside major urban areas.
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Media Bureau Changes Course, Revokes CP Grant for Oregon FM Translator
A construction permit for an FM translator in Oregon has been rescinded due to issues of interference.
In December 2017, Bustos Media Holdings filed a construction permit for FM translator station K260DK in Portland, Ore. The Media Bureau established a deadline of Jan.10, 2018 for anyone wishing to file a petition to deny. On Feb. 1 of that year, the bureau granted the application.
[Read: FCC Addresses Reconsideration Petitions on FM Translator Interference Rules]
A month later, the Media Institute for Social Change (MISC) filed a petition for reconsideration saying it had only recently become aware of the application and said the bureau should rescind the application grant because the translator would cause interference to listeners of its station KXRW(LP) in Vancouver, Wash.
To support its claim, MISC submitted maps, studies and lists showing the issues of interference. It included maps of the 60 dBu contours of KXRW and the translator, a map showing 10 listeners of KXRW whose addresses fell within the translator’s contour, a map showing listeners outside of the 60 dBu contour who were predicted to receive interference from the translator, a map showing areas where the translator’s signal would cause interference to the signal of KXRW, a list of KXRW listeners, an engineering statement and declarations from 25 listeners of KXRW.
MISC also asserted that Section 5 of the Local Community Radio Act of 2010 requires the commission to favor LPFM service in this case.
Bustos opposed the petition, saying the petition was not properly verified.
The bureau responded to Bustos and denied its petition. The bureau found no merit to Bustos’ claim that a subsequent Application for Review filed by MISC did not concisely and plainly state important questions of law. It also dismissed Bustos’ assertion that the AFR should be outright dismissed because the AFR was signed by a nonattorney. But that in itself does not violate the rules, the bureau said.
But the full about-face came from the Media Bureau soon after. It agreed with MISC and said it erred by concluding that MISC did not give enough evidence that the translator would interfere with the reception of KXRW by listeners.
The bureau found that the petition did indeed contain “convincing evidence” that the translator would cause such interference. That included a list of KXRW listeners, a map demonstrating that 10 of those listeners resided within the translator’s 60 dBu contour and proof that a future FM translator would result in interference to reception KRXW by those 10 listeners.
Thus, the bureau found that the company presented convincing evidence of predicted interference. As a result, the bureau granted the Application for Review and rescinded the grant for the construction permit for K260DK in Portland.
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Schnelle Joins Broadcast Depot
Mary Schnelle has joined the U.S. sales team of Broadcast Depot.
She’s well known to equipment buyers in the radio broadcast industry from her years with Harris, SCMS and Broadcasters General Store.
Broadcast Depot offers products and services for radio, television, IP, OTT and satellite transmission. It was founded in 1999 and is headquartered in Miami. Tim Jobe is national sales manager for the United States.
Schnelle began her career in accounting at Harris in 1992. She is a graduate of Culver Stockton College in Missouri and holds an MBA from Quincy University in Illinois.
Send People News announcements to radioworld@futurenet.com.
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WCR Community Radio Uses Sonifex S2
From our Who’s Buying What page: WCR Community Radio station in Warminster in the United Kingdom is using two new Sonifex S2 broadcast mixers for its refurbished radio studios.
The manufacturer quoted Managing Director Barry Mole saying the mixer’s modularity was an important consideration. The S2 has hot-swappable input and output modules in both analog and digital, and a selection of optional modules for its main surface and meter bridge.
[See Our Who’s Buying What Page]
WCR Community Radio relies heavily on volunteers. It was founded in 1996 as a hospital radio station broadcasting from a backroom at a local theatre. It secured an FM license in 2012, broadcasting on 105.5 MHz.
The station is using an S2-M6SS 6 Way Source Select Panel to handle remote OB inputs, feeds from other studios, a recording computer and other sources.
Send news about new product installations, studio or RF builds and other projects to our Who’s Buying What feature at radioworld@futurenet.com.
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Digital Radio as Solution to Both AM and FM Ills
The author is a consultant to Entercom and former senior VP of engineering at CBS Radio. He was a founder of HD Radio developer USA Digital Radio and was the VP of engineering for its successor iBiquity Digital.
A rule allowing AM stations to transmit in all-digital will be the most significant “AM improvement” since the allowance of FM translators.
Together they showcase the FCC’s interest in bringing AM radio into the 2000s; and it is happening as we approach the KDKA 100th anniversary of that famous Cox-Harding election coverage broadcast. I feel fortunate to have met the announcer, Leo Rosenberg, from that historic broadcast.
[Related: “The FCC Will Vote This Month on All-Digital for AM”]
From my earliest days of working in AM, I have been concerned about the quality of the AM reception process.
Following Greg Ogonowski’s research identifying AM receiver bandwidth as the choke point of quality in AM transmission systems and the subsequent introduction of pre-emphasis to overcome the limitations of the AM broadcast system, I began looking for technical solutions.
Then came household noise and egregious noise in the environment as the biggest enemy of AM radio. As I began reviewing my texts from my college textbooks, I began to see how advances in solid state that would ultimately lead to inexpensive digital chips for radios can solve both the problems of AM and FM.
The National Association of Broadcasters must also be given credit for bringing the possibilities of DAB to the United States through its interest in Eureka-147, even though U.S. broadcasters would have never been able to gain access to the required spectrum.
In the early 1990s I became a believer in digital radio as the solution for AM and FM ills. The draft report and order brings to the AM broadcaster the ability to offer what FM offers today. However, the total digitization of radio will bring to FM opportunities beyond the capabilities of all-digital AM, and once again leave AM behind — but not left out of the digital world.
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Pleadings
Actions
In the Matter of Online Political Files of WDLW Radio, Inc.
Applications
In the Matter of Online Political Files of WOBL Radio, Inc.
Broadcast Actions
Broadcast Applications
In the Matter of Online Political Files of Mittens News, LLC
FCC Seeks Comment on Proposed Application Limit for NCE FM New Station Applications in Upcoming 2021 Filing Window, Public Notice.
Listening Is Shifting Back to the Car
Audio consumption in the United States is shifting from home back to the car as quarantine restrictions have lifted in some areas.
Edison Research released a summary of its latest Share of Ear report.
[Read: Removing Car Radios “Puts Consumers at Risk,” Former FEMA Head Says]
“Prior to COVID-19 restrictions in Q2 2020, 32% of all audio in the U.S. was consumed in-car,” the company stated.
“When quarantine restrictions went into place in Q2, erasing many Americans’ commutes and greatly reducing travel in general, in-car listening plummeted by 38% so that it accounted for only 20% of all listening. This caused at-home listening in Q2 to soar from 49% of all listening to 70% of all listening, an increase of 43%.”
Now its latest research, conducted in early September, shows a shift back to the car as quarantine restrictions have eased in some locations and in varying degrees.
“In-car listening grew from 20% in Q2 to 28% today, not quite equal to the pre-COVID number of 32% of all listening,” it stated.
At-home listening levels fell from 70% early in the quarantine period to 59% of all listening today. The company said at-home is still 10 points higher than pre-COVID. “With a U.S. workforce that has seen many employees transition to home office environments, future surveys will bear out whether or not this is a permanent shift.”
Meanwhile, listening at work has “slightly rebounded” over the same period.
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KDKA Adds FM Signal
A century after its famous election night broadcast, KDKA will now be heard on the FM dial as well as its familiar 1020 kHz AM frequency.
Entercom, owner of the station in Pittsburgh, said, “News Radio 1020 KDKA will simulcast on FM for the first time ever and be heard on 100.1 FM as ‘100.1 FM and 1020 AM KDKA,’ effective Nov. 2.”
The new frequency is an FM translator, W261AX. The hip-hop format that had occupied that slot, WAMO, moves to 107.3 MHz.
[Read: What, Exactly, Was First About KDKA?]
There is already a station licensed with a KDKA(FM) call sign and owned by Entercom, but it carries sports programming.
The announcement that the news format would expand to FM was made by Michael Spacciapolli, senior vice president and market manager of Entercom Pittsburgh. “After serving Pittsburghers on our AM dial for the last 100 years, we are thrilled to expand the reach of historic KDKA on FM,” he was quoted in the announcement.
The station famously aired presidential election results on Nov. 2, 1920, and KDKA has been celebrating the anniversary throughout this year.
The post KDKA Adds FM Signal appeared first on Radio World.
FCC’s Starks Points to GeoBroadcast Solutions at Conference
FCC Commissioner Geoffrey Starks addressed the Hispanic Radio Conference on Oct. 15. In a section of his talk he singled out GeoBroadcast Solutions for favorable comments.
He drew attention to the company’s localized broadcasting technology. “The use of this geo-targeted content holds promise as a way for stations to provide hyperlocalized content including alternative language news, weather, emergency alerts, and advertising periodically during the broadcast day. It could provide a way for minority-owned stations to better serve their communities, and open up opportunities for small businesses looking to more cost-effectively advertise to a targeted audience and for FM stations owned by people of color to increase advertising revenue.”
[Read: Should Translators Originate Content? FCC Is Taking Comments]
Starks noted that the FCC can do to promote this. “One proposal before the FCC holds promise to do just that. GeoBroadcast Solutions LLC has petitioned the FCC to revise the FM booster rule to allow, on a limited basis, geo-targeted content to originate from FM booster stations.”
He added that GeoBroadcast Solutions “has developed an ad revenue sharing model that would help smaller stations install boosters and new technology necessary to use the system without having to come up with up front capital and operational expenses.”
GeoBroadcast Solutions CTO Bill Hieatt said, “We appreciate the commissioner’s remarks and note that our development of a geo-targeting solution for the broadcast radio industry was due in part to help reach underserved minority sub-markets within a station’s signal range.”
He explained, “We believe our technology will level the playing field across consumer media in ways that cannot be done today but can begin quickly to support moves the radio industry in line with today’s technology while also improving the consumer experience in the most widely-used source of news, entertainment, and information.”
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What Happens When Lightning Hits? A Case Study
Radio World congratulates our friend and contributor Mark Persons, who this fall received the Society of Broadcast Engineering’s John H. Battison Award for Lifetime Achievement!
Studio of KRJM with STL mast adjacent.It started at 4:30 a.m. Tuesday, Aug. 19, 2019, with a thunderstorm. KA-BOOM!
People in the small northern Minnesota town of Mahnomen reported hearing the loudest thunder they could remember. Sean Bjerk, KRJM Radio’s manager/morning man, lives three miles away. He was jolted out of bed and left wondering, “What happened?”
A quick check showed the station was silent. Upon entering the studio building, Sean found thick smoke. He grabbed a fire extinguisher and investigated but found no fire.
The power was out. All circuit breakers had tripped. Resetting them brought on only some lights, but no audio.
The thunder concussion had been so great that two studio clocks were knocked off the wall and onto the floor.
The evidence was clear. Lightning had hit a station-owned utility pole with an STL dish.
Fig. 1 shows that lightning chewed through the top of the pole to get to the STL dish and transmission line.
Fig. 1: Lightning struck the pole, cutting a deep gouge.Fig. 2 shows the 1/2 inch Andrew Heliax STL coaxial cable. It was burned as lightning jumped from the cable to the metal siding of the studio building at the point where the line entered.
Fig. 2: Lightning ate into the STL cableWhat to do now? Contract engineer Jim Offerdahl was 110 miles away. He set out immediately and on arrival found that virtually every piece of electronic equipment in the studio facility was damaged beyond repair.
The KRJM 101.5 FM 25 kW transmitter site, some 12 miles away, was fine. It just needed audio.
Jim used internet streaming audio from KRJB(FM), Ada, Minn., to restore temporary programming by early afternoon. Audio was from one of the dozen stations of R & J Broadcasting, Inc. in northern Minnesota. The format was country, instead of the oldies that Mahnomen area listeners were accustomed to hearing. KRJB added KRJM commercials and IDs to keep the station legal while continuing to make money.
Damage
Fig. 3 shows the wall outlet where the main equipment rack was plugged in. Totally blackened, it was useless.
Fig. 4 shows the wall where an electrician cut into a wall to check wiring to the outlet. After seeing the damage, Jim installed a new outlet elsewhere with new wiring.
Fig. 4: Opening the wall to examine power wiring.You’ll see a green light on the telephone system. It was lit but the system and its phones were fried as seen in Fig. 5.
Fig. 5 Even the telephone wiring was damaged.The main computer network switch was history. With that kind of damage, Jim strung new network cables to ensure reliability.
Fig. 6: The network switch was damaged beyond repair.The automation system at KRJM also was toast except for one of the three hard drives, the only component that survived the disaster. This allowed the automation to be rebuilt and the station to be back to normal programming in two days. Part of the delay was to install a new STL dish and feed line, along with an STL transmitter and audio processing.
All of the studios were down so a temporary one needed to be rigged.
The network connector on a studio computer and a black spot on the wall (Fig. 7) are evidence of fire and smoke created by the event.
Fig. 7: This studio computer was one of the victimsFig. 8 is where an unterminated computer network cable blackened a wall where lightning was seeking ground.
Fig. 8: A loose network cable blackened a wall.An insurance claims adjuster shook his head saying, “This is the worst damage I have ever seen.” The insurance claim was paid.
Fig. 9: Station manager Sean-Bjeck showed off some of the damaged equipmentFollow the Lightning
The KRJM studio facility had been constructed in a typical manner and enjoyed 20 years of normal service. There was a ground rod at the base of the STL pole for protection.
You’ll remember I wrote a Radio World article about grounding in the fall of 2017. It discussed how lightning will usually take the easiest path to ground. What we often forget is that ground rods, a standard approach to grounding, are imperfect.
Forensic Analysis
Lightning traveled down the STL pole and ignored the ground rod. Instead, it followed the STL transmission line to an equipment rack in the building.
From there, the lightning found ground through the rack’s 120 VAC power circuit, supplied by the building’s electrical load distribution center (circuit breaker panel). A lot of sensitive equipment was damaged along this path. Think of your broadcast equipment as a “fuse” in a series circuit between the lightning and ground. Poof!
In the final analysis, what was missing was a heavy wire link between the STL pole ground rod and the studio ground. To say it another way, the pole and the studio had two different grounds. They were likely thousands of volts apart during the lightning strike. Almost everything in the middle was damaged.
Lightning protection
The ideal setup is one in which the STL and all other cables enter the building near the electrical power panel. All cable grounds tie to the electrical panel ground and ground rods. It is a “common point” for all facility grounds. This “star ground” has a heavy wire from that point to each studio and equipment rack.
The idea is that studios and racks are “stubs” from the common ground point. Lightning has no reason to travel to a studio if there is no ground at that end to go to. That same thinking applies to transmitter sites, which are even more vulnerable to lightning damage.
Also, I recommend a flexible #12 wire from each piece of equipment to the rack it is mounted in. Don’t be fooled into believing there is a good electrical connection from rack to equipment because they are screwed together. Paint gets in the way of a good electrical connection.
Static Dissipaters
It is a well-known fact that sharp points, directed at the sky, are a good way to dissipate/bleed off static charges, i.e. reduce voltage between the ground and the sky. It happens continuously as storms pass by.
The result is either no lightning strike or less energy in a strike because the voltage is less than it would have been without dissipators.
Static dissipators are typically made of stainless steel to avoid corrosion. The one shown in Fig. 10 is suitable for the wooden pole or any tower under 100 feet. Two dissipaters are even better.
Fig. 10: Nott GS-2-Static DissipaterDissipaters go as high as possible on a tower, building or a wooden pole like the one in this article, and need a ground wire directly connected to a common point ground. No wire is required on a steel tower because steel is an electrical conductor. Learn more at www.nottltd.com/lightning.html.
Summary
It is experiences like this that get the adrenaline flowing in an engineer’s blood. Jim Offedahl will be telling his grandchildren this story someday from the comfort of his rocking chair.
Comment on this or any article. Write to radioworld@futurenet.com.
Visit the author’s website at www.mwpersons.com.
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NCE Filing Window Likely in Early 2021
There may soon be more signals on the lower part of the FM band in the United States.
While 5G seems to be the recent focus of Federal Communications Commission spectrum allocation, a new filing window for the noncommercial educational service is expected as soon as early next year.
Over a decade has passed since the FCC accepted applications for new full-power NCE construction permits.
A window would allow non-profit organizations, schools and native tribes to apply for original CPs in the NCE reserved band, 88.1–91.9 MHz. Individuals cannot apply for NCEs.
A filing window would probably also allow existing NCE stations to seek major changes. And observers expect that a window for additional low-power FM stations could follow (see sidebar at bottom of this story).
Chairman Ajit Pai, responding to a congressional inquiry about LPFM this summer, signaled the commission’s intent to open a full-power NCE window in early 2021.
“Staff anticipates that the new NCE FM window will be opened after our new processing rules for this service are effective later this year,” Pai wrote in a letter to Rep. Xochitl Torres Small (D-N.M.)
Asked for comment about possible expansion in the number of stations at the left end of the band, National Public Radio said it is always “supportive of opportunities to expand station services when they are presented.”
Observers say most opportunities for new NCE stations would be in less populous parts of the country, considering the number of signals already squeezed into the band where there are more potential listeners.
By the numbers
The number of FM educational stations has almost doubled in two decades, from 2,140 in the year 2000 to just under 4,200 at the most recent FCC count.
The number of commercial FMs increased at a much slower rate, from roughly 5,900 to about 6,700. The category of FM translators and boosters grew prodigiously, from about 3,250 to 8,300; and LPFMs, which didn’t exist before the beginning of this century, now total 2,146 licenses.
The NCE service has not had a window for new applications since 2010, according to the FCC, and that one involved a limited number of existing vacant allotments.
A 2007 NCE window yielded approximately 3,600 applications, of which about 2,700 were mutually exclusive, meaning applications involved geographic or spectral overlap. The FCC in that round granted approximately 1,330 CPs for new NCE service, according to commission data.
There’s no way to know yet how many new NCE licenses the commission might eventually award since it does not identify potential slots. Typically, an applicant identifies a spectrum opening on a certain frequency and names a transmitter site, power and antenna height to fit that spectrum availability.
New processing rules
The commission in late 2019 revised certain rules for processing NCE applications; the measures are intended to simplify and improve selection and licensing and clarify procedures for choosing among mutually exclusive applications.
The changes dealt with specifics such as divestiture pledges and amendments to the governing documents of applicants who claim certain MX point classifications. The FCC also will revise the application form to require each applicant to certify that it has reasonable assurance of availability of its proposed transmitter site.
“We are hopeful that Office of Management and Budget can finalize its approval of those rule changes in mid-October,” a spokesperson told Radio World in September. “After that approval, the commission will be able to announce more details about a new NCE window in 2021.”
The FCC included all of the changes to the NCE and LPFM processing rules, including rules governing major tie-breakers for mutually exclusive applications, in a Report and Order in MB Docket No. 19-3 issued last December.
The resolution of competing claims is an important part of the process whenever a new station window opens.
The commission places conflicting applications into MX groups before applying internal processing; it then selects one application for grant from each separate MX group. A point system is applied to each application based on public interest criteria (such as diversity of ownership, localism or technical superiority) and the application with the most points in an MX group is the tentative selectee.
The commission recently dismissed a challenge to the NCE MX process. Law firm Discount Legal had argued that the FCC should set up a secondary grant policy for MX groups, essentially naming “runner-up” applications, but it was unsuccessful.
“No new additional changes to the NCE processing rules are expected before opening a window next year,” the FCC spokesperson said.
Nitty gritty
Applicants in the filing window must propose a facility that meets at least the minimum for a Class A FM station, which is 100 watts (0.1 kW) at 30 meters height above average terrain. Facilities proposed may be up to 50 kW for a Class B or 100 kW for a Class C depending on the proposed station location.
Noncommercial educational FM stations protect all other reserved band full-service stations using contour overlap on co-, first-, second- and third-adjacent channels. However, reserved band stations are not required to protect existing LPFM and FM translator stations.
The FCC expects any new NCE window would be open for one week.
As for when that might be, the commission typically gives several months’ notice of any filing window for new station applications.
One observer, communications law attorney Dan Alpert, said the timing of the filing window is discretionary on the part of the FCC but guided by the winds of political pressure. But he said the window is likely to come while there are still economic unknowns caused by the pandemic.
“There may be fewer parties out there who can afford the time and expense to develop engineering proposals that would be necessary for an NCE filing,” Alpert said.
These filings would not involve a filing fee, he said, since these are for non-commercial facilities in the non-commercial reserved band. “However, there will be substantial costs involved pertaining to engineering and legal analysis.”
The 2007 NCE window limited applicants to a total of 10 applications nationwide; the FCC could again place a cap to avoid huge numbers of applications that would be difficult to process and could lead to daisy chains of competing applicants.
“To the extent the commission intends to explore imposing similar limitations this time around, it will first seek public comment and input on such an approach,” the FCC spokesperson said.
The spokesperson added that many applicants are disqualified because they didn’t pay sufficient attention to the filing requirements.
“Our rules spell out in detail our procedures for processing applications for new NCE stations. Those rules provide potential applicants with guidance about what factors will be taken into account to resolve any mutual exclusivity among applicants, and how to resolve mutual exclusivity.”
“Incredibly Crowded”
While the FM band has become quite busy in the 21st century, congestion and interference are generally viewed as greater issues higher up the dial. But that doesn’t mean there are a lot of tasty NCE market opportunities waiting to be discovered, either.
John Garziglia, communications law attorney for Womble Bond Dickinson, expects most new full service NCE licenses will be awarded outside major urban areas.
“The FM band in most areas of the country is already incredibly crowded. It is unlikely that applicants will find either full-power NCE or LPFM opportunities in most non-rural areas. In rural areas, there will be significant availabilities for both new NCE and LPFM stations,” Garziglia said.
Garziglia expects the application processing would take at least a year, which could delay the opening of the LPFM filing window.
“If the FCC opens an LPFM window prior to the almost-complete processing of NCE applications, there is the risk that spectrum space specified by NCE applications that will later be dismissed or denied will foreclose availabilities of LPFM spectrum,” Garziglia said.
“So, there may be a significant detriment to LPFM applicants if the FCC does not await a full processing of NCE applications prior to opening an LPFM window.”
Matt McCormick, co-managing member of Fletcher, Heald & Hildreth, said groups hoping to apply for an NCE license should use the next few months to select knowledgeable consulting engineers and a communications attorney familiar with the NCE selection process.
“There are too many traps for the unwary for an applicant to try to weave its way through the process without a lawyer,” he said.
“The third step is to make sure the applicant’s corporate paperwork in up to date with the appropriate state office, which is the secretary of state’s office in most states.”
McCormick said applicants need to submit the strongest application possible and assume that mutually exclusive applications will be filed; and they should propose technical facilities serving populations that currently have no or only one NCE radio service.
Should interested parties wait for the expected LPFM opportunity?
“Frankly, I think that any non-profit group that wants to get into radio should file in this window,” he said. “If it wants to reach a relatively large geographic area, it can do so with a full-service NCE FM, whereas the coverage of an LPFM is limited to the area it can reach with 100 watts at 30 meters above average terrain.”
In addition, even if a non-profit plans to operate with a low power level at first, a full-service NCE license may allow it to increase power later.
“Moreover, if the group is not successful in getting a full-service NCE FM through this window, it can always file for an LPFM during the window that will follow.”
For those selected to receive new full-service NCE construction permits, the costs involved in building and operating a radio station can be substantial.
REC Networks, a consultancy that is active in the non-profit and LPFM sector, estimates $3,000 to $30,000 for a transmitter to get started, depending on the situation. Antenna size and cost also will vary based on power level, with a simple non-directional antenna at lower power (250 watts or less) around $700 to start, but higher-power and directional antennas, especially those with a custom design, can be far more costly.
New NCE stations are also required to install an Emergency Alert System encoder/decoder, REC notes.
Sidebar: What About LPFM?
Scott FlickAn entity eager to apply for a low-power FM license may get an opportunity to apply for one once the FCC completes work on its NCE filing window. LPFMs operate under noncommercial educational broadcasting rules as well.
An FCC spokesperson says the commission doesn’t have a specific date “but we anticipate that will be a priority” once the next window for full-power NCEs is done.
“We want to avoid the situation where we issue new LPFM permits that are subsequently knocked out by new primary NCE stations.”
Some observers think an LPFM filing window could come in late 2021 or early 2022.
The LPFM service was launched in January 2000. LPFM stations are limited to 100 watts effective radiated power. There are 2,146 licenses as of the most recent FCC count. New LPFM applicants would be allowed to apply for one license, according to the FCC.
Scott Flick, a partner at Pillsbury Winthrop Shaw Pittman, answered questions from Radio World.
Radio World: How should non-profit groups prepare for the next LPFM filing window?
Scott Flick: In terms of preparation, there is no substitute for reviewing the application form used for this purpose by the FCC (Form 318) to see if the applicant can supply the requested information and make the required certifications, or needs to take further steps to be able to do so.
And of course, the applicant needs to make sure that it is the type of entity that can even qualify to apply for an LPFM authorization in the first place. The requirements are narrower than most people realize, and can be found in Section 73.853 of the FCC’s rules. The applicant must also be local to the station service area and, with some exceptions, can’t have an interest in other broadcast stations.
RW: What kinds of things often trip up LPFM hopefuls?
Flick: Common problems LPFM applicants have in the planning process include failing to secure the rights to their proposed antenna site — lease negotiations fall through — or discovering that they need to deal with local zoning authorities to be able to use their proposed site.
There is also a pretty long list of FCC rules applicable to LPFM, which can be found in Section 73.801, and applicants should ensure they are familiar with all of them. They also need to be thinking about how they will supply a continuous stream of content to feed the station, as, for example, LPFM stations are prohibited from retransmitting the signal of a full-power station, along with other types of content.
RW: How about the finances?
Flick: Of course the biggest issue is having a viable business plan in place. Since LPFM stations have to be operated non-commercially, it’s particularly important to have worked through how the station will cover the costs of its operation and what those costs will be. Many people underestimate the costs involved and then struggle to stay on air. Operating an LPFM successfully means being able to deal with occasional unexpected expenses.
For example, since LPFM stations are subject to interference objections from full-power stations, an LPFM operator may suddenly find itself having to modify its engineering operations to eliminate interference, or even having to locate a new channel to operate on in extreme cases. Having a budget in place that can withstand the costs of equipment modifications or replacement is a wise move.
RW: Any final tips for potential LPFM licensees?
Flick: It’s worth noting that applying for an LPFM station and getting an authorization to operate one are not the same thing. If the application is incomplete or incorrect, the FCC may reject it out of hand. If the application is perfect in every way, the applicant may still not get a license because other applicants applied during the same filing window for facilities that are mutually exclusive with that application.
In that case, the FCC has processes in place to decide who gets the license, and in some cases, may encourage parties to share the license. As a result, parties should be careful about spending money or making commitments for leases or the like until they know they have a construction permit in hand.
Of course, they need to make sure all equipment meets FCC requirements, as there are plenty of FCC enforcement actions out there against stations that tried to use whatever equipment they could lay their hands on rather than what is required by their FCC authorization, particularly after an equipment failure.
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