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50 Broadcast Groups to FCC: Remove Obsolete EEO Rules
A group of 50 state broadcaster organizations are telling the Federal Communications Commission that it’s time to remove outdated equal employment opportunity rules.
Many of the proposals presented in the FCC’s Notice of Proposed Rulemaking on equal employment opportunity would increase burdens on broadcasters and be of questionable constitutionality and little practical utility in achieving the commission’s stated goals, the group said.
The broadcasters filed their comments as part of the FCC’s request for reply comments on the commission’s Equal Employment Opportunity Compliance and Enforcement Notice of Proposed Rulemaking.
[Read: A Debate Over EEO Audits]
The FCC wants to reduce the regulatory burdens associated with the EEO rule without altering the substance of the rule.
“That can be accomplished quite simply and quickly by eliminating what has now become clear are repetitive and unproductive random EEO audits,” said the state organizations. Stations’ EEO performance is already reviewed at license renewal time and during mid-term reviews, and previous audits have confirmed “that they are not needed, as they have found a very high level of EEO compliance among broadcaster,” the group said in its filing.
“Alone among all other broadcast rules, the EEO Rule is the only rule enforced by random audits,” the group said. “There is no rational basis for implementing such an unusual, repetitive, and burdensome enforcement mechanism for EEO.”
The group also pointed to the questions of constitutionality that were raised about previous EEO rules. “[T]he DC Circuit has openly and repeatedly questioned whether the FCC has any compelling governmental interest in regulating the employment practices of broadcasters at all, a matter it has never had to reach in invalidating the prior iterations of the FCC’s EEO rules.”
As a result, any modified EEO rules adopted by the FCC should be as narrowly tailored as possible, the group said.
The New Jersey Broadcasters Association, which was as part of the 50 broadcaster group comment, filed a separate set of comments to advocate again that the FCC reassess its current documentation and paperwork approach to nondiscrimination and employment diversity.
“In the absence of evidence that the current FCC’s paperwork and recordkeeping requirements prevent or reduce discrimination, or increase employment diversity, the FCC should direct its regulatory efforts to finding effective ways to achieve the important goals of nondiscrimination and employment diversity,” the NJBA said.
The FCC’s current EEO requirements are unproductive and are not serving to achieve their intended goals, the organization said. Instead, it’s time for the industry to come “together to explore more effective options that will truly reduce discrimination and increase diversity in the broadcast station workplace,” the NJBA said.
Comments on the FCC’s EEO proposed rulemaking can be seen in the commissions’ ECFS database using Media Bureau Docket Number 19-177.
The post 50 Broadcast Groups to FCC: Remove Obsolete EEO Rules appeared first on Radio World.
A Debate Over EEO Audits
The MMTC believes a key to ensuring diversity and fairness in the hiring process is to audit stations to ensure nondiscriminatory practices are taking place.
Those are the suggestions issued by the Multicultural Media, Telecom and Internet Council in response to comments filed by the National Association of Broadcasters and ACA Connects — which are all part of the Federal Communications Commission’s request for reply comments on the commission’s EEO Compliance and Enforcement Notice of Proposed Rulemaking.
[Read: 82 Small Broadcasters Weigh in on EEO Rule Changes]
A series of initial comments on the issue was filed by MMTC in early September whereby the organization recommended four steps the commission should take immediately to improve EEO enforcement: increase the percentage of audits undertaken each year; institute deeper audits of randomly selected stations; install a whistleblower phone line; and publish a primer with best practices and model EEO programs.
Both the NAB and ACA, however, expressed concerns about the suggestion to increase the number of audits. The NAB said the FCC’s EEO audit program is already a material drain on local broadcasters’ resources. “Also, NAB knows of no other context — apart from instances where the commission grants money to an outside entity — where the commission aggressively audits compliance with its rules,” the NAB said. “Rather, in nearly every other instance, the agency adopts rules and then expects compliance. If an entity is found to have violated FCC rules, it faces various consequences.”
“This is the same approach the commission should take to EEO compliance,” the NAB said, adding that fewer than 1% of audits have revealed a violation of EEO rules.
But MMTC argues in later comments that just because discriminatory actions aren’t being found, doesn’t mean they’re not happening. EEO compliance is uniquely audit-worthy because compliance is seldom knowable except by insiders, the organization said. “Discrimination may be a subtle process which leaves little evidence in its wake,” the organization said by way of quoting the D.C. Circuit court. “On the other hand, engineering rule misconduct is generally discernable by members of the public.”
MMTC also counters NAB’s claims that existing reporting efforts are burdensome on smaller-market stations. Rather, MMTC said, nearly all of the information that stations must provide is already maintained as part of customary modern personnel practice.
“In a professional work site, none of this information has to be created just for an audit,” the MMTC said. “Consequently, the actual cost of responding to an audit is negligible.”
ACA also addressed the issue of cost in its filing comments, saying that it opposes enhanced onsite audits because the cost would outweigh the benefit. In response, MMTC said that the commission can be faithful to its EEO goals and its cost/benefit mandate by conducting a pilot program to test expanded audits.
Comments on the FCC’s EEO proposed rulemaking can be seen in the commissions’ ECFS database using Media Bureau Docket Number 19-177.
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Angry Audio: Of Gizmos and Gadgets
Broadcast engineers can generally anticipate using a fair amount of creativity. That creativity manifests itself in simple and complex control, monitoring and delivery systems. Engineers spend sleepless nights saying, “This is going to be a great addition to our operation, but how am I going to …?”
The Failsafe Switching Gadget installed (just below the Moseley STL). Note the optional half-rack panel with Angry Audio logo.Such was the case during a studio renovation wherein I deployed Yellowtec YT3105 microphone arms. The on-air staff was impressed with the LED tally light that was situated right above the microphone. How, though, do I get that sorcery to work? The preinstalled YT3105 cable has five wires; three for the microphone and two for the LED. I had to build a 5-pin pigtail that would break out the mic and LED connections. This was all hidden above the ceiling where the YT3105 cabling met with a confusion of power supplies and terminal strips to facilitate switching the LEDs.
In addition to YT3105 LED conundrum, the talent positions in these studios needed headphones. I wanted to put normal turrets in front of each position, but there wasn’t enough surface space on the studio furniture. So, this meant the talent got under-the-desk headphone volume boxes and no cough switches.
Fast-forward a few months to another project that involved transporting audio from a satellite downlink site to the studio. There were primary and backup audio paths (T1 and IP). Through an assortment of silence sensors and audio switches, I can switch to the backup if necessary, but it sure would be nice to have it all in one box.
So, what is there to do about all these issues? Nashville-based Angry Audio is owned and operated by veteran console designer Michael “Catfish” Dosch, who has been associated over past years with well-known brands like PR&E, Axia and Lawo.
Angry Audio understands broadcast engineering and the simple yet annoying problems that it involves. Plus its solutions look really slick. I found the Mic Tally Gizmo, the Guest Gizmo and the Failsafe Switching Gadget. Two words: Problems solved.
MIC TALLY GIZMO
Luckily, I inverted the Yellowtec YT3105 riser poles and supported them from a rigid aesthetic contraption on the ceiling. It allowed me to hide the homemade Y-adaptors and power supplies for the YT3105 LED and microphone harness. However, the Angry Audio Mic Tally Gizmo takes care of all of that by hiding ugly wiring. The rugged steel construction and surface-mount design allow the 5-pin XLR to plug in on the desk right next to the Yellowtec pole mic pole assembly.
Simply drill out a 2 1/8-inch hole in the desk and the Mic Tally Gizmo drops in. The back side has a male XLR jack that serves as a pass-through for the mic, a 15 V DC plug (wall-wart is included) to power the YT3105 LED and 1/8-inch jacks for LED logic. There are two logic ports. One activates the red LED and one activates the white. All the Yellowtec YT3105 functions are handled cleanly by the Mic Tally Gizmo. Everything comes to one place, and no homemade adaptations are required. The powder-coat finish looks great on any surface.
GUEST GIZMO
Studio design is evolving in such a way that the room is becoming less heavy. There are fewer equipment racks atop and under studio desks. Now we merely see computer peripherals, speakers and microphones. This lends itself to smaller desk design with less surface space. I experienced this firsthand in the studio design where I had no room for talent surfaces or turrets. The Guest Gizmo is a perfect solution for this.
Just like the Mic Tally Gizmo, the Guest Gizmo boasts a rugged powder-coated steel design. It fits into a 2 3/4-inch hole. The surface-mounted top panel has an illuminated cough button, 1/4-inch headphone jack and volume knob. The built-in headphone amplifier packs plenty of headroom. On the rear of the Guest Gizmo, inputs are left and right line level via balanced 1/4-inch jacks. A 16 VAC (wallwart included) powers the built-in headphone amp. An additional 1/4-inch TRS jack can be connected to the Insert jack found on the Mic inputs of live-sound mixers, providing broadcast-style remote mic muting even when the board lacks muting logic. The surface-mounted front panel is 3 inches by 3 inches and takes up very little desk space.
FAILSAFE SWITCHING GADGET
We move on from the gizmos to the gadgets. The 1RU Failsafe Switching Gadget is housed in a near-bulletproof half-rack wide steel enclosure. It comes with a 120 V power cord, so there’s no additional wallwart to put in the rack. The Failsafe Switching Gadget monitors audio on the “A” input. When audio fails on the A input, the system switches to the B input. The silence threshold level, manual switching, automatic switch delay and switch recovery behavior are controlled on the front panel. The recovery function allows for deciding how much human intervention is needed in the event of an audio failure.
Basically, the unit will either switch to the B input and stay there indefinitely, or will switch back to the A input when main audio is restored. The two XLR stereo inputs and stereo outputs are on the back of the unit as well as a 9-pin D-sub connector for remote A/B input switching, reset and status monitoring. The Failsafe Switching Gadget makes the switch between A and B inputs fully transparent with no clicks, pops or breaks in the audio. The active audio channel is indicated by bright red illuminated buttons on the front panel. When the unit loses power, it switches to the B input.
Angry Audio offers a handful of other ultra-useful appliances and cable adapters that simply make life easier. The construction and quality of the components make for clean and robust audio. Plus, the powder-coated finish and steel construction make the Angry Audio products aesthetically rugged and stylish. As Angry Audio grows its line of gizmos and gadgets, the “How am I going to do that?” factor for radio engineers will be more and more enjoyable.
Know of a product or a company that fellow readers should know about? Tell us at radioworld@futurenet.com.
PRODUCT CAPSULE:
Angry Audio “Problem Solvers”
Mic Tally Gizmo
+ Consolidates wiring mess
Price: $111
Guest Gizmo
+ Useful feature set
+ Strong amplifier
Price:$166
Failsafe Switching Gadget
+ Offers audio restoration options
Price: $222
For information, contact Angry Audio in Tennessee at 1-615-763-3033 or visit
https://angryaudio.com.
The post Angry Audio: Of Gizmos and Gadgets appeared first on Radio World.
Go on the Road With a Nomad
Field-measuring an FM or HD Radio propagation pattern is a time-consuming, mind-numbing task. It’s not quite up there with watching paint dry but it can be close.
The reason: Even with the latest in computerized data collection equipment, conventional measurements require an engineer to drive inside the antenna’s expected coverage area to collect real-time signal strength readings. This is a task that is repetitive, and can take hours to execute.
The collected FM/HDR measurements are then taken back to the station to create an accurate propagation/coverage map. If this map shows certain areas where signal strength is lower than expected — or that the antenna itself is not performing to specifications — then surprise! It’s time to send the engineer back out to take more measurements to verify the anomalies. (Only afterwards, when an accurate coverage map has been compiled, can work be done at the antenna/transmission site to remedy the problem.)
A piece of equipment called the HDR/FM Nomad Analyze promises to substantially reduce the amount of time associated with measuring and tuning HDR/FM antenna performance. It is made by Octave Communications, a Canadian engineering consulting firm that specializes in radio broadcasting, telecommunications and RF analysis measurement software.
Octave says the Nomad speeds up the field measurement process by having engineers create a “pre-simulation” model of the coverage site before conducting field readings using Nomad’s computer-based measurement system.
READY-TO-USE MAPS
“The presimulation incorporates the expected signal strength across the antenna’s coverage area, creating a predictive model ready to be tested before you hit the road,” said Francois Gauthier, Octave’s president.
“Once you are driving through the coverage area, Nomad compares actual signal reception points using its onboard radio receivers, and compares that data against the pre-simulation. If there are problems, the unit tells you, allowing you to take extra measurements right then,” he said.
Map showing the differences between the received signal level and the modelized signal level.“In this way, your field time is spent verifying the pre-simulation — including detecting and investigating anomalies — rather than collecting measurements to build a coverage map after the event,” Gauthier said. “The result is a time-saving, properly documented field measurement map ready to use back at the station, rather than raw data that still has to be compiled.”
Gauthier is a former DAB research engineer at the Communications Research Center in Ottawa and former director of broadcast systems and frequency engineering at Radio-Canada, among other professional credits.
NITTY-GRITTY
According to Octave Communications’ website, the Nomad measures the RF level of HD Radio sideband ratios to analog and interferer carriers along with analog FM RF level recording of each station along the entire FM band. The measured signals are marked on the pre-simulation’s map using WAAS/EGNOS satellites to access and record GPS locational data.
HD Radio metrics recorded by the Nomad (during field measurements) include:
● HD signal acquired
● HD digital audio acquired
● Digital quality
● PAD info (HD Artist, HD Title)
● Artist Experience graphics logging
● CD/NO
● Realtime audio recording (right channel analog and left channel digital) and geotagging for later analysis
FM/RBDS metrics recorded by the Nomad include:
● Analog RF level
● Multipath
● RDS loss
● RDS PI
● SNR
● Stereo indicator
● Realtime audio recording and geotagging for later analysis
The system is capable of logging up to five HDR/FM (analog) channels at a time. Nomad’s pre-simulation model can provide in-car engineers with real-time reports of unexpected RF drops, interfering channels and HD Radio sideband power ratio mismatches, among others. The measurement-loaded pre-simulation model can be downloaded in Excel-friendly CSV and/or Google Earth KML format reports.
Nomad’s pre-simulation is created by modelling the measurement area’s “spectrum picture” using propagation files uploaded from the Octave Propagation Model Cloud Service, which is based upon data the FCC, ISED (Canada) and Mexico broadcasting databases.
When problems are detected field measurements, the Nomad emits audible alarms to warn the driver. This allows them to take additional measurements on the spot, eliminating the need to return to the site afterwards.
“The actual Nomad unit is housed in a portable four-rack rigid case,” said Gauthier. “It comes with a built-in USB spectrum analyzer, a distribution amplifier to share signals received on the unit’s external antenna to the radio receivers in the box, and up to five HDR/FM Inovonics receivers. The software is loaded on the user’s laptop, which connects to the Nomad via a USB cable.”
USER RESULTS
When this article was written, Octave Communications had built four Nomads. Those have been getting serious usage and the results have been impressive.
The Canadian Broadcasting Corp. has been using an HDR/FM Nomad Analyzer after doing FM antenna rebuilds, to verify that actual propagation results match what the engineers had in mind.
“We’ve been using the Nomad for six months, and it is saving us a lot of time,” said Charles Rousseau, chief engineer of CBC/Radio-Canada’s Spectrum Group. “You can compare, in real time, what you’re measuring against the realistic simulation of field strength. Then, as an example, there’s an alarm that will ring if you’re 10 dB down your simulation. You can stop and see what may be wrong. Is that drop always happening in a certain azimuth? Was the antenna not properly installed?
“In the old way of doing things, we would only find out about a transmission problem once we were back in the office or at the hotel at night, and we would have to go back,” Rousseau added. “Since Canada is a large country, finding out about issues in the field after the fact cost us a lot of time and effort.”
GeoBroadcast Solutions is another user. The firm helps radio broadcasters maximize signal coverage and robustness through a number of transmission hardware solutions.
“We’ve been using the Nomad both in the lab and in the field,” said Bill Hieatt, the company’s CTO. “In the lab, the Nomad helps us gather measurements associated with the in-vehicle radio transmission test units we operate on behalf of our broadcast clients, where we can literally simulate signal fading and the impact of vehicle speeds without actually driving. In the field, the Nomad is useful in detecting problems like second adjacent channel interference, which is a growing issue as more HD subchannels are being turned on, and transmitter power is being boosted to cut through interference.”
Like the CBC, GeoBroadcast Solutions is happy with the Nomad’s performance, portability and time-saving capabilities. “The fact that the Nomad automatically measures second adjacent channels is a real advantage for us,” Hieatt said. “This unit helps us detect and discover problems that we might otherwise have missed.”
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FCC Reveals 60-Day Grace Period for IPAWS Update
EAS participants who are not able to update to the IPAWS certificate that was released on Oct. 28 by the deadline of Nov. 8 will not turn into the proverbial pumpkin when the clock strikes midnight, according to a Public Notice from the FCC.
In the notice from the Public Safety and Homeland Security Bureau of the FCC, it was revealed that there are specific guidelines regarding equipment readiness that will allow EAS participants to continue to operate without the impacted, required equipment for a period of 60 days after the Nov. 8 deadline.
The issue of this public notice came after FEMA and some EAS participants expressed concern over the timeframe from when the update was made available and the deadline that was set, saying that it was not sufficient time. As a result, the FCC issued the public notice to inform EAS participants about Section 11.35(b) of the commission’s rules, which allow for operations to continue “without the defective equipment pending its repair or replacement for 60 days without further FCC authority.”
As a result, EAS participants unable to make the IPAWS update prior to Nov. 8 will have until Jan. 7, 2020, to do so. In the event that they are not able to meet that deadline, an informal request for additional time must be submitted to the FCC and explain what steps have been taken, the alternative procedures being used while equipment has been defective and when the defective equipment will be repaired or replaced.
The update, and the subsequent operation without proper equipment in the situation of an extension, only applies to Common Alerting Protocol-formatted alerts distributed by IPAWS; EAS participants must still monitor, receive and process legacy EAS alerts formatted in the EAS protocol.
More information can be found in the FCC’s official Public Notice.
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Local U.S. Ad Revenue to Surge, Driven by Politics
Total local advertising revenue in the U.S. will reach $161.3 billion in 2020, up 5.8% from this year, according to BIA Advisory Services.
Commercial radio, with its still-significant reliance on local OTA advertising, should benefit from wider trends in local spending, including 2020’s election calendar. Although TV and online platforms will snag most of the political money in 2020, BIA said, radio will still receive about $312 million in local political ads.
[Read: U.S. Local Advertising Revenues Predicted to Increase 5.2% in 2018]
Across the board, “traditional” media revenue will account for 58.5% of total local advertising in 2020 at $94.4 billion, BIA believes. Online/digital revenue will grow to $66.9 billion, or 41.5% of total local media revenue.
“The expectation of an aggressive presidential election next year, along with primaries and statewide races, indicate that political ad spending will be a serious driver of local ad revenue next year,” said Mark Fratrik, chief economist and SVP at BIA Advisory Services, quoted in the announcement. “Combine these factors with the ongoing growth of mobile and social advertising and the emergence and future significant advancement in over-the-top advertising, the revenue landscape for next year looks robust.”
Among BIA’s findings:
- OTT locally activated advertising will be more than $1 billion and should double in another four years;
- Local political ads will total $6.58 billion overall next year, led by broadcast TV and online/digital media;
- Mobile spending is expected to be $29.5 billion, growing to $44.6 billion by 2024. Close to 40% of mobile spending will be tied to native social.
BIA Advisory Services projects “significant” ad spending in native social advertising next year. Social media ad revenues from all forms of mobile devices now represent about 93.8% of total social ad spending, BIA said, and will grow to nearly 96% by 2024 as more user activity shifts from desktops to portable devices.
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In the Matter of Use of Common Antenna Site, Modernization of Media Regulation Initiative
Broadcast Actions
Actions
Broadcast Applications
Applications
Pleadings
Sage Releases Rev. 95 Update for ENDEC
Sage Alerting Systems has released a new update for its Model 3644 ENDEC to make it functional for upcoming EAS changes. A validation certificate will be expiring making CAP message reception impossible for units not updated.
From the company: “The Rev 95 release includes a replacement for a security certificate used by FEMA to allow EAS devices to validate alerts. That validation is required by Part 11.56(3)(c). One of the certificates used to perform that validation will expire at 18:20 UTC Nov. 8, 2019. Rev 95 includes a replacement for that certificate, which was not released and approved for use until Oct. 30, 2019. To allow the ENDEC to continue to receive CAP alerts, you must install Rev 95 by November 8 at 1:20 p.m. EST.”
The company adds that the update is free for those who purchased their ENDECs after March 1, 2018. Earlier purchasers will need to buy the update pass from a distributor.
More information can be found here and downloading info can be obtained here.
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82 Small Broadcasters Weigh in on EEO Rule Changes
When it comes to improving broadcasting’s equal employment opportunity rules, any changes must simultaneously increase employment diversity while not overburdening small broadcasters with onerous paperwork and nonproductive actions.
Those are the comments from a group of 82 broadcasters who responded to the Federal Communications Commission’s request for reply comments on the commission’s EEO Compliance and Enforcement Notice of Proposed Rulemaking.
[Read: NAB Believes FCC’s EEO Rules Can Be “Streamlined”]
While the 82 broadcasters do not question the laudable goals of the EEO rules, they do doubt the necessity of what the group calls “burdensome paperwork and nonproductive actions.” As it stands today, the EEO rules require broadcasters to use a three-pronged approach to recruit for full-time vacancies, including the implementation of certain short-term and long-term recruitment initiatives, as well as the need to keep records on station compliance with those rules.
Those rules are a significant burden on smaller broadcasters, the joint broadcast commenters said.
“It is time that the FCC reassess its current documentation and paperwork approach to nondiscrimination and employment diversity,” the group said, adding that without detailed evidence that the current FCC paperwork and recordkeeping rules are reducing discrimination, it’s time for the FCC to direct its regulatory efforts to finding more effective ways to achieve the goals of nondiscrimination and employment diversity.
The 82 broadcasters advocate for proposed FCC rule changes to require all stations (no matter the size) to post job opening notifications on a recognized job seeker website, to revise the FCC’s EEO definition of employment unit to include all employees in the broadcasting entity, and to reduce EEO paperwork for small broadcasters by exempting entities with fewer than 50 full-time employees (instead of the current number of five).
The broadcasters propose that the burden of bringing diversity to the industry should be “placed upon larger broadcasters with human resource departments, rather than foisted upon smaller entities for whom just finding employees is a challenge,” the group said.
“The 82 broadcasters emphasize that they have no desire to lessen or diminish the FCC’s quest for diversity in employment and full and transparent opportunities for all job seekers in the broadcasting industry,” the group said. But the group said it is important that all broadcasters stand behind the FCC’s EEO program in both process and spirit.
“There is nothing more sapping to a small broadcaster than EEO paperwork and documentation that it is not staffed to handle, knowing that its larger competition has an HR department handling such record-keeping,” the group said.
The group of 82 broadcasters include the likes of Eureka Broadcasting Co. in Eureka, Calif.; Blakeney Communications in Laurel, Miss.; and Eastern Utah Broadcasting Co., in Price, Utah. The reply comments were filed in response to a series of comments left by ACA Connects, the National Association of Broadcasters and other EEO supporters.
Comments on the FCC’s EEO proposed rulemaking can be seen in the commissions’ ECFS database using Media Bureau Docket Number 19-177.
The post 82 Small Broadcasters Weigh in on EEO Rule Changes appeared first on Radio World.
Commentary: Buffer Compromise Would Boost FM Class C4
The author is CEO of SSR Communications, owner of WYAB(FM) in central Mississippi.
Matthew Wesolowski has told the FCC that hundreds of FM Class A stations would be able to double in power thanks to a Class C4, “and would gladly do so if given such an opportunity.”A proceeding currently before the Federal Communications Commission to provide eligible Zone II Class A commercial FM broadcasters an opportunity to upgrade from 6 kilowatts to 12 kilowatts has not attracted a great number of headlines this year, but that has not prevented the FM Class C4 proposal from making some significant strides as of late.
Most noteworthy, the Class C4 FM idea has attracted some powerful allies. In January, the proposal won the backing of Sen. Roger Wicker of Mississippi, sitting chairman of the U.S. Senate Committee on Commerce, Science, and Transportation, the congressional body that maintains direct oversight over the FCC.
Sen. Wicker noted that the power increase could be of particular benefit to “small and rural radio stations” in a letter to FCC Chairman Ajit Pai. In his February 2019 reply, Chairman Pai agreed by saying that the FM Class C4 option “could be especially important for small, minority-owned stations that currently cannot serve their entire communities.”
TURF WAR
Sen. Wicker now joins the list of approximately 130 small broadcasters who filed comments in full support during the FM Class C4 Notice of Inquiry (MB 18-184, FCC 18-69) filing windows in September, 2018.
Several years prior, FCC Chairman Ajit Pai first advocated for the new station class in September, 2016 at the NAB/RAB Radio Show in Nashville, Tenn., and going back further, the Multicultural Media, Telecom and Internet Council (MMTC) supported the effort in 2013 when it helped author the original proposal.
Predictably, a turf war has erupted between the small broadcasters that the FM Class C4 proposal would benefit, and larger license holders who generally control the biggest signals in any given market.
The National Association of Broadcasters did not support the introduction of a new station class, which is unsurprising, as that same organization vehemently opposed the creation of the FM Class C0 allotment type some 20 years earlier. Although larger companies stopped short of endorsing the idea fully, some nationwide broadcasters did come out in support of the FM Class C4 concept, including Educational Media Foundation, while iHeartMedia did not oppose the new station class in its comments.
The current sticking point in the FM Class C4 proceeding appears to stem from a component of the proposal that would give certain underbuilt Section 73.207-licensed stations a Section 73.215 designation, provided that the affected station has operated under its maximum antenna height, power level or equivalent thereof, for a period of 10 years or more.
Under the current FCC rules, a neighboring station looking to upgrade that is adjacent to an underbuilt Section 73.207-licensed station must treat that station as if it were fully built out, whereas a Section 73.215 station can be protected assuming its actual antenna height and power level.
The practice of treating underbuilt stations as if they were fully constructed can have large implications for smaller adjacent stations wanting to upgrade in power or situate their antenna sites more favorably. For example, a full FM Class C1 station is able to broadcast with 100 kilowatts of power from an antenna height above average terrain of 299 meters. If that station were to have an antenna height of only 200 meters above average terrain, then its primary service contour would be about 5 miles short of what a fully built FM Class C1 facility could reach. Any competing neighboring station looking to upgrade is compelled to protect that underbuilt station for five extra miles of coverage that it does not (or if underbuilt for more than 10 years, likely will not ever) serve.
BUFFER ZONE
In August 2019, SSR Communications Inc., which co-authored the FM Class C4 petition with MMTC, presented a revised version of the Section 73.215 aspect of the proposal to the FCC’s Audio Division.
The amended plan would still call for redesignation of certain underbuilt Section 73.207 licensed stations as Section 73.215 authorizations, but would also provide a 3 dB protective “buffer zone” to allow the affected stations an opportunity to relocate or build out more fully in the future. The buffer zone would create a protective bubble around underbuilt stations, usually amounting to anywhere from 3 to7 miles, depending on how severely underpowered or under-height the affected station may be.
This 3 dB buffer zone “compromise” would resolve the controversial aspects of the FM Class C4 proposal and should allow the proposal to advance.
The buffer eliminates almost all scenarios in which an affected reclassified Section 73.215 facility could be hemmed in and blocked from making future service improvements or tower relocations. It would also disincentivize the Section 73.215 conference procedure for stations seeking such towards neighboring underbuilt Section 73.207 facilities in almost all cases, except for those involving Section 73.207 stations that are the most decidedly underbuilt with respect to their class. Indirectly, the buffer prevents almost any scenario in which a secondary service could be affected by the Section 73.215 component of the FM Class C4 idea.
BREAKTHROUGH NEAR?
Meanwhile, an alternative waiver-based path towards a FM Class C4 equivalent facility may also soon exist. In July 2018, WRTM(FM) 100.5 MHz asked the Federal Communications Commission to consider allowing the station to double in power from 6 kilowatts to 12 kilowatts. If granted, the WRTM waiver application would establish new precedent and provide certain Class A FM stations an opportunity to enjoy an improvement in coverage.
Unlike the FM Class C4 proposal, the WRTM application (BPH-20180716AAC) suggests that, in order to double in power, a Class A FM licensee should guarantee that its upgraded signal would not impact vital LPFM and FM translator services. Also departing from the Class C4 FM proceeding is the idea that a neighboring Section 73.207-licensed station could still be reclassified as a Section 73.215 facility if it is not built out fully, but only if that station has been operating below its antenna height or maximum power level for a period of 30 years (the FM Class C4 proposal states that a 10-year window is appropriate). The WRTM filing backs this argument by saying, “No zoning problem, FAA issue, or cost consideration could not be resolved within 30 years if the desire is truly there to build out fully.”
Whether moving forward “as is,” as an amended proposal with a 3 dB buffer zone consideration, as a waiver-based procedure for eligible stations, or something else altogether, what will happen next in the FM Class C4 proceeding is anyone’s guess.
What is clear is, however, that hundreds of FM Class A stations would be able to double in power and would gladly do so if given such an opportunity. With support in high places, it seems as if a breakthrough is just around the corner, and it could be sooner than later that the FM Class C4 idea moves from concept to reality.
Comment on this or any story. Write to radioworld@futurenet.com.
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Beasley to Receive Award From Broadcasters Foundation
The patriarch and founder of the Beasley Media Group, George Beasley, will receive the Broadcasters Foundation of America’s Lifetime Achievement Award at the Golden Mike Award Gala, March 4, 2020, at the Plaza Hotel in New York.
Beasley started with an AM daytimer in Benson, N.C., in 1961, building his company into a top radio group owner with more than 60 stations in nine states. While the company is listed on the NASDAQ, family members, notably daughter Caroline and son Bruce, are closely involved in the day-today operation; making it seem more like a family-owned broadcaster.
Broadcasters Foundation of America Chairman Dan Mason said, “Starting off with radio stations in small market America and expanding to major cities, George built the company that bears his name with ingenuity, integrity, and innovation. We are delighted to recognize his leadership in our industry.”
The announcement quoted Beasley, “I fell in love with radio early in my career, and I have been fortunate to be a part of this wonderful business as it has grown and expanded.”
He added, “Giving back is an important tradition in our family, and it is an honor to support the mission of the Broadcasters Foundation to help those in our industry who need it most.”
Beasley has long been involved with the foundation, having served on its board for many years. He has been recognized with awards by several state broadcasters associations and inducted into many associated halls of fame.
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