WASHINGTON, D.C. — The FCC on Tuesday released a Public Notice inviting comments from the radio industry in a Petition for Rulemaking from a group of radio station and FM translator licensees who could be seeking something that some may see as a big evolution for the 250-watt Class D signal Chairman Ajit Pai has championed as an AM “revitalization” tool.
Introducing the Broadcasters for Limited Program Origination, and they believe a GeoBroadcast Solutions LLC “Zonecasting” plan opens up an FM translator’s ability to originate limited programming content, too.
The group is comprised of 24 FCC licensees, who together own 108 full service radio stations and 85 FM translators.
The Petition for Rulemaking asks that if the FCC considers allowing FM booster stations to originate limited programming content to provide zoned programming to a primary station’s service area, key to the proposal submitted by GeoBroadcast Solutions, the same opportunity for limited program origination should also be afforded to FM translator stations.
It’s a big stretch. Until now, the Commission has remained largely steadfast in its insistence that an FM translator rebroadcast in full a HD multicast signal, or an AM radio station. When asked if it could originate programming for any reason, or in instances where this was found to be occurring, the Commission has been adamant in saying no and ordering an immediate cessation to such use of a translator.
And, some may argue it could greatly change the playing field between a Class A and an FM translator, while further diminishing the LPFM, depending on the market dynamics.
What does the Broadcasters for Limited Program Origination request? Simply, “a uniform FCC rule change for both FM boosters and FM translators” is warranted, they say. In their view, both services should be allowed to originate programming content, provided that the primary station is retransmitted for no fewer than 40 hours in any calendar week.
In another view, an FM translator need only 100% simulcast its originating station for less than six hours per day, across a given week.
This will certainly be open for debate, as the remaining 18-plus hours of a translator’s broadcast day could be unique.
Yet, the push for limited program origination from the FM translator licensees appears to center on localized advertisements, and the “addressable” promise to clients and media buyers that the radio industry has been clamoring for in the face of digital media and NEXTGEN TV’s rollout.
“The Broadcasters for Limited Program Origination observe that some radio stations may choose to broadcast different localized advertisements,” says John Garziglia, a Womble Bond Dickinson attorney who is widely viewed as one of the nation’s top communications lawyers. “Other stations may broadcast localized city council meetings for two or more communities in their coverage areas. Some broadcasters may determine what serves a particular station’s listeners are multiple localized high school sports games. Or, another broadcaster in a diverse area may broadcast two different kinds of ethnic entertainment programming at certain times of the day.”
Is this what an FM translator, as intended by the FCC, can provide?
The Broadcasters for Limited Program Origination say yes.
“The Commission has long encouraged diverse programming content,” they state in their petition. “If FM booster stations are allowed a regulatory easing on content choice, then so also should FM translator stations be equally allowed to choose whatever programming their licensees best think would serve their listening audiences for limited portions of the broadcast day.”
Meanwhile, because the FCC’s new FM translator interference rules have re-defined the coverage contours of FM stations, the Broadcasters for Limited Program Origination advocates that extended coverage contours out to the greater of the 45 dBμ contour, or a 25-mile radius from the FM translator transmitter site, should now apply to what is regarded as a fill-in station for the purposes of the FM translator rules.
That will also likely generate counterpoint argumentation.
There’s also one last request from the group: Instead of an FM translator call sign as seen today (for example, W252BA designating the Class D FM translator at 98.3 MHz used by Spring Arbor University’s WJKN-FM 89.3 in Spring Arbor, Mich.), four-letter call signs with the suffix “-FX” should be implemented for FM translator stations that originate limited programming content.
For those that have something to say about the proposals, statements in support or against what is formally designated RM No. 11858 need to be sent to the FCC by the end of day, Eastern time, on July 23.
The FCC’s June 23, 2020 Public Notice requesting comments is available at: https://ecfsapi.fcc.gov/file/06230912321604/DOC-365103A1.pdf.