11-6-2013
I applaud FCC Acting Chairwoman Mignon Clyburn, Commissioner Ajit Pai, and the commission as a whole for their swift action in compiling and releasing the Notice of Proposed Rule Making for revitalizing the AM broadcast service. There are many good proposals put forth in the document and I encourage all to take the time to read, and hopefully comment, on the contents therein. It truly appears that the cause of getting AM ?reloaded? is gaining traction.
After reviewing the NPRM, I can say there is a lot of good that can come from these proposals if enacted. Probably the quickest and most beneficial of the proposals, is that of the ?AM exclusive window? to allow AMs to apply for FM translators. While of tremendous benefit to those who will be able to attain them, this proposal is not without its limitations. Those in congested markets will readily acknowledge that there may be no available spectrum to find an open channel for a ?fill-in? translator, especially after the current LPFM window closes. However it is an effort that offers one of the best chances for current AM facilities to better reach their audiences and will help many from coast to coast.
In reviewing the NPRM, some additional considerations immediately come to mind. As the intent is to protect and improve the role that many of these AM stations serve, or could serve, for their communities, the most effective, equitable, and useful application of translators should be considered. The NPRM touches on this issue in taking into account that these ?fill-in translators? may have to be rationally allocated in ways that provide the best result to the communities served. That realization may need to be prioritized towards those stations having the most challenging technical and viability issues confronting them in providing service. Should stations with little-to-no night service or AM-only stations have first priority in applying for this potentially scarce broadcast spectrum? If an AM-only is granted a translator, can the station be acquired by, or LMA?d by, larger operators that will use them to ?AM simulcast? their HD2/3 through the AM ?fill-in? FM translator? Would that defeat the purpose of an ?AM exclusive window?? However there also has to be a balance in regulation to allow the market to be competitive and responsive to audiences, and viable to operators, correct? Certainly there is a case to be made that AM-only or severely compromised, underpowered, daytime-only stations are in a more desperate situation than AM/FM combos or large group operators are. Issues such as these, whether obvious or as yet unforeseen, are why we should all make comments for debate and hopefully end up with a better outcome from the eventual rule-making.
Looking to the future, and after rules are established, there will still be issues to be addressed, including with FM translators for AM. A proposal worthy of investigating is allowing smaller, signally disadvantaged AM stations that have successfully implemented an FM translator and now better serve an equal or larger part of their community to turn in their AM license. A new class of station allocation that would allow ?origination? on the translator would have to be established, but it would allow for reduced congestion on the AM band, allowing many remaining stations the ability to improve their facilities and/or simplify their transmission systems and reduce costs.
There are still many more considerations that will come about in response to this NPRM and there are many who are eager to see how things shake out. With many more ideas likely ?waiting in the wings,? I urge interested parties to bring them forth. There is no doubt now that the FCC ?gets it,? is off to a good start, and has tossed the ball back to us. It's time to knock it out of the park.
Dave Webster is the CEO at VSI|HD Media Services in Southington, CT and can be reached at David Webster DWebster@vsimedia.com
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