Prometheus Files To Stop FM Translator Change

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The Prometheus Radio Project has officially filed a petition with the FCC asking the government agency to reconsider the change being made to the rule that limited the placement of an FM translator such that the translator’s 1 mV/m contour is not extending beyond a 40-mile radius from the AM station. Prometheus, which represents LPFM radio stations, wants the Commission to revert back to that rule. Here’s why.

Prometheus says countless incumbent LPFM stations that are outside the core service area of AM stations will now be severely limited when seeking to relocate within their communities of service because new and relocated FM translators will inevitably box in or short-space them. “Because the FNPRM did not contemplate abandoning the Commission’s commitment to limiting translators to an AM station’s core service area, and in fact reaffirmed its commitment to do so, the Order’s removal of the 40-mile distance restriction is not a logical outgrowth of the FNPRM’s proposal.”

Prometheus goes on to say that the Commission’s justification for this modification incorrectly conflates “core service area” with “primary service area,” two distinct and drastically different concepts. “By failing to give notice of any intent to eliminate set distance limitations, the Commission did not provide opportunity to develop a record as to the impact of this change, which will inevitably lead to increased vulnerability of countless LPFM stations beyond 40 miles from AM stations. Moreover, the Commission’s Order is arbitrary and capricious because it does not consider, much less resolve, the question of the adverse impact that the Order will have on LPFM raised by Prometheus in its ex parte presentation on February 16, 2017. By removing any set distance limit, the Order will elevate commercial AM interests to the detriment of incumbent non-commercial LPFM stations. This demeans local, diverse, non-commercial broadcasting in a way that is contrary to the Local Community Radio Act. At no point in the Order did the Commission address these inconsistencies or rebut the contention that incumbent LPFM stations will be chained to their current location as the gaps around them are filled by cross-service translators.”

Finally, Prometheus says, the Commission falsely equates the public interest value of smaller commercial AM radio with intensely local non-commercial LPFM service. “LPFMs’ diverse, locally-focused content that is not subject to commercial interests is vitally important to the listeners in the local communities that LPFM stations serve, and cannot be replicated by market-driven commercial AM stations that are likely to be primarily focused upon serving other, relatively distant communities.”

Read the entire Prometheus filing HERE.

3 COMMENTS

  1. There is not agreement in the LPFM community re: this translator proposal (see REC’s support of it). LPFMs are de facto secondary to translators (lower power, different protection contours); if LPFMs are allowed under one proposal to increase to 250w, that will help a little.

  2. I had to wait til LPFM’s got two bites of the apple before I got my first taste. And now Prometheus expects their constituency to be protected from all their future possible woes. “Immediate harm” for something that may or not happen. I have two LPFM’s preventing my little translator from being all it can be and neither is on the air and in fact both filed for a license to cover at the deadline with nary an antenna in sight. If LPFM hadn’t gotten a second crack before me, I would be 250 watts now. And of course, pinning in some poor satellite religous station from a transmitter move.

  3. What Prometheus is up to is trying to stop the next window opening up for those AM stations who didn’t buy a translator last year. This window will allow those AM stations to apply for a new translator license. Ahead of that window the Commission opened up possible translator locations, effective 4/10. Here’s the actual rule at Section 74.1201(g):

    “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.”

    And then the deliberate confusion begins. Most AM stations in the east will have a hard time getting their 2 mv daytime contour out 25 miles, let alone the “40 miles” that Prometheus hyperventilates about. The local 5 kw non-d AM only does around 15 miles. More to the point, any new translator will have to protect co-channel and first-adjacent channel LPFM stations, so there is little danger that any LPFM will be forced off the air.

    And they are already dropping like flies for other reasons–we have 6 LPFM’s licensed in our area but 2 are off air (one lost their tower, I believe), one off-air under an STA, one sits on a satellite feed, & one is running some kind of strange back ground music. Only one is being programmed, that being a station we helped build at the local community college.

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