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Possible changes to expanded-band rules
The FCC has been asked to consider liberalizing its current rules governing use of the expanded AM band (1,605 to 1,705kHz) by allowing increased power and the use of directional antennas.
Broadcast historians will recall the FCC's years-long effort to clean up the AM band by making available virgin spectrum beyond the original upper limit of the AM band to licensees who were willing to migrate their stations up to that new spectrum. The idea was to reduce congestion — and its natural by-product, interference — in the lower portion of the band. When the dust finally settled after years of rule makings and re-location efforts, the results were somewhat limited: only 65 stations made the move (or committed to make the move).
In setting up the expanded-band opportunity, the Commission sought to avoid the shoehorn approach which complicated AM allocations for the better part of a century. Rather than permit expanded-band stations to use directional arrays and a range of powers to snuggle themselves into tight locations between or among adjacent stations, the Commission opted for a more FM-like approach based on distance spacings, omni-directional operation, and uniform 10kW (day), 1kW (night) power limits.
Now three expanded-band pioneers have filed a petition for rulemaking asking the FCC to amend its rules and afford Class B status for stations operating in the AM expanded band. In particular, the petitioners have asked for the elimination of the limitations on power and the prohibition against directional antennas. According to the petitioners, those revisions would "enable expanded band stations to respond to market forces," which presumably means that the changes would make it easier for such stations to go after listeners they can't presently reach. According to the petitioners, the changes would also help alleviate the second-class status of expanded band operators. That status, they say, arises at least in part from the fact that ground conductivity--a key factor in determining the reach of an AM signal--tends to be worse for higher AM frequencies than for lower ones. While expanded-band licensees could theoretically already seek waivers of the existing power and directionalization limits, the petitioners claim that eliminating those provisions would relieve the FCC's staff of the “burdensome task of evaluating multiple waiver requests.”
Of course, any such relief would presumably be offset, at least partially, by the added burden of processing modification applications that would likely require essentially the same staff analysis as would waiver requests, so that potential benefit may not that great administratively. Moreover, to the extent that reliance on power increases and directional antennas might result in increased potential for interference to other stations, such reliance might also trigger more petitions to deny or other objections, thus imposing an even greater burden on the Commission's staff.
For the time being, the Commission has taken no action on the proposal. But the Commission has gone so far as to issue a public notice alerting the public to the fact that the petition was filed. The issuance of such a notice is often the first step toward a rule making proceeding, so the petitioners have apparently succeeded in getting the ball rolling. It is not surprising that the FCC is interested in the proposal given the lack of success of its expanded-band program to date. Anyone with more than a passing interest in AM technical standards--and particularly anyone with an expanded-band license or with a station near the expanded portion of the band--should probably keep an eye out for further developments on this proposal.
April 1 is the deadline for radio stations in Texas to file their renewal applications, biennial ownership reports and EEO public file reports. Also on April 1, stations in Michigan and Ohio must begin broadcasting their pre-filing announcements in anticipation of the June 1 renewal filing date for stations in those states.
Martin is president of the Federal Communications Bar Association and a member of Fletcher, Heald and Hildreth, Arlington, VA. E-mail firstname.lastname@example.org.
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