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Translator Rules Revisited
A little over a year ago, we looked at some the history behind FM translators and gazed into a cloudy crystal ball. Fast forward to now. While the crystal ball is still a little cloudy, a couple of important events have happened in the life of translators that warrant some discussion.
It is an undeniable fact that the change in the permissible service rules of FM translators to allow fill-in service has been a boon to AM licenses. The demand for translators by AM stations has also generated substantial new interest in these secondary facilities. The effect a fill-in translator can have on the value of an AM station, especially a Class-D facility, is huge.
Because there is no free lunch, we, as expected, are seeing more cases where the interests of fill-in translator operators are pitted against their colleagues or competitors in the same or adjacent markets. Despite the obvious benefits these translators provide to their communities, they still retain their secondary status, which means they cannot cause actual interference to the regularly used signals of full-power FM facilities. Thus, a 3kW class A that is under height and 50 miles from the location of your translator, can complain about your interference, while it would have no leg to stand on should a similar level of interference come from an authorized full power station operating according to the terms of its license.
That being said, many licensees have been able to construct fill-in translators that will likely enjoy long-term survivability. In some cases, the end state of the translator was finally reached after several hops or relocations. In others, the moves are still ongoing with the end result yet to be realized. While large changes in the location of a translator are not strictly prohibited by the Commission's rules through hopping, this practice has been abused by a number of entities over the past several years.
A minor change
Under the current rules, a minor change involves a change in frequency of plus or minus three channels, plus or minus 53 or 54 channels, or a change in location where there is common overlap of the 1.0mV/m service contours. It should be noted that any change in frequency for an un-built translator that moves the facility from the reserved to unreserved portion of the band, or vice-versa, is considered major regardless of how small the change in frequency is.
Hopping occurs when the translator is moved to a new location through successive minor changes to avoid a making a single major change. The Commission is not fond of this practice, and has alluded to the imposition of restrictions on such activity in the future. This can be problematic since on the one hand the use of translators to fill-in AM facilities is promoted. On the other, however, the relatively small footprint of a translator coupled with the coverage overlap requirement has hampered some relocation efforts to fill-in AM facilities.
One solution to this dilemma has been for the Commission to waive, in certain instances, provisions of section 74.1233 of the Rules. This is the section that describes major and minor changes to translators. The first of these narrowly defined waivers was granted to a translator in Central Illinois that sought to relocate to a site that would not have met the 1.0mV/m contour overlap requirement between the proposed and licensed facilities. The Commission agreed with the contention of the applicant that this move was nevertheless in the public interest because of four specific conditions.
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