Small Broadcasters, NAB on Opposite Sides of C4 NOI
More than 100 small radio broadcasters want the FCC to create a new C4 class of full-power FM stations, which NAB and some larger groups oppose. C4 will "increase congestion on the already crowded FM band and escalate the risk of interference to other FM services, especially FM translators,” NAB commented in docket 18-184 in response to a notice of inquiry. “There is no chance of increased interference as a result of the proposal,” said SSR Communications, the petitioner behind the C4 proposal. The plan would consume only “previously-unused, available bandwidth,” SSR said.
Since the NOI was announced and before Federal Register publication, filings supporting the C4 plan from individual broadcasters have been trickling in, some apparently based around text circulated as part of a campaign by SSR (see 1806190056). Broadcasters such as Tennessee-based Southern Stone support the new class because it will allow them to upgrade their facilities. Davis Broadcasting wants the upgrade option but said the new class would help many minority-owned radio stations. AM licensee Charles Tillman compared the C4 idea to AM revitalization and supports it out of solidarity: “As was the case in my situation, I ask that the FCC grant relief to my fellow small broadcasters.” Support from individual small broadcasters is “overwhelming evidence for the demand for this change,” said SSR.
C4 would be “a step backward for the radio industry at a time when radio stations are working through any number of interference issues,” NAB said. Stations upgrading to C4 would threaten nearby translators and cause complications for commission efforts to fix translator interference, NAB said. It asked the regulator “to close this proceeding after the comment period.”
Several larger radio groups including Beasley Broadcast, Delmarva and Bryan refiled comments from 2011 opposing the proposal. Though iHeart Communications’ previous incarnation, Clear Channel, was part of that joint filing, iHeart filed separately and said it's reserving judgment. HD radio company Xperi said the new class would increase the FM band’s noise floor. “Given the maturity of the FM service, the Commission must balance the benefits to FM service coverage that an increased density of signals could provide against the potential to degrade reception for stations in areas where there is currently a listenable signal,” Xperi said.
C4 “will enable many FM broadcast facilities to significantly improve their service areas without impacting the actual service areas of other stations,” SSR said. It identified 22 conflicts between stations that would immediately be able to upgrade to C4 under the proposal and low-power FM stations or translators. “An engineering remedy existed to clear the overlap,” SSR said. Begin issuing waivers to let stations transition to the new class before an NPRM and order, SSR asked. The agency could make such waivers conditional on applicants showing no potential negative effect on nearby secondary services.
Wait to create the class until after acting on proposals to improve low-power FM, said the LPFM Advocacy Group. The type would allow “even more new interference to the nation’s lowest powered, most minimally funded, FM service,” the group said. “Strike a balance between the expansion of primary FM services and the unique services provided by LPFM stations as well as the services provided by FM translators,” said REC Networks, which said the new class could be allowed as long as protections are sufficient for LPFM.
Many denounced a secondary part of the NPRM, to allow the FCC to involuntarily reduce interference protection for FM stations that aren’t performing at their allowed level. That “would be deleterious to the public interest,” iHeart said. “This will only lead to more overcrowding in the FM band, degrading service and preempting the use of translators in areas in which they can now currently operate without interference,” said the Educational Media Foundation. SSR said the proposal would free up spectrum facing competitive demand.