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Skywaves formally objects to the new FCC FM translator interference rule
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Skywaves Comments on new FM Translator Interference Rule

08-04-2019
Skywaves formally objects to the new FCC FM translator interference rule
Skywaves objects to the new FM translator rule:
  

Skywaves undertook a major industry-wide study of the effects of this new rule on existing full-service stations, translators, and LPFM stations. The rule protects the 45 dBu contour of all licensed FM, FL, and FX stations.

Our database includes the normally-protected and 45 dBu f(50,50) contours of those stations.  

Using the normal interference ratios of -20, -6, and +40 db for co-channel, first adjacent, and second/third adjacent situations, we generated the 25, 39, and 85 dBu interfering contours of all licensed FM translators.

Once the contours are developed, it is possible to check for overlaps. 

Only 5% of all licensed translators are fully protected under this rule.

The rule provides new pathways for full-service and previously authorized translators and LPFMs to create inteference claims against translators.

Anyone who thought the rule would provide any sort of balance between translators and other interests is badly mistaken. The proposed rule used a much more reasonable protected contour of 54 dBu, but apparently the FCC acceeded to full service broadcasters who argued that they have listeners out to 45 dBu and farther. 

Oddly, the new rule prevents full-service and previously-authorized translators and LPFMs from filing interference claims within their own protected contours. This is a total departure from the "translators as secondary services" regime, and seems to be an unintended consequence of the proceeding's concentration on outlying areas.

 

Dave Doherty
Principal Consultant
Skywaves Consulting LLC
PO Box 4
Millbury, MA 01527-0004
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