Broadcasters Disagree on Proposal for New A-10 FM Class

Large and small broadcasters, engineers and low-power FM interests disagree about whether the FCC should create a more powerful group of Class A FM station known as A-10, according to comments posted in docket 24-183. Due Monday, the comments responded to a Commander Communications petition (see 2406200052). Many smaller broadcasters support the proposal, but Cumulus and NAB said it could increase interference at other stations. Common Frequency and REC Networks said the proposal must be paired with one allowing increased power for LPFM stations. Multiple commenters, including Commander, said the petition contains technical errors in its calculations of separation distances, but those discrepancies could be adjusted. “Commander believes that the Commission could easily correct these spacing values and that the underlying concept of the FM Class A-10 station would not be affected negatively,” Commander said in a comment filing.

Allowing Class A stations to upgrade to the higher power A-10 class would help local outlets reach larger audiences, increase diversity of voices, and help cover isolated rural areas, filings from numerous small broadcasters, the Multicultural Media, Telecom and Internet Council, and Rep. Bennie Thompson, D-Miss., said. In his state, wrote Thompson, “more than thirty stations could have more power to serve the mostly rural areas with news and lifesaving weather information.” MMTC said the proposal could help increase “the dwindling numbers of minorities and women owning commercial broadcast stations.” A power increase could be an affordable way for stations in rural Appalachia to overcome signal loss due to difficult terrain, Total Media Group said.

“Hundreds of FM Class A operators would be able to realize improvements in coverage,” if an A-10 class were allowed, Commander said. “We believe that only a subset of stations that could potentially upgrade are likely to do so because of the expense,” NAB said. REC Networks found about half of the 1,400 Class A FM stations would be eligible for upgrade under the proposal, and 26% of those could be mutually exclusive.

Allowing the A-10 Class could increase the FM noise floor, threaten FM translator stations and undo the FCC’s AM Revitalization efforts, said Cumulus, which owns numerous AM stations. “Operating these upgraded facilities would elevate the band’s noise floor and degrade FM quality for all,” Cumulus said. REC Networks found that if all the Class As eligible for A10 upgraded,10%-20% of LPFM stations and just more than 12% of FM translators would experience interference. “REC did not highlight alternate channels or other engineering remedies available to these secondary services in its study, of which there would be many,” SSR Communications said.

Class A FM stations are a primary service and FM translators and low-power FM stations are secondary, so AM broadcasters with translators could have their translators displaced by stations increasing their power under the A-10 proposal, according to Cumulus. A-10 “would on the whole be a derogation of overall broadcast service, particularly for AM licensees reliant upon their cross-service FM translators,” Kaskaskia Broadcasting and Miller Communications said in a joint filing. “I question that number of stations that could qualify for A10 power increases balanced against the impact to secondary stations,” TZ SawyerTechnical Consultants engineer Tim Sawyer said.

NAB said the petition didn’t offer sufficient technical information for the trade group to take a position. The FCC, it added, should consider the same interference risk issues and the crowded FM band that it did during the last proceeding for an increased power radio class. That proposal, by SSR Communications for a C-4 FM class, has been stalled at the FCC since 2016. NAB opposed it (see [Ref:1809110051).

LPFM entities REC Networks and Common Frequency said they would support the A10 proposal only if it were paired with REC’s proposal -- which has been sitting at the FCC in one form or another for more than a decade -- for increased LPFM power levels, sometimes called “LP-250” or “Simple 250.” A single rulemaking on A10 and Simple 250 would “promote the ongoing relevancy of radio,” and ”improve the rural quality of life,” said REC. If the proposals aren't paired, REC and Common Frequency said they would oppose A10 because it would mean increased interference for LPFM stations. “Perhaps Class A10 may be viable if LPFM were able to have tools to solve its existential interference and displacement issues,” Common Frequency said.