But he says the FCC should keep a rule codifying “last in time, first responsible”
The NAB supports several proposals for changes to American radio technical regulations. But he opposes a change he says would undermine interference protections.
The Federal Communications Commission adopted a regulatory proposal notice in July that identifies seven technical rules it wants to eliminate or revise. As we have reported, various technical observers who have commented on Radio World have stated that they consider these changes to be beneficial.
Now the National Association of Broadcasters has weighed in.
He asked the FCC to stipulate that rule changes will not result in violation of existing stations and that all negatively affected stations should be grandfathered to avoid being forced to modify operations.
With this caveat, the NAB supports most of the proposed changes: it said the FCC should remove the maximum power rating limit for AM transmitters; clarify and harmonize the definition of the coverage of the NCE-FM license community; harmonize the second adjacent channel protection requirement for Class D FM stations; eliminate protection for the operations of mid-band public carriers in Alaska; and modify the definition of “AM infill zone”.
But he also identified a few areas of potential concern.
He wants the FCC to grant grandfathering rights to the operation of any stations near the Canadian or Mexican borders that may become closely spaced or otherwise non-compliant as a result of the changes. He also said the commission should clarify how the distance figures in the rules for cross-border stations are to be calculated.
Finally, the NAB explained why the FCC should not eliminate the regulatory requirement to consider “nearby” transmission facilities.
In this proposal, the commission wants to eliminate a rule according to which applications proposing the use of FM broadcast antennas in the immediate vicinity (60 meters or less) of other FM or TV broadcast antennas must include “a demonstration of the ‘expected effect, if any, of such an approximate operation. The FCC believes this is unnecessary because broadcast radio antennas in this situation are unlikely to create interference issues if they are otherwise compliant. He calls out the rarely used rule and says it rarely prevents interference.
The NAB disagrees and says the requirement provides an important legal tool for defining interference protection rights.
He said the rule helps ensure that intermodulation distortion products are not generated and radiated as a result of a new station co-located, or nearly co-located, with existing stations. He stated that IMD is a common result of collocation, especially when an FM coexists with other FMs or Channel 6 stations, and that it can cause interference to other stations as well as to the aviation and mobile telephony, including public safety.
“It is essential that such interference is anticipated, considered and corrected before the start of regular broadcasting,” he told the committee. “NAB believes that removing the rule is like asking applicants not to worry about the potential effects of their operation on existing stations. “
Eliminating the rule could also blur the question of whether a station for newcomers is responsible for the correction. “A policy does not have the same weight as a rule, and the NAB believes that Section 73.316 (d) provides important legal ‘teeth’ to its long-standing, but uncodified, policy with respect to responsibility of newcomer stations to correct any problems they create. . “
The NAB believes that the commission needs an enforceable rule codifying its “last in time, first responsible” policy.
[Read a PDF of the NAB filing.]