FM translators

This is a response to a letter to Radio World by Daniel Brown, Zebra Radio who was responding to Michelle Bradley of REC's previous letter to Radio World.

REC Networks has filed comments opposing RM-11858, the Petition for Rulemaking originated by “Broadcasters for Local Program Origination” (BLPO).  The BLPO petition called for FM translators to be able to reak off of their primary stations to provide separate programming for up to 128 hours per week, use special call signs with an “-FX” suffix, only be required to broadcast 40 hours of “translated” programming per week from the primary station and to allow commercial FM broadcast stations be permitted to extend commonly owned or financed translators outside of the primary station’s service contour (60/57/54 dBu) to 45 dBu.

REC Networks has had a chance to review the language of the Ask Musicians For Music Act of 2019 or AM-FM Act as submitted by Rep. Jerrold Nadler (D-NY-10).  

The intention of the bill is to put into place a method where the recording industry would obtain payment in connection with music played on terrestrial radio.  Historically, radio has been on a statutory exemption as it was perceived that radio acutally promotes music.  When you look at today's post 80-90 environment with stations so heavily narrowcasted and the lack of local talent (i.e. DJs) and more of a public expectation of "more music and less talk", especially when faced with competition by "non-radio" (streaming) services, with the exception of a small number of noncommercial and commercial stations that still care about the music, radio is not promoting music. When was the last time you heard a DJ say what label a certain song is on?  For many years now, the recording industry had relegated that task to Walmart.  

In the Petition for Reconsideration filed by The LPFM Coalition (LPFM/C) in MB Docket 18-119, the translator interference proceeding, LPFM/C raises some very excellent points in respect to the decisions made by the Commission in the proceeding. 

While FM translators must protect existing LPFM stations using prohibited overlap, it is REC's position that the disparity between LPFM's use of distance separation and FM translator use of the contour model does raise an LCRA Section 5 issue where translators are overprotected by LPFM stations by as much as 10 times the area that they are entitled to in cases where a translator's directional pattern can be used to protect an LPFM but LPFM stations must protect a translator as they are a non-directional facility.