Cumulus Media is asking the FCC not to create a new FM station class called Class A10.
“Class A10 poses an unacceptable risk of increased interference at a time that stations face an elevated risk of losing listeners to alternatives to broadcast radio, would harm LPFM stations and FM translators especially those that are licensed to AM stations, and thus would disproportionately affect minority owned stations,” the company told the FCC in its filed comments.
[Related — “NAB: We Can’t Endorse a Class A10 at This Time”]
Cumulus is the parent of about 400 U.S. radio stations in 85 markets. It was commenting on the proposal from Commander Communication Corp. to create an FM station class with a maximum of 10,000 Watts effective radiated power and 100 meters height above average terrain.
Commander hopes it would allow hundreds of Class A stations to increase power and that the idea would be simpler and more feasible than a previously proposed Class C4.
But in comments signed by Chief Technology Officer Conrad Trautmann, Cumulus said a Class A10 would create unacceptable congestion to the band and interfere with translators and LPFM stations. “Protecting signal quality has never been more vital to retaining listenership,” the company said.
“The public today has access to multiple alternatives to terrestrial radio. Listeners who face difficulty tuning in can readily access audio programming through different devices and platforms. Interference jeopardizes audience retention. Class A10 will further congest the already crowded FM dial.”
It noted that REC Networks has estimated that 1,414 stations have a path to upgrade to Class A10.
[Related — “REC Asks FCC to Pair Class A10 With LP250”]
“Operating these upgraded facilities would elevate the band’s noise floor and degrade FM quality for all. The contour protection system is inherently inefficient. It is well established that contours are not determinative of actual reception.”
Citing comments filed by iHeartMedia about the earlier C4 proposal, Cumulus said that stations broadcast interfering signals over much greater distances than the extent of their service areas. Class A10 stations would create “islands of service in the midst of seas of interference,” Cumulus argued. “They would contribute to the evolution of the crowded FM band into many small and interference-ridden signals rather than high quality services, that is, the ‘AM-ization’ of the FM band,” again echoing earlier comments from iHeart.
This, Cumulus said, would risk the integrity of the FM band and harm its development by degrading service and steering listeners to alternative platforms.
A new class would also harm existing stations that may otherwise be able to increase their facilities within their class or relocate when necessary for various reasons such as damage to a tower or expiration of a lease.
“Weather conditions are making it increasingly likely to encounter equipment problems and/or destruction of a tower. Finding a new tower site is already difficult and the added congestion caused by the proposed Class A power increase will just add to that congestion and limit the ability of existing stations to relocate when forced to do so.”
Cumulus also warned that adding classes in a “piecemeal” approach would just prompt requests for yet more classes, “each with a small but significant power increase … This is not an efficient way to manage the FM spectrum, which has already been overcrowded with the proliferation of FM translators and LPFM stations.”
And it noted the estimate by REC Networks that 12.7% of FM translator and 10.6% of LPFM facilities could suffer new or increased interfering contour overlap. “The burden to this sizable number of stations is potentially destructive to the continued existence of these stations.”
The potential harm of Class A10 to FM translators, it wrote, would also undermine the FCC’s efforts to help AM stations. It quoted comments filed by NAB: “Translators have been a boon for many AM stations, if not the difference between staying on the air and going out of business.”
