Classical change in Washington DC

[Scott Fybush]

A. Joseph Ross wrote:
> On 24 Jan 2007 at 14:16, Scott Fybush wrote:
> 
>> What's more, the FCC's inane "ratchet rule" would come into play, 
>> negating any nighttime improvement WTOP would get as a result. (I'm on 
>> my way into work for the rest of the day, so I'll leave it to our 
>> Esteemed and Recuperating Moderator to further explain that one.)
> 
> What's a "ratchet rule"? 

I was hoping Garrett would rise to the bait on that one, but he didn't, 
and I need to get to bed. In a nutshell: in a misguided attempt to clean 
up interference on the AM dial a few years back, the FCC adopted a rule 
that required AM stations making voluntary changes to their nighttime 
facilities to be able to demonstrate that the change would reduce the 
amount of interference caused to other stations by 10%. The intention 
was good, but the outcome was not. The new WOR is an excellent example. 
Because its move to a new site was not considered an "involuntary" move 
(though in that particular case, with its old site lost to development, 
it might have been able to make such an argument), WOR had to put some 
otherwise unnecessary nulls in its new night pattern to satisfy the 
ratchet rule and reduce nonexistent interference to a Canadian station 
that doesn't even exist anymore. And the existence of the ratchet clause 
has kept a number of AM stations from moving at all, since any new 
facility will almost inevitably end up with less coverage than an 
existing one. It's bad engineering and bad regulation, and deserves to 
be scrapped.

To answer the other question on the table - an allotment, in FM terms, 
is - or was, until just this week when the rules changed - the line in 
the FCC's Table of Allotments, enshrined in the Code of Federal 
Regulations, that specifies which FM channels may be used at which 
classes in which communities. So the table listed, for instance, 238B 
for Providence, which meant that a class B station could exist on 95.5 
(channel 238) in Providence. Most any change to a station's class, 
channel or city of license was considered a major change, because it 
changed the Table of Allotments.

The new rules shrink the Table of Allotments so it lists only channels 
that are available but for which no construction permit or license 
exists. Under the new rules, WBRU could change channel, class or even 
city of license as a minor change, so long as the rest of the FCC's 
regulations (on matters such as channel spacing, city of license 
coverage and equitable distribution of service) are met.

Real-life example: under the old rules, WXRV had to first petition for a 
change in the Table to remove the allotment for 223B at Haverhill MA and 
add an allotment for 223B at Andover MA. Only then could WXRV actually 
apply to change city of license. Under the new rules, the whole move 
could be filed as a one-step minor change, though with most of the same 
paperwork that the two-step move required.

s