HD subchannels

Garrett Wollman wollman@bimajority.org
Fri Aug 19 02:05:21 EDT 2011

<<On Thu, 18 Aug 2011 08:46:16 -0400, "Jim Hall" <aerie.ma@comcast.net> said:

> Which makes me think of another question: why do stations that were
> originally licensed to a suburb, but which have moved to the same
> antenna locations as stations licensed to Boston itself, still
> identify themselves with the suburban town in which they were
> originally licensed?

Other people have answered the main question, but I just wanted to
expand a bit on their answers.  The FCC's regulatory structure
considers every little bump in the road to be, at least potentially, a
"community" which could be "served" by some local radio station.  The
system for FM allocations gives preference to stations which are the
"first local service" in a particular community, and at present it is
simply not permitted to take away the last "local service".  (There
are also preferences for "second local service" and "first audio
service".)  However, what the FCC considers to be "local service" does
not require the licensee to do anything special beyond mumbling the
name of the "community" during a legal ID buried in the :52 stop set.
(Well, technically, the legal ID rule doesn't allow that, but the FCC
has not enforced the legal ID rule as written in many years.)  So if
someone wants to move the last "local" station away from one
community, it must in general jump through three hoops:

1) Find a new community name which receives a city-grade signal from
the proposed new station location, which has no stations licensed *to
that exact text string*.  (The FCC would consider West Barnstable as
potentially distinct from Barnstable, for example, even though West
Barnstable is a part of Barnstable.)  The proponent must demonstrate
that the proposed community is a "distinct" community, which
historically could be done by browsing the yellow pages and writing
some nonsense about how it has its own post office, numerous
businesses use the community name in the name of their business, it
has a local government of some sort, etc.  There are also special
rules prohibiting stations from moving into an "urbanized area" (as
defined by the Census Bureau), so if the station is not currently in
such an area, the new community must not be in one either.

2) Find some means to "backfill" the old community, either by
identifying another allotment that could replace the one being moved
(for example, replacing a big class-B signal with a barely-feasible
class-A), or more commonly, finding some other station in the large
market that everyone is trying to serve which can be relicensed to the
old community without making any facilities changes.  The backfill
station would have to come from a community that already had at least
one "local service".  (I don't think they let you backfill with a bare
allotment any more, unless the old facility was also an unbuilt
allotment.)  In the past decade there have been some instances of
backfill chains a dozen or more stations long.

3) Apply for a full construction permit for both the originally
intended change and also the backfill facility.  Even if the backfill
facility requires no technical changes to serve its new community, a
full CP and license to cover process is required, which means that the
station loses grandfathering, must do full RFR and possibly
environmental processing, and undertake other costly engineering work
-- all preparatory to replacing the sign in the studio that tells the
jocks what to say when legal-ID time rolls around (or, alternatively,
paying voice talent to redo the pre-recorded IDs).

The sensible thing to do would be to allow any station whose
principal-community contour encompasses all or nearly all of a
Core-Based Statistical Area to identify with one or more of the core
communities of that area (as defined by OMB).


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