1430 WKOX MA relocated transmitter site?

[Scott Fybush]

Apologies in advance, because this may turn into a somewhat complex 
reply. There's a TL;DR at the bottom if you don't want to read a 
dissertation :)

There are a lot of issues to unpack in what Mark is noting about WKOX 
and WPLM and how their facilities appear in a lot of the free search 
tools DXers use.

Keeping an AM station on the air at all in 2021 is an increasingly 
fraught task. Many (even most) AM directional arrays in North America 
are past their original design lives; as many as half of all directional 
AM sites are estimated to be more than 70 years old now. An increasing 
percentage of AM facilities don't matter to their owners as AM signals - 
the expectation is that listeners are tuning in to FM translators, and 
the AM is just kept limping along because the rules require it to stay 
on the air to "feed" the translator. The base of engineers with 
experience maintaining high-power AM facilities is aging out. Many of 
the manufacturers who used to make the equipment used at AM sites have 
stopped. (For much of the past three years, there was only one company 
making AM transmitters at 10 kW or higher power levels!)

Now add into that the declining value of AM signals, the increasing 
value of the land under many big AM arrays, and the short-term business 
models that have led most of the big broadcasters to sell off their real 
estate and lease back only what they need.

That's what caught WKOX. It had been owned by Clear Channel but was spun 
off into a trust when Clear Channel became iHeart and then went private. 
The 1430 signal ended up over the FCC's local ownership cap and was no 
longer grandfathered in. The property where its transmitter was located 
was originally also the studios for 1430 (as WHIL/WXKS-AM) and 107.9 (as 
WHIL-FM/WXKS-FM), but those studios moved to a different leased space 
and the land became more valuable as development accelerated in the area 
(it's next to a transit station.)

When iHeart sold off most of its physical property, the transmitter 
sites went to a company called Vertical Bridge. In some cases, VB keeps 
the sites operating and leases them back to iHeart. In this case, VB 
intended to sell the land and force the stations using the site to find 
new homes. (This particular site had also been used by WILD 1090 for the 
past decade or so after WILD sold its original site a mile away - in an 
ironic twist, the original WILD site has been redeveloped as part of a 
big office park whose tenants include the current iHeart studio complex.)

So: WKOX and WILD both had to move, because both ended up as tenants at 
a location they didn't control. Neither license was worth very much by 
the time they ended up in this pickle. WKOX never found a buyer and it 
was eventually easier for iHeart to just donate the license for a tax 
writeoff rather than go through the hassle of maintaining the trust. 
WILD was sold last year for a pittance, maintaining a month-by-month 
tenancy at the existing site pending its demolition. (And because the 
buyer is one of my clients, I'll say nothing further publicly for now 
about what's in store for that side of the deal.)

That's the background, and it's a fairly common story for smaller AMs in 
bigger urban areas these days.

And how does it affect what we see on sites like V-Soft and Radio-Locator?

These sites usually don't do any of their own data collection. Neither 
do other (and often better) alternatives such as FCCData.org and 
FCCInfo.com. In various ways, they each depend on FCC databases, and 
each site has struggled in its own way as the FCC has transitioned from 
the old CDBS system to the new LMS database. Most of them take a daily 
database dump from the FCC, and each has its own special sauce for 
figuring out what database fields to interpret, how to check them for 
changes from the previous day's data, and how to display them.

What all the sites have in common is that they display licensed station 
data. But what does it mean for a station to be "licensed" with a 
certain facility? The assumption most of these sites use is that 
"licensed" = "on air with the stated facilities" - and that's not always 
a safe assumption these days.

"Licensed," to the FCC, for the purposes of its database, really means 
"these are the facilities that other broadcasters must protect 
domestically," as well as "these are the facilities that are notified to 
us internationally under treaties that require U.S. broadcasters to 
protect them."

Anyone who's ever used the FCC database (or the websites that rely on 
the FCC database) to look up Canadian AM stations knows how this works 
in practice: callsigns aren't updated by Canada in the US database, and 
stations that have been gone for 20 or 30 years, or even longer, still 
appear as "notified" and must still be protected by US AM stations. 
(This is one reason I'm a fan of FCCdata.org, which has a tab that 
allows for some limited search and display of Canadian data from the 
Canadian ISEDC database instead.)

Still with me? Good, because here's where it gets really fun.

There are many reasons these days why a US AM station may have 
"licensed" facilities that no longer exist, and thus may be on the air 
from a different facility or not on the air at all.

The FCC has known for decades that it's getting harder for AM stations 
to retain aging facilities and keep them on the air. Enter the STA.

"Special Temporary Authority" has been part of the FCC's rules forever, 
but it's never been used as much and for as many purposes as it is these 
days. There are a variety of forms of STA, ranging from a verbal STA 
that can be granted over the phone by Commission staff in emergencies, 
to "silent STA" that allows a station to be off the air for six months 
at a time when it's experiencing technical or economic difficulties, to 
"engineering STA" that is also granted in increments of up to six months 
at a time. Engineering STA typically allows a station to run at reduced 
power, to use a different antenna system or location from what's 
licensed, or for a directional AM to operate ND with up to 25% of its 
usual DA power.

STA filings are typically granted very swiftly and with relatively 
limited engineering showings. In most cases, the FCC will renew a 
six-month STA several times with just a brief explanatory paragraph 
showing that the station is still trying to fix whatever justified the 
STA in the first place. (The big exception is the silent STA; by act of 
Congress, a station cannot be silent for more than 365 consecutive days, 
at which point its license is automatically deleted. This is why many 
silent AMs find a way to return in some very minimal form once a year to 
keep their licenses alive - and that's why WPLM 1390 still sort of exists.)

For a station such as WKOX that's in the process of moving to a new 
location, the actual work of getting relicensed at the new site is a 
lengthy and complicated one. The engineering studies involved are much 
more complex than what's needed for an STA, and the FCC's processing 
resources are limited, especially with the entire staff working remotely 
because of COVID. It can take many months to get the one AM staffer in 
the Media Bureau to issue a new construction permit, and even longer 
after that for the "license to cover" process to result in an actual new 
license record in the database.

In the case of WKOX, the application to move to the WROL site was filed 
Nov. 12, 2020, but with the clock ticking on eviction from its existing 
licensed site, WKOX realized it was going to have to move before the FCC 
could get around to granting the construction permit for the move. Enter 
the STA: on Dec. 18, WKOX filed an STA request to be allowed to begin 
operating from the WROL site immediately, in this case using the same 
facilities (2.5 kW D, 26 watts N, ND) as it will use once its new 
license is granted.

The full application for the move runs 10 pages, plus 9 technical exhibits:

https://licensing.fcc.gov/cdbs/CDBS_Attachment/getattachment.jsp?appn=101822593&qnum=5120&copynum=1&exhcnum=2

The STA application is just 2 pages:

https://licensing.fcc.gov/cdbs/CDBS_Attachment/getattachment.jsp?appn=101823426&qnum=5150&copynum=1&exhcnum=2

The STA application was granted pretty much immediately, allowing WKOX 
to make its move and stay on the air. The full CP application actually 
moved through the FCC pretty expediently: it was granted on Thursday, 
and because the facility is already built under STA, I expect WKOX will 
move fast on filing for its license to cover, which means its license 
record should be updated within a few weeks to reflect its new location.

That's unusually speedy. There are license records in the FCC database 
for AM sites that haven't existed for decades - 990 in Muncie, Indiana 
is one, where its six-tower array went away in the early 1990s and it's 
been using very reduced facilities on a longwire ever since.

Now:

Because of the way STA engineering records exist within FCC databases, 
it's very complicated for most of these outside sites to find an easy 
way to display whether a station like WKOX (or 990 in Muncie) is 
actually on from its licensed facility or from an STA. In the case of a 
990 Muncie, its licensed facility will never return - it's long since 
been sold off and there's a housing subdivision there now.

Yet there has to be a "license" record for every AM, and so any site 
that's built on license records is going to show the old six-tower site 
for 990 in Muncie, because until and unless it's ever fully relicensed 
at a new site, the six-tower site was the last one that was licensed, 
and it's still protected until such time as a new license is issued at a 
new site.

And so if you go looking for the actual location of 990 in Muncie, you 
have to dig a little deeper. I swear by FCCdata.org for this purpose. If 
you search for WJCF in Muncie, you get this:

https://fccdata.org/?lang=en&facid=1724

There's a lot of data here, and yes, it starts with the license record 
showing the location and pattern of the six-tower array that's been gone 
for more than 20 years now.

Look at the right column toward the bottom and you see a long run of STA 
filings, every six months for all these years. Look at the top left and 
you see a more graphic display of more recent STAs, including 
BSTA-20201211AAH, granted Jan. 8. 2021. You can click on "view 
application" here and get to the licensee's explanation of its most 
recent attempts to get relicensed at a permanent site, along with a 
description of the STA facility. In this particular case, one of the 
justifications of the extended STA is that they're waiting (and waiting, 
and waiting) for the FCC to finish the rulemaking proceeding that may 
eventually loosen certain interference rules for new AM facilities, 
which would make it easier to license a better new permanent facility. 
They're not alone in that wait.

For anyone who really needs to know what's *actually* on the air, as 
opposed to what's licensed, there's going to be more of this in our 
futures. As more AM facilities age, fail, or get sold off, I wouldn't be 
surprised if we're headed to a point soon where 10% or more of all AMs 
are on some form of STA. (My guess is that we're already at the 5% mark, 
and that's just the stations that are actually being responsible and 
filing proper STAs - there are plenty of AMs that are simply operating 
from less-than-licensed facilities or expired STAs and just hoping they 
won't get caught.)

And because STAs are granted in six-month increments, they're hard to 
capture by annual sources such as the NRC Log - a lot can come and go in 
the 12 months between editions, through no fault of Wayne and crew, of 
course.

Bottom line:

Any time something you hear on the air doesn't seem to match up with the 
basic license records you find in a quick search of something like 
radio-locator or in an annual source such as the NRC Log, the next stop 
I'd recommend is FCCdata.org. They provide a much deeper dive into FCC 
records than most of the other free sites, especially for STAs, and it's 
usually pretty easy to see whether there's a valid STA that's being used 
instead of the license record. Once you learn some of the basic lay of 
the land (the BSTA- and BESTA- prefixes in CDBS records are the ones 
you're looking for, though FCCdata's lists also include definitions of 
what filings do what), it gets easier to understand what you're looking 
at - at least until AM filings migrate to the new LMS system and those 
prefixes go away....

I deal with a lot of this stuff for a living these days, so if there are 
any questions I can help answer, I'll try!

s