1430 WKOX MA relocated transmitter site?

[dib9]

Awesome explanation.   Thank you!Sent from my Verizon, Samsung Galaxy smartphone
-------- Original message --------From: Scott Fybush <scott@fybush.com> Date: 2/7/21  8:37 PM  (GMT-05:00) To: Mark Connelly <markwa1ion@aol.com>, boston-radio-interest@bostonradio.org, irca@groups.io Cc: nrc-am@googlegroups.com Subject: Re: 1430 WKOX MA relocated transmitter site? 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=2The STA application is just 2 pages:https://licensing.fcc.gov/cdbs/CDBS_Attachment/getattachment.jsp?appn=101823426&qnum=5150&copynum=1&exhcnum=2The 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=1724There'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