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FM Translator Basics: FCC Rules

 The FM translator service is a low-power, secondary service in the FM broadcast band that was originally meant to complement the primary FM service. It was created in 1970 to allow FM stations to provide service to areas that were not served well by the primary service, due to reception difficulties created by distance and/or intervening terrain. Translators simultaneously re-broadcast the program of their primary station (AM, FM, or HD) on a different frequency, in the FM band (88-108 MHz). They are not authorized to originate programming — except for brief fundraising announcements. (See the third article in this e-book for more details.) Because translators are now allowed to have AM radio stations as their primary stations it is important to note that translators relaying daytime-only AM stations may continue to carry programming of their primary AM station, even when said AM station is off-air overnight.



Translator stations that provide service within the primary station’s protected service area are defined as “fill-in” stations. Fill-in translators can be owned by the main station or by an independent entity. Commercial non-fill-in translators (which are outside of the primary station’s protected service area) are generally owned by independent entities, with certain exceptions. Noncommercial educational non-fill-in translator stations are generally owned by the primary station being rebroadcast.

FM TRANSLATOR OWNERSHIP IS NOT SUBJECT TO THE FCC’S FULL-SERVICE STATION NUMERICAL OWNERSHIP LIMITATIONS.

FM translator ownership is not subject to the FCC’s full-service station numerical ownership limitations. Therefore, broadcasters with full market complements of AM and FM stations may acquire as many fill-in FM translators as they may find. Translator stations rebroadcasting a commercial AM or FM station (as their primary station) may be authorized on Channels 221 through 300 (92.1 MHz to 107.9 MHz), while a translator rebroadcasting a noncommercial educational station may be authorized on any FM channel (Channels 201 to 300 — from 88.1 MHz to 107.9 MHz). The maximum effective radiated power (ERP) permitted for any translator station is 250 watts. It is important to note that, depending upon the circumstances, the ERP will often be much lower. (More on that later.)

FILL-IN TRANSLATORS   

A “fill-in” translator by definition provides complementary coverage to its primary, inside of the protected service contour of its primary. It is required to maintain its service contour within the service contour of the primary station. For the following classes of FM stations: A, C3, C2, C1, C0 (C-zero), C or noncommercial educational Class B, B1, or D FM primary station, the fill-in translator station must maintain its 60 dBu (1 mV/m) F(50,50) service contour within the 60 dBu contour of the primary station. The fill-in translator of a commercial Class B primary station must maintain its 54 dBu (0.5 mV/m) F(50,50) service contour within the 54 dBu F(50,50) contour of the primary station. The fill-in translator of a commercial Class B1 FM primary station must maintain its 57 dBu (0.7 mV/m) F(50,50) contour within the 57 dBu F(50,50) service contour of the primary station. The distances to the primary station and translator station contours are to be predicted using the standard contour prediction method as specified in Section 73.313 of the commission’s rules, using as many radials as necessary to accurately locate the contours.

THE COMMISSION HAS RULES REGARDING THE UNATTENDED OPERATION OF TRANSLATORS.  

An FM translator may have an AM station as its primary only if the translator’s 60 dBu service contour is within the smaller of a) a 25 mile (40 km) radius circle from the AM station’s transmitter site and b) the AM station’s 2.0 mV/m contour. This limitation applies to all applications being filed by AM licensees for FM translator stations in 2016 and 2017 as part of the AM revitalization effort. (Chris Wygal’s article on page 10 will provide more details.) A fill-in translator station may be owned by the licensee of the FM primary station or by an independent entity. An independent owner of a fill-in translator must secure the permission of the primary station to rebroadcast its programming before commencing operation. It is important to note that the primary station is allowed provide financial and technical support for an independently owned fill-in translator both before and after the translator commences operation.

ration. Fill-in translators may have their ERPs limited by the need to maintain the translator’s service contour within the primary station’s service contour, but in any case, the upper power limit is 250 watts. (Non fill-in translators have their ERPs limited by their HAAT, as defined in 74.1235.) A commercial fill-in translator may receive a primary station’s signal via any terrestrial transmission method, including (but not limited to) microwave, internet, and all manner of circuit types provided by local telephone companies. Satellite delivery is prohibited. These requirements also apply to noncommercial educational translators in the reserved band (88 to 92 MHz) that are not commonly owned with the primary station. A noncommercial educational FM translator, commonly owned with the primary station, may deliver the signal to the translator by any means, including satellite delivery. Only one channel will be authorized for a translator; and, the translator can have only one primary station.

NON-FILL-IN TRANSLATORS  

As the name suggests, non-fill-in translators provide coverage for their primary stations outside of the primary’s protected service area. In some cases, the coverage of the non-fill-in translator may lie completely outside of the primary’s service contour. The most important legal aspect of non-fill-in translators is this: Commercial stations, and anyone associated with the commercial primary station, may neither own nor provide direct, or indirect, support to the non-fill-in translator station, before or after the translator commences operation. Interestingly, the commission has added this note to its own explanation of this particular rule: “However, in order to facilitate service to white (or unserved) areas, the commission is favorably disposed toward waiver of this rule to permit a commercial primary station to support its own translator, or an independently owned translator, which provides service to these unserved areas.” For the purposes of translator station applications, “white area” is defined as any area outside the coverage area of any full service aural service (AM as well as FM). A showing of the “white area” must be presented in the translator application with a request for waiver of the ownership requirement. When locating the “white area” boundaries, the service contours for FM stations shall be predicted using the standard method as described in 73.313. Consult with your communications attorney for more on this waiver possibility. 

“Technical support” for non-fill-in translators is a different matter though. The primary commercial FM station may provide technical support to an independent translator station, including services provided by the primary station’s technical staff or compensation for the time and services provided by independent engineering personnel. This support does not extend to the supply of equipment or direct funding for the translator’s discretionary use. Technical assistance by the primary station should occur after the issuance of the translator’s construction permit or license in order to meet expenses incurred by installing, repairing, or making adjustments to equipment. A special caveat for commercial non-fill-in translator stations: The commission may terminate the operation of a non-fill-in translator station at any time if the circumstances in the community or area have changed such that its application would have been denied if those circumstances had existed at the time of its filing. The notice of termination, when issued, will list a date at least 60 days from the notice date by which operations must be terminated. However, the commission also says, in its own text, that “notices of termination pursuant are rare in practice.”

Non-fill-in translators relaying commercial FM stations must receive the signal off the air, unless a waiver has been granted to feed a “white area” translator by other terrestrial means. (A showing of the “white area” must be presented in the application for construction permit, requesting waiver of the signal delivery requirement.) Independent non-fill-in translator licensees must have secured the written permission of the primary station to rebroadcast its programming before commencing operation. Noncommercial educational non-fill-in translators operating on Channels 201 through 220 (88.1 through 91.9 MHz) that are owned by the licensee of the primary noncommercial educational station may use alternate means to receive the primary FM station’s signal. Non-fill-in noncommercial educational translators on Channels 221 through 300 (92.1 through 107.9 MHz) are prohibited from any alternative methods of signal delivery, including programming feeds by satellite. The program feed must be taken off-air.

A significant technical distinction between a fill-in and a non-fill-in FM translator is the power and height limitations on non-fill-in translators. For a non-fill-in FM translator located east of the Mississippi River or in Zone 1, maximum effective power can be limited under FCC rules to as low as 10 watts with antenna heights of 141 meters HAAT and above.



CONCERNS FOR BOTH TYPES OF TRANSLATORS  

Naturally, any translator applicant expects that the translator will be built, and after that, will just run by itself, without much in the way of intervention. The commission, though, has rules regarding the unattended operation of translators. For example: If the transmitter site cannot be reached promptly at all hours and in all seasons, means shall be provided so that the translator can be turned on and off at will from a point which is readily accessible at all hours and in all seasons. In order to meet the letter of the law, some sort of remote control must be installed, and the control location “must be adequately protected against tampering by unauthorized persons.” Further, the translator must be equipped with an automatic system by which it will be placed “a non-radiating condition in the absence of a signal on the input channel.” For those readers who are AM station owners, I once again point to rule 74.1263 (b):

 “An FM booster or FM translator station rebroadcasting the signal of an AM or FM primary station shall not be permitted to radiate during extended periods when signals of the primary station are not being retransmitted. Notwithstanding the foregoing, FM translators rebroadcasting Class D AM stations may continue to operate during nighttime hours only if the AM station has operated within the last 24 hours.” In other words, you can continue operating your translator overnight, even if the primary AM station is a daytimer. You cannot, however, make the AM dark and continue operating the translator.  

 If the translator is on a tower or supporting structure that requires lighting under part 17 of the commission’s rules, the translator licensee must make suitable arrangements for the daily inspection and monitoring of the tower lights. This is another reason for providing the translator site with a remote control device. Difficulties in obtaining a translator license are many, as are impediments to its construction and operation. None is as grave as the interference issue. A translator may not cause predicted nor actual interference. First, let’s look at predicted interference. A translator construction permit application will not be granted if an objecting party provides convincing evidence that the proposed translator station would likely interfere with off the air reception of a full service FM station, even if there is no predicted prohibited contour overlap.

 This means that even if you file an application permit for a translator, after successfully accommodating all of the rules, that an outside party, like the licensee of an FM station on or near the frequency you apply for, can derail your application by way of an objection, based on evidence they provide to the commission. In order to counter this threat, use an experienced engineering consultant, and an experienced communications attorney who has succeeded in other cases. After your translator CP is granted, and you construct the system, you are still subject to interference complaints. Here is the exact wording from the commission’s rules:

74.1203 (a(3)) The direct reception by the public of the off-the-air signals of any authorized broadcas station including TV Channel 6 stations, Class D (secondary) noncommercial educational FM stations, and previously authorized and operating FM translators and FM booster stations. Interference will be considered to occur whenever reception of a regularly used signal is impaired by the signals radiated by the FM translator or booster station, regardless of the quality of such reception, the strength of the signal so used, or the channel on which the protected signal is transmitted.

A SIGNIFICANT TECHNICAL DISTINCTION BETWEEN A FILL-IN AND A NON-FILL-IN FM TRANSLATOR IS THE POWER AND HEIGHT LIMITATIONS ON NON-FILL-IN TRANSLATORS.

This is very important, because this rule says that your translator cannot interfere with a signal that is already there, no matter how weak it is, if it can be shown that there was previous, regular use of that signal. If the licensee of the signal purported to be receiving interference didn’t derail you in the application process, they can do it now by soliciting and gathering reception complaints from listeners in the interference area, and forwarding them to the commission. So what can the holder of the CP do in the event that interference complaints are forwarded to the commission? 74.1203(b): If interference cannot be properly eliminated by the application of suitable techniques, operation of the offending FM translator or booster station shall be suspended and shall not be resumed until the interference has been eliminated. Short test transmissions may be made during the period of suspended operation to check the efficacy of remedial measures. If a complainant refuses to permit the FM translator or booster licensee to apply remedial techniques which demonstrably will eliminate the interference without impairment to the original reception, the licensee of the FM translator or booster station is absolved of further responsibility for that complaint.

There you have it: the basic rules of translators. For additional information, I invite you to read the third article in this e-book, which delves into the construction and operation of translators.

 



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