FCC petitioned to create new Class C4 FM service

Currently, the technical parameters of a Class A FM station top out at 6 kW @ 328’. A Petition for Rulemaking from SSR Communications to allow the power to be doubled from the same HAAT in Zone II areas.

Zone II areas are the ones where Class C stations are allowed to be built, as opposed to Class B stations which are the big hitters in places like the very crowded FM dial on the eastern seaboard. The Class C areas have a lot more wide open territory around them, hence less concern about interference issues.

The proposal, put forth by SSR’s Matthew K. Wesolowski, would give Class A stations the chance to upgrade their signals and gain sounder competitive footing.

Wesolowski stated, “Petitioner respectfully requests that the Commission adopt these changes, as they would serve the public interest and benefit several minority-owned Class A FM stations.”
He noted that the current maximum power for a Class C3 FM, the weakest of the Class C group, is 25 kW – and pointed out that the 12 kW of the C4 would fill the big gap between C3 and A that currently exists.

Wesolowski also noted that the Commission’s own Advisory Committee for Diversity in the Digital Age has recommended the creation of sub-Class A groups, or medium power FM stations, for use in more crowded areas that would allow new stations to go on the air with parameters between the current Class A specifications and the LPFM/translator level. He noted the proposal for a Class A1 limit of 1.5 kW @ 328’ and a Class A2 limit of 1 kW @ 164’. While such stations might not fit in everywhere, they would provide a useful option for some high population density areas.

Wesolowski argued that his C4 classification would be valuable addition to the FM class structure for a number of reasons and should also be considered.

Wesolowski was conscientious enough to put dots on his i’s and crosses on hits t’s – he even provided the FCC with a new minimum separation chart that takes into account the hypothetical existence of Class C4 FM stations.

RBR-TVBR observation: This sounds like it would be in the public interest to us. If a station can cover more territory and reach more people without interfering with another station, what’s the harm?

Well, the harm could be a second round of Docket 80-90-type damage – that was the FCC proceeding that led to the creation of rimshot FMs, which in turn led to the presence of a lot more forks dipping into the local advertising pie as well as the introduction of stations that began life at a competitive disadvantage. Add in the influx of non-broadcast equity investors and a sour economy and the end result was bankruptcy, a new local ownership cap of up to four stations in 1992 and the eight-station cap for large markets that hit the industry for better or worse but either way like a sledge-hammer as a result of Telecom 1996.

But we doubt that will happen here. So we say why not? Let’s do the work, see how many small stations would benefit and give this proposal strong consideration.