Not only is Matt Wesolowski the owner of WYAB-FM Flora, MS, he’s also an engineer. He’s not buying the claims by NAB and a group of larger radio owners that his proposal to have the FCC protect only actual, on-the-air FM contours will fill the band with lots of interference.
“The Opposing Parties’ comments contain an abundance of supposition, lacking any substance or a single “real world” example. Petitioner need only look at its own station, WYAB
103.9 FM, to upend the Opposing Parties’ claims,” Wesolowski said in his reply comments. Then he laid out the engineering calculations, which we won’t repeat here, determining that the station’s current 11.66% service-to-interference ratio would improve to 12.96% if WYAB upgraded to the maximum extent if it no longer had to protect the un-built maximum facilities of another station’s allocation. “Under Petitioner’s proposal, WYAB would provide a far better service-to-interference ratio than under the current system. Thus, Petitioner need only look at its own station to invalidate the claims of the Opposing Parties,” he concluded.
Wesolowski also disputed the claim that the proposed change would adversely impact HD Radio digital FM broadcasting. The proposal would make the contour protection rules for the non-reserved (commercial) portion of the FM band exactly the same as for the reserved educational band. Wesolowski noted “the documented success of digital radio within the reserved band” and questioned how anyone could make the case that the proposed change would harm HD Radio in the non-reserved band. “Petitioner contends that, if anything, the Commission’s adoption its proposals has the potential to enhance digital radio. Any station receiving upgraded facilities under the proposed rules would also be eligible to upgrade its corresponding digital facilities, thus increasing the reach of its digital signal,” he argued.
“In the Joint Statement [from the six group owners], the bizarre allegation is made that Petitioner’s proposals represent an attempt to eviscerate the Commission’s policies to promote rural radio service,” Wesolowski told the FCC. “The statement postulates that ‘Petitioner all but admits that its proposal will provide a run-around of the Rural Radio Service changes.’ Petitioner has again reexamined its own Petition and is unsure as to which document the Opposing Parties’ may have been exposed. Petitioner’s proposal very particularly states that ‘adoption of this proposal will allow existing commercial FM broadcasters the opportunity to upgrade their facilities without the need to change their community of license or abandon their rural listeners, a priority the Commission favored in MB Docket No. 09-52.’ Given its definitive statement in affirmation of the retention of rural radio services, Petitioner strongly disagrees with the Opposing Parties’ assertion that its proposal would provide some ‘run-around’ of the Commission’s policies pertaining thereto,” Wesolowski said.
RBR-TVBR observation: Now we wait to see if the FCC’s Media Bureau decides to do anything with this proposal to end what Wesolowski calls “overprotection” of FM signals, unlike anything done in the AM of TV bands or the educational portion of the FM band. The next step, if there is one, would be a formal Notice of Proposed Rulemaking (NPRM) by the Commission.