Tagged: LPFM FCC
May 2, 2018 at 12:52 pm #36542
Non Profit KISN-LP Needs your help: (The Map is on Our Facebook Page “KISN Everywhere”and will soon be on website: GoodGuyRadio.com
This is a special announcement to all of our KISN Listeners. The KISN Good Guys need your help! An AM radio station has filed an application with FCC to construct an FM radio station on the same frequency as KISN. This will cover areas of North and NE Portland. If the FCC allows this, it will eliminate our coverage to those areas of Portland and negatively impact many of you KISN listeners. It will also eliminate our listeners in Vancouver, Hayden, Sauvie, and Tomahawk Islands.
To prevent this from happening, we need your help immediately to collect petitions that we can submit to the FCC. We will soon have more information on our KISN Goodguy website. But, for now, we need to identify listeners who travel through North Portland or live in North Portland.
If you live anywhere near those areas, or have friends who listen to KISN in those areas, please contact us immediately. Please refer to the enclosed map to identify the areas we need listenership information from.
For now, if you live within the RED line we need emails that state: Your name, home address, phone number, email address and a brief statement that you listen to KISN-LP on a regular basis.
If you travel through any of the streets within the RED and GREEN line, we need to know your route traveled and state you listen to KISN. We will also need your contact information (you can live outside of the RED/GREEN line in those cases).
KISN engineers will plot all of this information on a map to send to the FCC. We will very likely contact you to sign a declaration too.
We need this as soon as possible as there is a deadline in a week or so for us to send a response to the FCC. More to follow.
A Sample of what you can say is below. Feel free to copy and paste in your email.
Send emails to: WORC.KISN@gmail.com
Thank you, our loyal KISN listeners…
I am a regular listener of “KISN – Good Guy Radio FM 95.1” which broadcasts on FM frequency 95.1 MHz, FM to the Portland, Oregon area.
Soon a new radio station will begin broadcasting on 95.1 MHz. I am concerned this station will interfere with my regular listening to “KISN – Good Guy Radio FM 95.1”.
I regularly listen to “KISN – Good Guy Radio FM 95.1” at my home and at the following other locations which I fear will be subject to future interference:
In addition, I regularly listen to “KISN – Good Guy Radio FM 95.1” along the following mobile routes which I fear will be subject to future interference as well:
(describe streets traveled through the red area on map)
I am providing this declaration to ask the Federal Communications Commission in Washington D.C. to take action to keep this interference from occurring. Other than being a regular listener, I am not connected in any way with “KISN – Good Guy Radio FM 95.1”
I declare under penalty of perjury that this Listener Declaration is true and correct to the best of my knowledge and belief.
Executed this Date of: __
Email:May 3, 2018 at 1:05 am #36547
I don’t think it has a prayer if it’s outside of their 60dbu contour. There’s another LPFM going on the air on the westside as well so their troubles are only beginning. It’s been a fun ride so I hope it can last a little longer.May 3, 2018 at 9:38 am #36548msndrspdxParticipant
The map mentioned in KISN’s announcement was posted on their Facebook page yesterday, and on the website last night. The station filing for the translator turns out to be KXET Mt. Angel, which runs a Russian language format. According to Tom Hopkins at KISN, at least some of that Russian programming comes from a network. The site turns out to be the KGW-TV tower for 7 Watts vs. KISN’s 3w.
But wait, there’s more! Bustos has filed for a transmitter at that same site for 105.5 FM. The KXET translator would run on 95.1, the same frequency KISN uses.
KISN also has an on air announcement abiut this situation running twice each hour. KISN has two weeks to appeal, so that’s why they’re asking for help from listeners.May 3, 2018 at 1:48 pm #36549
“I don’t think it has a prayer if it’s outside of their 60dbu contour.”
That is incorrect. 74.1204(f) plainly states the opposite:
(f) An application for an FM translator station will not be accepted for filing even though the proposed operation would not involve overlap of field strength contours with any other station, as set forth in paragraph (a) of this section, if the predicted 1 mV/m field strength contour of the FM translator station will overlap a populated area already receiving a regularly used, off-the-air signal of any authorized co-channel, first, second or third adjacent channel broadcast station, including Class D (secondary) noncommercial educational FM stations and grant of the authorization will result in interference to the reception of such signal.
KHPE and KXRU have successfully had Salem Media’s attempt to put an AM Revitalization translator in the west hills on 107.9 and then 105.5 thrown out.
I’ve been in contact with Ken at WORC (licensee of KISN LP) and with Ed at KXRU and they both will be attempting to circumvent the shoehorning in of another translator into the already saturated Portland metro.
“vs. KISN’s 3w.”
KISN-LP has 2 watts ERP, not 3.
“some of that Russian programming comes from a network.”
Irrelevant to this issue.
As I’ve explained several times before, the only way to fight these drop ins is to get written affidavits from listeners outside your 1 mV/m (60 dBu) contour that are inside the proposed 1 mV/m (60 dBu) contour. If applications like these succeed, and because the spacing is so tight, no one would receive either station in the area between the existing and proposed 60 dBu contours (sans obstructions blocking one or the other) because the signals are too close to each other in strength. A typical radio receiver would try and get both and end up getting nothing listenable.
KISN LP shouldn’t have any problem getting the 95.1 application thrown out. Not only is there a glowing omission of being short spaced to KISN LP with no explanation, but KISN LP will have no problem finding enough listeners in the right place to count at the FCC. KXRU, which has been through this before with Salem Media, will have a tougher time this go round because the proposed 60 dBu is further away, but the damage would be huge if they can’t make it go away.May 3, 2018 at 2:36 pm #36554jr_techParticipant
So then is KISN-LP likely to remain on Mt Scott and not move to the lower location to the east, indicated in the cp?
https://transition.fcc.gov/fcc-bin/fmq?call=kisn-lp&arn=&state=&city=&freq=0.0&fre2=107.9&serv=&vac=&facid=&asrn=&class=&list=0&ThisTab=Results+to+This+Page%2FTab&dist=&dlat2=&mlat2=&slat2=&NS=N&dlon2=&mlon2=&slon2=&EW=W&size=9May 3, 2018 at 2:44 pm #36555
Unknown. The proposal has to avoid overlapping either of their sites and when it is short spaced like it is to both, has to make a showing that their contours do not overlap either one. They did not make that showing or discuss the short spacing at all, even though it is in their application that they are short spaced. However, that could be corrected and have it be shown that the directional antenna and power applied for won’t overlap. It’s getting the affidavits from folks inside the proposed translator 60 dBu that matters.May 3, 2018 at 2:53 pm #36556
I just want to publically thank you Andy – for your advice you have given us in our pursuit to keep our LP station broadcasting on it’s frequency 95.1 unencumbered… Your expertise with this has been great. We are doing everything we can with letters from listeners in those areas affected. Again, I’m sure I speak for all of us with KISN-LP.. Thank You Thank Thank You…!!!May 3, 2018 at 4:50 pm #36557
You’re welcome. Like I said in the Beatle thread (Here, there and everywhere), there are few things left about broadcasting to cheer about, or at this point be pissed about anymore, but the deep pockets bullying LPFM’s is something I can not just sit by and be idle about especially since there is something I can do about it. The big mistake, I think, is letting AM Revitalization translators use directional antennae. Had they put a no DA’s clause in the rules for this go around of translators tied to AM’s, it would have avoided this mess nationwide. LPFM’s can’t use DA’s to avoid co channel issues.May 3, 2018 at 11:43 pm #36560
I’m really happy to be wrong about this one!May 7, 2018 at 3:49 pm #36629
While it is not uncommon (especially in Zone I and I-A) for proposed (and existing) new primary service to push their contours right up to their co-channel neighbors’ contours, at primary service ERPs there remains a large radius of interference free coverage. In other words, the size of the 60 dBu contour still provides value to the license.
In secondary service coverage, the same tactics in essence wipe out secondary coverage beyond the 60 dBu contour of both stations involved (obviously in the direction of each other) so all that remains is a few miles of interference free coverage at the center of each service. This is what the FCC allows though it seems quite counterproductive to me. Where is the incentive to spend 25 to 50 thousand dollars to license and construct a secondary service where other secondary services can so severely limit your coverage?
That’s why there is that rule in Part 74 (74.1204(g)). If you are there first, and you cultivate a following, you can have other secondary service applications bounced but the bar to filing a complaint comes at high cost.
In addition, changes in primary service stations in the area can literally displace secondary service altogether. Should, for example, some primary station 50 miles away decide to move along their ridge to a cheaper tower site and that happens to be in the direction of a co channel secondary service, the licensee might never find a new channel good enough to duplicate the quality of coverage. In other words, what if 107.1 in Castle Rock decides to move just a little south of where they are now but enough to make 107.1 unusable in the west hills of Portland as a secondary service. Metro would have to move it south or east, or find another channel (hint: there are none) and the mighty XRAY would cease to have their most important delivery system.
The system is flawed in many ways, and that’s one of them.May 13, 2018 at 4:33 pm #36766msndrspdxParticipant
KISN reports on their Facebook page a big response from listeners in the translator case. Lots of responses thru the website’s online form and in the mail, along with E-mail and Facebook posts. Their FCC lawyer quoted as saying he’s never seen a supportive response like this. They’re pinning down reception reports which will be submitted soon to the FCC. This might not be resolved for several months but KISN thinks they’re building a strong case. Worth noting that KISN and X-Ray recently celebrated three years on air.May 13, 2018 at 5:53 pm #36768chessyduckParticipant
LPFMers can get a break it seems.
Back here in Washington DC informal complaints by WOWD-LP listeners due to interference from a newly re-located FM xlator for WCTN-AM actually led to the immediate shutdown order from the FCC for the ill-engineered translator.
For more details see:
Or visit recent postings in the mailbag section of DCRTV.COM : http://www.dcrtv.com/mailbag.htmlJuly 23, 2018 at 10:25 am #38571
I was looking for a KISN topic. Is anyone else slightly intrigued that 96.7 is now KICN? I wonder if it will be a west side version of KISN. Don Burdon used those calls in Denver as “Kissin'” and intended them for KISN’s FM before they lost their license and it ended up as K103.July 23, 2018 at 1:48 pm #38574
Semoochie….You are quit the detective… Intriguing minds want to know…. Keep On KISN 95.1FM to find out….July 23, 2018 at 5:09 pm #38579
LPFMs sharing programming is nothing new and frankly, it doesn’t help make a strong case for giving LPFMs a higher status (immunity from being bumped for example) or more power (ERP that is). What it says is that there aren’t enough volunteers to provide enough programming (since dollars aren’t there, either) especially in cities like Portland where there are just too many secondary service licensees. What’s going on is building LPFM networks to cover larger areas so from a coverage perspective it helps spread the format employed, whether it be the Community model or automated oldies, but there is only so much underwriting dollars to go around, so it is going to further spread those dollars and each outlet will get less. The big elephant in the room, though, are the Republican driven assholes in Congress and their willingness to strip diversity from not only ownership but programming as well. Most of you don’t realize that the NAB didn’t want LPFMs and continues to try and put crap through at the FCC to kill them off.
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