Simmering translator pot now boiling

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This topic contains 88 replies, has 15 voices, and was last updated by  semoochie 1 month, 2 weeks ago.

Viewing 15 posts - 61 through 75 (of 89 total)
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  • #39440

    cbaravelli
    Spectator

    Don’t know why the Rototiller and Penetrator are in discussion. They are circular.
    A cloud of dust and a Hi-Yo-Silver?
    “…and asked them if they can build a circular polarized version with one element due to limited tower space?
    I have.”

    Can be done. Anybody can build one in the garage. Although a circular Yagi-Uda would be a waste of aluminum.

    #39450

    Andy Brown
    Participant

    Two new letters this month.

    Bustos made some progress in the 101.5 translator confrontation. No surprise that the FCC found the Petition to Deny as incomplete and threw out some of the informal objections as insufficient. None of the filings were done properly. I posted as much when they were filed. Several informal objections remain, but even if those pass muster there aren’t enough. They should immediately file more of them and fer Christ’s sake plot your address on the proposed 60 dB contour map.

    So Bustos paperwork on this one remains Accepted For Filing. There still remains Prometheus’ et. al. Application for Review to be resolved. (see below)

    The 95.1 and 105.5 Bustos gambits remain in limbo but those objections were complete and properly done.

    If I had to guess today, I’d say Bustos gets one out of three, and only because the 101.5 PTD was centered around interfering with a Eugene Springfield station and the Informal Objections about interfering with a local LPFM were incomplete, at best, with no map showing how the addresses that were in the objections reside within the proposed 60 dBu contour.

    The KXRU 105.5 and KISN 95.1 objections have all the signed testimonials, the addresses are plotted on the map and are inside the proposed 60 dBu. For those reasons, I doubt Bustos will prevail as the Commission has already thrown out Salem Media’s attempt to wash out KXRU with a similar gambit that KXRU objected to.

    Then again, when you have Republicans in charge at the FCC, rules don’t outweigh obscure highly tangential case law (fancy wording for payoffs).

    http://licensing.fcc.gov/cgi-bin/prod/cdbs/forms/prod/getimportletter_exh.cgi?import_letter_id=87789

    Meanwhile, the massive objection filed by Prometheus, et. al. remains in the pipeline. Although it was denied, they have filed an Application For Review (posted earlier in the thread) which was objected to by a bunch of group owners salivating over their translator pipe dreams. Prometheus has filed a reply to their objections just last week. Until the Application for Review is fully killed by Pai’s FCC and the objections are dismissed as moot, no new translators under the AM Revitalization plan can be granted which includes the 101.5 situation described in the beginning of this post.

    https://licensing.fcc.gov/cdbs/CDBS_Attachment/getattachment.jsp?appn=101791882&qnum=5000&copynum=1&exhcnum=1

    #39455

    cbaravelli
    Spectator

    Now, that is a brief! Worth the read (twice).
    However, there are three voices (Todd should just stop being a legal beagle) and the Review Response fails to restate in new language positions presented in the original Petition Reply. Replies and Responses are different animals.
    Petitioners make good points;
    The lack of retrospective intervention in Auctions No. 99 and 100 compared to said intervention in Auction No. 83; and the presence of population-density considerations in Auction No. 83 but not 99 or 100 is disparate treatment vis Melody Music, Inc., Appellant, v. Federal Communications Commission, Appellee, 345 F.2d 730 (D.C. Cir. 1965).
    and bad:
    Victoria bemoans the existence of the “parties aggrieved” standing option, inferring that Petitioners should embrace the more common means of standing better covered in case history under Section 1.106(b). Victoria delving into Section 1.106(b) standing qualification is thus superfluous.

    9th Circus

    #39459

    KXRU-ED
    Participant

    +1 @ Andy Brown.

    How hard is it to write complete and legal PTD? Even if you don’t have an attorney, there is a ton of good ones around. Use them as a template!

    #39473

    boisebill
    Participant

    The new C4 class if used could submarine quite a few translators and LPFMs. Don’t have any numbers but that’s the opinion of several consultants.

    #39477

    cbaravelli
    Spectator

    New FCC Class 4 designation in the Inquiry stage. Understand the reasons. Class A FM stations are becoming non-local (satellite programming usually religious) or are, like AM, signing off.
    NAB identifies “short – spacing” waiver issues and adjacent channel interference. Anyone with a radio in NYC, LA and NO will hear adjacent stations in large blocks on the broadcast FM spectrum. This point is moot. NYC and LA are not in Zone II.
    Don’t know what RAB thinks.

    #39480

    KXRU-ED
    Participant

    Do we have a list of stations and translators that would be affected?

    #39486

    Andy Brown
    Participant

    http://bit.ly/2N0k2Xv

    Within 100 km there are a bunch, mostly Longview, Salem, Hood River and the coast.

    At least half of them are in the reserved band.

    Depending on the final rules, and if the FCC remains bound by previous rules including those that created the LPFM service, there should be no effect on existing LPFMs.

    “the Local Community Radio Act of 2010, they stated in section 3(b):

    (1) IN GENERAL- The Federal Communications Commission shall not amend its rules to reduce the minimum co-channel and first- and second-adjacent channel distance separation requirements in effect on the date of enactment of this Act between–

    (A) low-power FM stations; and

    (B) full-service FM stations.”

    Explanation here:

    https://recnet.com/node/2123

    #39488

    KXRU-ED
    Participant

    Andy, would it be much difficult to map what would it look like if KUKN upgraded to C4 in relationship to KXRU?

    #39496

    Andy Brown
    Participant

    The link below shows you the distances to all your co, first and second adjacent channels within 220 km of your antenna.
    The distance to KUKN is 75 km.

    http://bit.ly/2N5gIe4

    This second link to the spacing chart shows you that you are currently experiencing interference received up to 92 km, which would increase to 104 km for C4.

    https://recnet.com/73807

    If they are upgrade capable, and can go the full amount of increased power appropriate for their HAAT without being short spaced in other directions, the result would be like the first example at the explanation link I gave above which is https://recnet.com/node/2123 and would be similar to this, rotated appropriately:

    https://recnet.net/images/C4-1.jpg

    I’ll draw out the contours tomorrow if I get a chance and email it to you.

    #39498

    semoochie
    Participant

    What about assigning all the high power translators that want to drop their AMs to Class A1? I know the FCC is saying “no” but the government has been known to change its answer.

    #39586

    Andy Brown
    Participant

    Three more informal objections have been filed against the Bustos application for a new translator on 101.5 MHz.

    http://bit.ly/2IzLWsR

    #39876

    Andy Brown
    Participant

    Bustos had all of its arguments denied but their CP on 99.9 remains intact because the filers of the Petition To Deny did not sufficiently demonstrate that there would be interference although IMO they did provide the right exhibits but apparently lacked the analysis the FCC was looking for. Frankly, it’s a white wash and I think the reason in this case is that the CP was already granted. You really need to get objections filed immediately (30 days) after the application, not after the CP has been granted. There is always a higher burden of proof when complaints arrive after the grant has been issued. Tough loss for 99.1 but some key rebuffs of Bustos’ scattered and often irrelevant rebuttals. Again, the CP remains intact but not because of ANYTHING Bustos wrote in their response. Also, there is no carryover to the other translator applications not yet granted on 105.5 and 95.1. I still think those Bustos applications will be denied.

    http://licensing.fcc.gov/cgi-bin/prod/cdbs/forms/prod/getimportletter_exh.cgi?import_letter_id=88216

    #39879

    KXRU-ED
    Participant

    My understanding is once fully licensed there is another route to get them off the air just a much longer, and most likely more expensive approach.

    #40104

    Andy Brown
    Participant

    The informal objections to Bustos 101.5 gambit have been consolidated and detailed properly in a new filing that may be the fatal blow. As far as I can surmise, the 95.1, 105.5 and 101.5 Bustos applications have now been challenged properly which is what needed to to be done to get said applications dismissed.

    http://bit.ly/2DaNfhd

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