BEFORE THE FEDERAL COMMUNICATIONS
COMMISSION, Washington D.C.
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In the matter of RM-9419 to allow
certain AM licensees to be able to
operate FM translators.
COMMENTS
1.
I am filing these comments to oppose the American Community AM Broadcasters Association鈥檚
(ACAMBA) petition.
This petition calls for AM broadcasters which meets certain power
qualifications and have no FM station in the same market to be able to obtain FM translators in order
to provide nighttime service.
2.
The AM service (formerly known as the Standard Broadcasting Service) has been in existence since
the 1920鈥檚. The original AM stations were only licensed on one of two frequencies. Stations were
subject to interference. Due to the interference caused by co-channel stations, more channels were
created. In my generation, the FCC spearheaded the expansion of the AM broadcast band to 1700kHz
in an effort to reduce interference.
3.
The bottom line is that interference is a reality. When a licensee originally was granted their
broadcast license, they should have known their station was subject to nighttime interference.
4.
Back in the 80鈥檚, the broadcasters hung themselves by demanding that additional stations be given
nighttime authority on designated clear-channel frequencies. For example, here in Phoenix, we have a
station on 740kHz. This station used to be a daytime only station back when it was KMEO(AM). The
station now has unlimited authority with reduced power and a directional antenna. The station can not
be heard 8 miles away because of interference from KCBS(AM), San Francisco. The reason, 740kHz
is a clear channel. There really is no need for this station in Phoenix to be operating at night on
740kHz.
5.
By allowing the AM stations to operate FM translators, we are granting them a service area that they
were not entitled to in the first place. I also see this petition as an attempt to allow the AM stations to
be allowed to simulcast on FM, a practice that I thought was banned many years ago so the FM band
would be able to diverse from AM when AM was the primary broadcasting band. Allowing AM
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