Tuesday, October 18, 2011

FCC doesn't buy smartphone as interference solution

The FCC has refused to allow the licensee of an FM translator to offer smartphones as a solution to interference to FM radio reception in Michigan.

A new radio station was launched in Detroit in April. Smooth jazz station "Oasis 104.7" broadcast over the HD2 subchannel of WGPR-107.5 -- and in analog over translator station W284BQ.

FM translators are not allowed to cause interference to full-power "regular" FM stations. Even if the normal engineering methods suggest no interference should occur, if complaints of actual interference are received, the translator must either make technical changes to eliminate it, or cease operations.

Translator W284BQ operates on 104.7 in Detroit. When it began operation this spring, listeners in Ypsilanti, Belleville and Taylor, Michigan contacted full-power station WIOT, on the same frequency in Toledo, Ohio 50 miles to the south, complaining of interference to WIOT's signal.

In July, the owners of W284BQ modified its antenna to reduce signal to the south, in the direction of the complainants. This seems to have resolved five of the 28 complaints. Another thirteen could not be contacted or refused to cooperate; and one doesn't listen to WIOT anymore & doesn't care about the interference.

W284BQ offered the remaining nine complainants free smartphones with the iheartradio.com application. This can be used to listen to participating radio stations online; WIOT is one of the stations that participates in this program. The translator agreed to pay both for the smartphone hardware, and the airtime charges. Eight of the nine accepted the offer.

However, WIOT doesn't buy in to this plan. They gave the FCC several areas of concern:
- WIOT may discontinue participation in iheartradio.com;
- The wireless network may fail;
- Smartphone listeners won't hear unstreamed content; (some material may not be licensed for broadcast over the Internet, where it may be heard in other markets where someone else has the rights)
- It's not entirely certain W284BQ would continue to pay the airtime fees indefinitely.

WIOT also mentioned 58 additional complaints. While they didn't explicitly say so, it would seem the smartphone solution doesn't do anything for listeners who might not listen to WIOT now, but who might hear the station & decide to listen to it in the future -- unless they can't receive it due to interference from W284BQ.

The FCC raised three additional issues:
- WIOT only forwarded complaints from listeners living within the station's "protected contour". The translator is responsible for resolving all complaints. (and given the densely populated area in which such interference is likely to occur, there are likely to be many such complaints.)
- Who's responsible for maintenance? If one of the smartphones is damaged or lost, will the translator pay for its repair or replacement?
- How can a cash-strapped FCC monitor & enforce compliance with such an unusual solution?

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The Commission has decided W284BQ's solution is not workable. Pursuant to regulation 74.1203, a translator that interferes with a "regular" station must be shut down -- and the FCC has so ordered.

1 comment:

Doug Smith said...

W284BQ may be shut down, but it's not dead.

When I wrote that post, it already had a permit to move to 93.9. There's a 100,000-watt station on that frequency just a few miles away in Windsor, Ontario.

That's legal, because Canadian stations are not protected from interference as long as the interference happens wholly within the U.S.. (and vice-versa: the Canadian coverage of U.S. stations is not protected either)

But you can reasonably assume Windsor's CIDR-FM would pretty much destroy W284BQ's coverage.

To which end, W284BQ has already filed to change frequency again, this time to 93.5.

There is a reason for the seemingly dumb interim move to 93.9. The FCC defines two types of technical changes: "minor" and "major".

Basically, "minor" changes are those where the existing technical facilities and the proposed new facilities could not exist at the same time without interfering with each other. For example, a station proposes to change frequency from 96.5 to 96.7 without changing transmitter location or power. 96.5 and 96.7 at the same site would interfere with each other -- so the move would be a minor change.

"Major" changes then, are those where the old and new facilities could co-exist.

The FCC only accepts requests for major changes during "filing windows", periods of a week or two. These windows aren't held very often. It could easily be five years before the next filing window for FM translators is held.

So you really don't want to file a major change, unless you're really, really patient.

W284BQ moving from 104.7 to 93.5 would be a major change. Moving from 104.7 to 93.9 isn't.

(the 10.8MHz difference between 104.7 and 93.9 is a "magic number". The "intermediate frequency amplifiers" in most FM radios operate at 10.6, 10.7, or 10.8MHz. If two stations in the same city operate on frequencies separated by one of these values, their signals are likely to mix within these amplifiers in cheap receivers. The result: listeners hear a mix of both stations - regardless of what frequency they've set their dial to,)

93.9 to 93.5 is, again, mutually exclusive & thus a "minor" change.

So, instead of making one major change from 104.7 to 93.5, W284BQ makes two minor changes, from 104.7 to 93.9 and then from 93.9 to 93.5.

The station must file for a "license to cover" for the intermediate 93.9 frequency first, before it can apply to move again to 93.5. Requesting a license to cover requires that the station be operational on the 93.9 channel. However, there's no minimum requirement for how long it must operate on 93.9. A few minutes will do.

(Why didn't W284BQ select 93.5 in the first place? I'm not sure, but I note the move from 104.7 to 93.5 includes a power reduction from 250 watts to 99 watts. 99 watts is also a "magic number" -- at powers of less than 100 watts, less paperwork is required -- but it's possible higher powers on 93.5 would interfere with something else.)