June 2000 Newsletter

News from the Offices of

Munn-Reese, Inc.

Broadcast Engineering Consultants

100 Airport Drive – PO Box 220

Coldwater, MI 49036-0220

Wayne S. Reese, President

Telephone: 517-278-7339

Internet: www.munn-reese.com

Fax: 517-278-6973

June 2000

Munn-Reese Matters

Our wacky editor, Thumbs Feebleman, was overheard mumbling something about "making a list and checking it twice." We all thought he’d lost track of what month it was again, but it turned out he was just talking about our station list for the annual AM occupied spectrum measurements. The beautiful, lush growth of late June with green grass, green trees, and beautiful dark green corn reminds us that it will soon be the season for large flies, mosquitoes, and other biting insects. Thus, it must be time for our Field Engineer, Ed "ET" Trombley to hit the road for his annual tour of AM occupied spectrum measurements—sometimes also called NRSC measurements. Ed swats the "elements" while checking various AM stations throughout Michigan, Indiana, and Ohio. In fact, by now readers in those states should have received a fax from Ed regarding our annual package. If for some reason your station did not receive the information, let us know so we can provide you with the full details. Our package pricing is based on grouping stations together by geographic area so it’s important that we hear from you soon if you wish to be included on the tour. You can sign up by telephone, fax, e-mail, or on our web site.

As mentioned in last month’s newsletter, our package includes all of the required measurements including two spectrum analyzer plots for each mode of operation requiring measurements. Harmonics and other spurious responses are checked and measured with a calibrated field intensity meter. Once Ed gets the data back to the office, you will receive a complete, signed report that meets all of the requirements of §73.1590 including the measurement results and measurement methodology. AM stations are required to make these measurements annually at intervals not exceeding 14 months. All stations must keep a report of occupied spectrum measurements on file for a period of two years.

We have been finding more useful features in our recently upgraded version of the Probe II™ software package from V-Soft. In addition to the very useful studies combining coverage and interference that were mentioned in the previous newsletter, the new version of the program also includes the ability to show street level mapping for small-scale maps. This allows us to show a close-up view of coverage in small areas using either FCC contours or Longley-Rice type prediction methods. This feature also shows good promise for showing areas where a transmitter site can be located and still meet the Commission’s spacing requirements. Another new feature is the ability to show the combined coverage of a group of stations. This can be done with the traditional multi-colored Longley-Rice style of maps. Alternately, a separate color can be assigned to each station, and the map can be setup to show which station has the strongest signal throughout the combined coverage area. Contact our President, Wayne Reese, for full details on how these features might benefit your operation.

Commission Matters

The first filing window for Low Power FM (LPFM) applications has been completed, but not before being extended by the Commission due to unanticipated problems with the new electronic filing system. The original filing window was scheduled to open May 30 and close on June 5. However, the Commission received complaints that applicants were having problems with the electronic filing system on June 3 and 4. Therefore, the closing of the window was postponed for both paper and electronic filings until June 8.

On June 21, the FCC announced that 769 LPFM applications were filed during the window. The list was included in the Daily Digest for that date, and most applications appear to be available for inspection at the CDBS (Consolidated Data Base System) site on the Mass Media Bureau web page. It remains to be seen how many of these applications can actually be granted. Even absent action from Congress or the Courts to restore third adjacent channel protections, some applications can be expected to fail because of mutually exclusive status or errors in the documents that were filed. The next LPFM filing window is scheduled to open at the end of August—although no official announcement has been made yet. It will include transmitter sites in the following locations: Connecticut, Illinois, Kansas, Michigan, Minnesota, Mississippi, Nevada, New Hampshire, Puerto Rico, Virginia, and Wyoming.

The FCC has announced a limited filing window for Low Power Television (LPTV), Television Translators, and Class A Television facilities. The window will open on July 31 and close August 4. During the window, applications may be filed for new facilities or major changes in existing facilities provided the transmitter sites meet the geographic restrictions of the window. Transmitter sites must be at least 75 miles (121 km) from a long list of community reference coordinates listed in an attachment to the Public Notice announcing the window (DA 00-1383). The Commission has indicated it will consider waiver requests for locations that fail to meet the spacing requirements if those locations can be shown to be isolated from the listed communities by terrain shielding. Mutually exclusive applications received during this window will be subject to auction.

For purposes of this filing window, a major change is defined as any change in output frequency, other than a change in the precision offset of the carrier frequency, or any change that would increase the distance to the station’s protected contour in any direction. The Report and Order establishing Class A TV service included a more inclusive definition of minor changes for Class A TV, LPTV, and TV Translators that would even include power increases. However, the more inclusive definition does not become effective until October 1. Although some Class A applications can be filed at any time, holders of Class A licenses or construction permits will have to file their non-exempt applications during filing windows.

Those who decide to file during the upcoming window will face a combination of electronic and paper filing requirements. The short form application, Form 175, will have to be filed electronically before the end of the window. In addition, paper copies of the appropriate form, FCC Form 346 or 301-CA, will have to be filed in triplicate, along with a printed copy of the Form 175 that was filed electronically! Applicants are cautioned to use the June 2000 version of the paper forms. A statement highlighted in bold print in the Public Notice warns that neither older paper versions nor electronically filed versions of the new long forms will be accepted.

The FCC has announced the availability of four new broadcast related forms. FCC Form 302-CA is to be used by qualifying LPTV stations to apply for Class A status. The Commission released a Public Notice in early June that contained a complete list of qualifying stations. The initial application for Class A status can be made at any time during a six month period that began on June 9^th—the effective date of the Class A Report and Order. The form will also be used for applications for a license to cover any subsequent construction permits received by Class A stations. Unlike the other new forms, Form 302-CA can be filed electronically through the CDBS link on the Mass Media Bureau page. Paper copies can be printed from the files available on the FCC Forms page.

The other three forms, FCC Form 301-CA, 346, and 347, must be filed in paper form. The forms are "certification based" and electronic filing of them at some point in the future seems virtually certain. Form 301-CA is a new form and will be used for applications requesting changes in authorized Class A TV facilities. The new versions of Forms 346 and 347 replace the existing versions of these forms that are used for LPTV, TV Translator, and TV Booster station applications. The old forms can be used until July 14, but will automatically be returned after that date. The new version of Form 346 is designated as the June 2000 edition, and the new Form 347 is designated as the April 2000 edition. All three forms are available for downloading from the Commission’s web site.

The FCC is updating the search tools for its web site. The new system is known as the Electronic Document Management System, or EDOCS. The system will provide interactive research to users and aid them in retrieving documents from the web site. The system will also create indexes as an alternate tool for finding documents. EDOCS will contain electronic copies of documents back to March 1996 and also will contain citations to the FCC Record Index, FCC Reports 2^nd Series, and the Federal Register back to 1982. The FCC cautions that there could be some service disruptions during the changeover to the new system.

Have you ever tried to explain the FCC Guidelines for human exposure to radiofrequency radiation to a concerned listener or viewer, a neighbor to your transmitter site, or a zoning board? Then you may be interested in a new guide the FCC has just released in cooperation with the Local and State Government Advisory Committee. The document is designed to be a "plain English" guide to assist non-technical people in understanding the FCC radiation guidelines. The guide explains the exposure limits and how they were derived. It also provides some guidance in determining what kinds of facilities are least likely to be a source of excessive exposure. The official title is "A Local Government Official’s Guide to RF Emission Antenna Safety: Rules, Procedures, and Practical Guidance." It is available in a downloadable format from the FCC web site.

The Commission has issued a report on its biennial review of broadcast ownership rules. The full report (FCC 00-191) is available on the FCC web site and is quite lengthy. However, the News Release announcing the report provided a summary of the information it contained. Basically, the FCC decided to retain, but modify, three areas of the ownership rules, and it proposed the elimination of one other restriction. The Commission indicated it will issue a Notice of Proposed Rulemaking (NPRM) to receive comments on each of the proposed changes.

The first area of proposed change would allow one of the established television networks (ABC, CBS, FOX, or NBC) to also own an emerging network (WBTN or UPN). Since the emerging networks are subsidiaries of large program producers, the Commission believes such a merger could promote economic efficiencies without destroying diversity and competition. Any merger of the established networks would continue to be prohibited.

The second area of proposed change involves the radio ownership rules. The Commission believes that limiting the number of stations that can be commonly owned in a market continues to be necessary to avoid further erosion of competition and diversity. However, it said an NPRM will be issued to address how radio markets are defined and how stations are counted. Comments will be requested on whether Arbitron market definitions should replace the current contour area definition. The NPRM is also expected to address the methodology used to count stations within a given market. The News Release said, "The Commission also noted that its current methodology may produce unrealistic results in certain circumstances where a station is counted as being in a market but is not counted against a licensee’s cap on the number of stations it may own in that market."

In general, the Commission has decided to continue the newspaper/broadcast cross-ownership rules. While it recognized that media markets have undergone great changes in recent years, the Commission does not believe that many of the new outlets can actually serve as substitutes for newspapers and/or broadcasters at the local level. The Commission also believes that newspaper/broadcast combinations could produce some economic efficiency in their news departments, but this efficiency would come at the expense of diversity and competition. However, the Commission believes there may be some instances in which the size of the market, along with the size and type of newspaper and broadcast facility involved, might permit cross-ownership without endangering diversity and competition. It will examine such circumstances more closely.

Lastly, the Commission believes it can safely eliminate the ban on owning multiple experimental broadcast stations. These facilities are designed to develop and advance new technology. The Commission said other rules that prohibit charging for programming or establishing regular program schedules on these research facilities would be sufficient to preclude the kind of commercial abuse the ban on multiple ownership was designed to prevent.

Miscellaneous Matters

The Commission is providing further implementation of the Satellite Home Viewer Improvement Act (SHVIA). The SHVIA requires the FCC to adopt rules regarding satellite carriage of local TV signals by November 29, 2000. The NPRM seeks comments on a whole array of issues including market definitions, DTV obligations, duplicating signals, compensation for carriage, etc. Comments are due by July 7 with reply comments due by July 28. The NPRM was issued by the Cable Services Bureau.

For years, television broadcasters have been prohibited from using Channel 37 (608-614 MHz). This frequency band has been reserved for radio astronomy use. Now the FCC has established a new Wireless Medical Telemetry Service (WMTS), which will be allowed to use Channel 37, along with two other frequency bands. The service previously operated on unoccupied television allotments on a secondary basis. With the increased use of the television spectrum by DTV and relocated LPTV/Class A stations, interference free operation was becoming more difficult. The allocation of specific frequencies for the service should improve reliability of the transmitted data.

Upcoming Matters

We hope you are finding time to enjoy the beautiful summer weather. The warmer weather is always a more pleasant time to inspect and/or repair transmitter buildings, towers, and equipment shelters. It’s also a good time to make sure the vegetation (hopefully grass) over AM ground systems has not turned into a jungle! It might even be a good time for management and the engineering department to make a joint inspection of the transmitter site and discuss maintenance needs. The outdoor preventative maintenance work is much more pleasant during the warmer months than the emergency "get it back on the air" maintenance during the dead of winter.

The changing rules and processing procedures at the Commission necessitate changes in the technical strategies for improving existing stations. The staff and management of Munn-Reese, Inc. continues to thank you for the opportunity to help meet your consulting needs. We welcome the opportunity to help you determine what effect the current rules may have on your facility. Please let us know when we can help you.

*E-Mail Addresses*
Wayne Reese, President	wayne@munn-reese.com
Chris Reese, Accounting	chris@munn-reese.com
Don Baad, Staff Engineer	don@munn-reese.com
Ed Trombley, Field Service Engineer	et@munn-reese.com
Justin Asher, Staff Engineer	justin@munn-reese.com
Thumbs Feebleman, Newsletter Editor	thumbs@munn-reese.com