RM-9419 [ETC]
RM-9419;
ETC 
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In the matter of RM-9419 to allow
certain AM licensees to be able to
operate FM translators.
BEFORE THE FEDERAL COMMUNICATIONS
COMMISSION, Washington D.C.
COMMENTS
1. I am filing these comments to oppose the American Community AM Broadcasters Association’s
(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’s. 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’s, 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
stations to operate FM translators would give these stations an unfair advantage over their higher
powered AM counterparts.
6. The Commission is currently considering RM-9208 and RM-9242 which would permit the licensing of
Low Power FM (LPFM) stations. Any action on this petition should be stayed until the RM-9208 and
RM-9242 proceedings are completed.
7. The AM community should look at other methods of extending their nighttime service. These could
include petitioning the Commission to allow for synchronous operation of AM stations on the same
channel or the possibility of migrating lower power AM broadcast stations to 5 kHz channels (such as
1235, 1245, 1255, 1265, etc.). This is currently being done by some stations in the Caribbean.
8. I would support this petition if the Commission would consider my previous petition to allow LPFM
stations (undocketed proceeding) to use FM frequencies in the 82-88MHz band where no NTSC
Channel 6 is in operation. These AM stations can also apply for channels in this band.
9. I oppose the position ACAMBA takes on arbitrarily relocating non-commercial translators carrying
satellite-fed programming to another channel between 201-220. This tells me that ACAMBA is
asking for something more than secondary status for their FM translator stations. While I don’t
approve of these non-commercial satellite-fed translators, I have to defend their secondary allocation to
their licensed channel.
10. In conclusion, lower powered AM stations were designed to provide a daytime service to local
listeners during the prime listening hours while clear channel AM stations provided a nighttime service
over a wide area. These stations knew this when they were issued their licenses. There have been
interference problems since KDKA in 1922. The Commission should look at alternatives such as
synchronous operation (which works in the UK) and 5 kHz channeling (which works in the
Caribbean). The Commission specifically banned FM simulcasting of AM stations many years ago.
Respectfully Submitted,
Richard Eyre-Eagles
REC Networks
PO Box 2408
Tempe AZ 85280-2408
January 15, 1999
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