April 23, 1998
Office of the Secretary (1800)
Room 222
Federal Communications Commission
1919 M Street, NW
Washington, DC 20554
Reference: RM-9208
Susquehanna Radio Corp., (Susquehanna), licensee of 6 AM and 14 FM radio stations offers these comments on the requests for amendment of the Commission's rules to authorize the operation of low power radio stations.
Susquehanna, a broadcast station licensee for more than 55 years, opposes any authorization of low or micro-power radio stations. Our opposition is not made out of concern for economic damage to existing broadcasters but out of concern for the technical viability of the existing AM and FM bands.
The Leggett Request
This proposal appears to be contradictory in its basic premises. Leggett consistently cites the need for "niche" programming and their desire to serve "niche" markets. Their stated purpose for the proposed service is in part:
"New musical groups could present their products to society and new social and political options could be discussed. Specialized stations would arise addressing specific subjects and activities such as golfing, flying, archery, energy conservation, ecology, animal rights, etc."Susquehanna, which spends a great deal of time and money in programming research, finds it difficult to understand how any "niche" market can be served by an FM station operating with one watt and an antenna height of 50 feet. Programming to "niche" markets can only succeed with a station that has wide coverage. It is illogical to expect a reasonable number of persons interested in archery or ecology to live within several blocks of this transmitter. Anyone interested in expressing his social or political opinion would reach far more interested listeners by calling a full service radio talk show than on any number of one watt radio stations. Susquehanna's main concern with micro-power broadcasting is that it would probably not remain "micro" for very long. Attached is a recent Internet listing of FM transmitter kits available from Steven Dunifer's Radio Free Berkeley. For $105, anyone can purchase a 40 watt amplifier to add to their one watt micro-power station. If the Commission could make spectrum available for micro-power FM stations, the equipment available from Radio Free Berkeley and others will quickly destroy the operation of any licensee that is operating with a maximum of one watt.
The TRA Communications Request
This request for a low power FM broadcast service would have merit if spectrum were available; unfortunately, it is not.
The petitioner relies on statements of engineering consultants and broadcasters as well as the Commission's conclusions in Docket No.96-120 concerning Grandfathered Short-Spaced FM Stations. The petitioner does not seem to recognize that this group of stations is considered to be "special" under the Commission's new rules. These are short spaced stations where the probability of interference presently exists. The industry discussion and Commission's conclusion in this Docket was to eliminate second and third channel restrictions only in these special cases because interference already exists due to their present short spacing. The Commission's decision was to retain these restrictions for all other stations and new allocations because they did not want to create new interference.
Susquehanna believes that with the adoption of Docket 80-90 and its present allocation polices, the Commission has maximized the use of the FM spectrum and any further change in the allocation tables would severely damage our existing FM broadcasting system.
As Susquehanna looks to the future of radio broadcasting, we envision to the emergence of Digital Radio and the incorporation of In-Band On-Channel (IBOC). A great deal of research and development into the possibility of IBOC has been completed and at least two systems are presently proposed. In these potential systems, the digital information resides in the area between 100 kHz. and 200 kHz. removed from the station's carrier. This digital information is actually in the spectrum of the first adjacent channel and is kept at a very low level in order to fit within the FCC required RF spectrum mask. These systems are very dependent on the existing FCC allocation policy and would be seriously hampered by the elimination of the second adjacent allocation separation requirements.
For the preservation of our existing system of radio broadcasting and to allow the development of a digital broadcasting service for the United States, Susquehanna urges the Commission to dismiss both of these requests for Rulemaking.
Sincerely,
Charles T. Morgan
CTM/mek
[link substituted for attached exhibit. hh]
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