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60 Years with the Very Helpful FCC
by Ken Benner, CBRE, NCE

This month marks the anniversary of my first experience with staff members of the FCC back in 1958. I was stationed at a U.S. Navy teleprinter relay facility on a mountaintop in North Africa.  Some of us had obtained our MARS (Military Affiliated Radio Service) licenses to exchange teleprinter messages with our families back home.

To communicate verbally during a period of excellent sunspot ionospheric activity, using a rotatable beam antenna on the 20-meter American phone band, we were able, for about six hours each night, to arrange phone patches with a fellow “ham” operator in New York, to avoid the $15 per minute transatlantic cable costs. The operator would simply place a phone call to the serviceman's loved ones for a live 8000-mile chat.

I needed a U.S. amateur operator license to operate and with the cooperation of the FCC, I was granted my first FCC amateur radio license following a couple exam tests. This was my first experience of extraordinary cooperation with the Commission that continues to this day with never the slightest problem.

On more than one occasion, I have requested the presence of an FCC regional engineer/inspector for seminars conducted at broadcaster conventions.  Each request was always promptly granted.

While on the road conducting Alternative Inspections, I would frequently be confronted with a question I could not address.  A simple phone call to either the regional FCC office or their offices in Washington promptly provided the information to resolve any problem or question.

On more than one occasion following my certification of a station’s compliance, a problem between a station and the FCC would develop. Such was almost always the result of a complaint filed with the FCC by a competitor seeking the forfeiture of a license, a disgruntled former employee, or a party unhappy with a station's program resulting from a disturbing news item related to the complainant. 

In every instance, once I was made aware of such issues, following a review of my inspection reports for the victim stations, I was able to satisfactorily document, admittedly some times under oath, the reality of the station’s innocence resulting in a satisfactory review of a possible fine.

The staff of the Federal Communications Commission are willing to assist any station with helpful suggestions for anyone approaching them with absolute integrity.  Indeed,  such has been my experience for the past 60 years.

Charlie Goodrich Remembered

by Dwight Morgan

It is with much sadness that I read that Charley Goodrich has passed. 

He helped me many times (at all hours) with needing parts or help with a radio station that was giving me fits. I once had a station with the transmitter in a 2-story log house in Gunnison, CO., that had some tube problems and he was the patient engineer that talked me through the tube and socket replacement. 

I have had his phone number for many years in my address book and today it was erased in the book, but not in my memory.

(Have a Charlie Goodrich story? Share here.)

The Impact of MB 18-184 
The FM Class C4 / 73.215 Proposal

by Matthew Wesolowski
SSR Communications, Inc.

From now until August 13th, the Federal Communications Commission is accepting formal comments in the FM Class C4 / 73.215 (MB 18-184) Notice of Inquiry proceeding.  The NOI seeks to ascertain the demand for a new Zone II FM station power class, the "FM Class C4" allocation, and if changes to 73.215 are warranted for certain long-underbuilt FM facilities.

Approximately 800 FM Class A radio stations could be eligible to upgrade from a maximum reference effective radiated power level of 6,000 Watts to 12,000 Watts under the proposal.  In many cases, the 73.215 changes would further enhance the ability of small stations to improve their facilities.

The National Association of Broadcasters, iHeart, and all of the other "usual suspects" are not apt to support the plan.  The "big guys" already own prime radio real estate, and collectively, only operate a handful of the nearly 800 stations that could benefit.  There is simply no reason for larger broadcasters to be enthusiastic about the proposal.  In short, a turf war is brewing between independent stations and the broadcast megacorps.

Still, over seventy-five small broadcasters have already submitted their comments in support of full implementation of the MB 18-184 proceeding, and with several weeks to go until the comment deadline, it is likely safe to assume that more positive letters are coming and that the demand is clearly there for the adoption of the MB 18-184 proposal.

Even if just 200-300 stations actually take advantage of the changes, the benefits would be almost exclusively for smaller "Mom and Pop" and independent operators.  These are the broadcasters who didn't sell out to the larger groups and are still very viable in their communities.  In other words, the smallest commercial class of broadcasters stand to gain the most.

Though it very well may be the case that some stations use this proceeding as an opportunity to become rimshot signals to larger markets, for the most part, any station with that goal in mind would likely have to move further away from an urban core in order to upgrade to a FM Class C4 license, as the separation tables are greater for the C4 class.

The proponents are a "rag tag" bunch, to be sure, but the opposition is very well funded and will not want to see any increased competition from the small Mom and Po
p and independent stations.  By and large, the big guys will not want a new station class, nor will they want to cede any potential bandwidth to a (seemingly) meeker broadcaster.

The MB 18-184 FM / Class C4 and 73.215 proposal represents a tremendous opportunity for responsible small broadcasters everywhere.  It is the precise type of relief that independent operators seek, and the exact tool that would help the "little guy" regain a competitive toehold in the industry to which they have exhibited their total devotion

Repacking the C-Band

by Clay Freinwald

Sitting just a few feet from FCC Chairman Pai at NAB recently I came away thinking that he is not anti-broadcast…Then I learned his position regarding C-Band (3.7-4.2 Gig) Called Mid-Band by the wireless industry.  Once again we are in a defensive position in terms of spectrum.  The wireless industry is not dumb – They want additional spectrum and they consider any of that is not heavily used fair-game…On the surface, apparently, our C-Band qualified.

Remember the battle over the 2 Gig spectrum when the wireless industry set its sights on that band?  Broadcasters were scrambling to show the FCC that we did indeed use the spectrum a lot more than they thought.  The issue was the lack of information regarding the number and location of receivers.  Frankly, we were caught short on this one…As a result we experienced our first dose of ‘repacking’…(even if it was not called that).  In the end, we lost spectrum.

Then it was deemed that Broadcasters were never going to use all the TV spectrum they were allocated….and, on top of that, the FCC had done a poor job of spectrum management with the switch from analog to digital and the case was made to ‘re-pack’ TV….One more time, we lost ground.

Now the wireless ‘cross-hairs’ are on C-Band.  This spectrum has been used for a very long time for program/network distribution and, in the minds of many, is un-utilized…..”Wireless Speak’ for ‘We want it’.  Much like the 2-Gig issue, broadcasters have laid back thinking that the FCC was never going to let anyone else use this band…Nothing to fear.  All it took is for the Wireless crowd to assert that the band was under-utilized and contend that, at least, it could be shared by them.  IMHO, much of the blame here rests with Broadcasters, in particular Radio Stations, that have sprinkled satellite receiving antennas all over the land and not bothered to have any formal data documenting all this use.  This ‘under-counting’ is proving to be dangerous.  Now, all of a sudden there is this scramble to try and make a case that this is not a suitable location for shared use.  Whether or not we will be successful at beating back this threat remains to be seen.

History has shown that, when confronted with this kind of a situation, that we may well be looking for a loss of spectrum in exchange for a smaller piece of the pie with some protection.  Several organizations are involved in this battle – NAB, NPR, iHeartMedia, program distributors, networks etc.

Has this has put the FCC in a position that, perhaps, they did not see coming?

On the Wireless side – they are making it clear that they need the spectrum, and this particular piece is ideal for their new 5G systems.  Seems to me that this pits the desire of new ‘Gee-Whiz’ wireless toys up against old fashioned systems that are frequency hogs anyway.  Let’s face it – 5G is being pre-sold as the do-all, end-all, wireless system that’s likely exciting to the policy makers while Broadcasting is being pushed to the rear of the bus as old technology.

We were being told that the FCC would be voting in July on the proposal….Then we got word that the filing deadline had been extended to October 17.  As a lot of media coverage has pointed out.  Our C-Band systems impact a huge amount of Radio and TV operations.  A lot of fingers are crossed – My Guess – Standby for more re-packing.  See GN Docket Nos. 18-122.


The FCC is O&O By Non-Broadcasters

by Bill Shrode

Fact plain and simple. The current FCC is owned and operated by the cellular industry and the current administration.

Actually, the FCC has been in the "real estate" business ("spectrally" speaking) since the Reagan era (which I refer to as "de-Reagan-ulation") There has not been a genuine engineer on the FCC in decades.

Knowledge of what and how the spectrum is and does should be required.

Too Much Money for Too Little Promise

by Tom Miller

As an owner of a small group of stations, I am not sure I want to draw attention to myself and my licenses, but as background, I will tell you that I have been on the air for almost 40 years. I have owned my own stations for more than 20 years, and I am a two-time past president of our state broadcaster's association.


Ron Schacht's editorial echoes several of my concerns with this whole C-Band dish issue. I have one 3.8 meter Comtech dish out back, that drives several receivers, and at this point, I am not planning to spend the $435.00 to register the dish, nor the $1200.00, plus or minus, for the frequency coordination. I have discussed this with my lawyer, and with a couple of NAB rep's, and I cannot figure out what I am getting for the money that they are asking me to spend.

The following is a copy & paste of my thoughts in an e-mail conversation with my broadcast lawyer...

"The $435 is a filing fee. It does not license my receive dish. It does not guarantee any rights or protections... nor does the frequency coordination.

I think it is disingenuous for the FCC to ask for information, and then put up a monetary impediment to my providing that information. I would gladly send them the information - it is not a secret dish - but I am not willing to pay them to take the information, especially with no guarantee for protection to follow it up.


(NAB rep) estimated 25 thousand dishes could be registered... times $435 is over $10 million dollars, and I am frustrated that the FCC is encouraging the industry to send that kind of money to the Treasury for no reason, no return, no promise, no kiss at the end of the night.

We could apply the same logic to AM revitalization. Let us register all the whip antennas on all the vehicles so we know how many are out there, and then we will "protect" them from interference.

At the end of the day, this will all be decided well above my pay grade.

The satellite owners are licensed to operate in those frequencies. If they choose to sell off portions of those frequencies, it affects their business models, but maybe they make enough money off the sale to not care, and take the buyout, which is not affected by my $435 dollars.


All of the programming providers who distribute through those satellites will have to find another way to reliably distribute their services - in my case, three music formats, CBS News, NBC Sports, and three sports networks. Streaming is not reliable enough for longform live programming, and nobody is singing the praises of KU band.

Maybe 5G will become the distribution means. If C-Band is screwed, so are these guys, and registration of my dish will not matter, because they will have to find a different way for their customers to get their product."

Food for thought.

FCC: Wake Up About C-Band Use!

by Ron Schacht

Back when I was in 8th grade, which was about two months before rocks were formed, I sat in Geography class and, as usual, was paying no attention to where Egypt or Mesopotamia were located. Instead, I was drawing out a schematic of the class B modulator with a pair of 6L6’s that I wanted to build for my 40 meter CW rig.

Out of a clear blue sky, I heard my name and looked up.

The teacher was looking at me with a quizzical expression. It was obvious he asked me a question concerning something and, of course, it had nothing to do with 807’s or 6L6’s so I had no idea what would be a good answer. After a long sweaty pause, he finally broke the silence with this little gem “Mr. Schacht, it's about time you wake up and smell the coffee.”

Well, that line is where I am going with this thought concerning the FCC and the C-Band debacle.


It seems to me, that the agency that licenses and controls all of the radio spectrum would vaguely know what everyone else in the communications industry knows: C-Band satellite transmission is the lifeblood of television, radio, CATV, and a great deal of data transmissions.

I would have to say, rather than the Commission ask every broadcast station, and CATV system to register their antenna (of course for commercial purposes at an unnecessarily high fee) CATV, radio and television that do not use C-Band downlinks should register!

There probably are very few excepting LPFM’s (although I do take care of a big 100 Watter that does have a C-Band downlink) so why cannot the Commission just accept the fact that every broadcast station, TV, radio, commercial and non-com are all using C-Band downlinks? C-Band is also the lifeblood of every CATV system so I am sure the Commission knows where every one of them exists as well. 


Now, about those frequencies.

Take a look at the RF spectrum as is allocated by the FCC. You can find it in most radio books and all over the Internet. How much spectrum does “radiolocation” need? Yes, this is radar and the like but I really think of what is listed as “radiolocation” is either unoccupied or being saved for government use. Why not share some of that underused spectrum? There is a whole bunch of it around 3 GHz. along with lots of other places.

More importantly, why do we, the broadcasters have to keeping making concessions for the cellular and broadband people, other than money talks and they have lots of it?


Do you know why the cellular people and broadband people have so much money to bully the FCC around and the broadcasters and CATV people have so little?

The reason is because, while we are certainly in the business of making money, we are also community servants. Right now, as I write this, we are under a tornado warning and severe storm warnings in Iowa. The local radio stations are tracking the storms and I am listening to them do live coverage. What broadcast is doing is using their licensed facilities to keep people safe and save lives.

On the other hand, the cellular people do very little of that, they just rake in money to provide a telephone and an Internet service that works ”some of the time.” Sure they send out alerts. I have two cellular phones from two different carriers. I hear severe weather alerts on local radio or television as NOAA trips the EAS system.


Anywhere between 10 and 30 minutes later, severe weather might trip one or both of my cell phones.

By then, the storm has passed, or I might have been sucked up in a tornado I did not know about, or the Amber Alert child is three states away.

Neither the cell phones nor the Internet even come close to what the broadcasters provide in their communities. Unlike the cell companies or the broadband providers, the broadcasters will do whatever is necessary to keep the public informed in an emergency - Stations operating from their transmitter sites when the studio was leveled by a tornado or AM’ers stringing up long wires when their tower is toppled - Local radio and television will be there when the public needs them.


Have you ever tried to use the Internet or cell service for a program link?

Yes, both radio and television do but it is no match for the reliability or quality you get from a satellite. A few of the stations that I deal with have given up carrying some college football teams because the provider went off the bird and onto the Internet and it just is not reliable.

The Internet and cell phones are nice but as toys. But if I need to make an important call, I will always go to a landline, it sounds good and I will nott lose the call.

Maybe, rather than give the cell and broadband more spectrum, the Commission should require that they make what they have work and not keep reducing the sample rate of the calls to make more money by squeezing more calls onto each RF carrier.


So, my message to the FCC: maybe you should look at less used spectrum for the broadband people.

Take it away from somewhere else. You have taken our TV ENG channels, our over-the-air TV channels, and have had your eyes set on our UHF RPU frequencies. And now, our you are focusing on the major source of programming outside the studio, C-Band. We are doing our damned best to serve the people of our communities, over the air, commercial or non-commercial, in spite of the big money trying to make us stop watching free TV or listen to free radio and keep us safe.

I think it is time for the FCC to wake up and smell the coffee!!       

Ron Schacht
Contract Engineer - Northcentral Iowa and Southcentral, MN

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