The Broadcasters' Desktop Resource

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

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 Pop 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.