AFCCE News & Events
Sep 07

Comments solicited for RM-11727 (“Class C4 FM”)

On January 22, 2013, SSR Communications, Inc. (“SSR”) filed a petition for Rulemaking to create a new Zone II FM broadcast station class, or “C4” allocation, and amend certain technical rules for the FM broadcast service.

The petition is here:  Class C4. The FCC has extended the deadline for filing statements in support of or in opposition to the SSR Petition by one month, until September 18, 2014. The deadline for filing replies to such statements is October 3, 2014.   See DA-14-1182A1. AFCCE members interested in this matter may post their comments on the web page.


  1. Steve Crowley
    September 11, 2014 at 8:41 pm ·

    What are the engineering issues in this matter that would be of concern to AFCCE?

  2. Ben Evans
    September 17, 2014 at 6:51 pm ·

    The Class C4 proposal seems to be reasonably thought out, but there are issues I see that are problematic.

    In allowing stations to upgrade their facilities, the proposal intends to compel stations that are underutilized for their class and are NOT authorized as Section 73.215 stations, to become Section 73.215 stations if the upgrade sought by the first station isn’t possible otherwise. The station applying for the upgrade would “trigger” an order to show cause, directed to the conflicting underutilized station, which would direct that station to seek an upgrade to maximum class facilities. The way I understand it, if the station receiving the show cause order gets a CP for such an upgrade, the triggering application is dismissed, but if it doesn’t follow through, or chooses not to apply, the station is automatically designated as a 73.215 station on its license.

    This is sort of what the FCC did when they created the “C0” Class, which the proponent makes reference to. However, this Class C4 proposed rulemaking seems to go way beyond that. In the case of the Class C0, the underutilized Class C station would have had their Class designation downgraded to C0, but if the station’s facilities were under the maximum for that class, it retained the right to upgrade to full Class C0 anytime in the future. The same was done when the FCC created the Class C1 years before that. (Does anyone remember what was done when the Class C3 came along?) However, this PRM goes way beyond that by locking in underutilized non-73.215 stations to its actual facilities operated at the time, by designating them as 73.215. What’s more, the PRM as written seems to permit this process not only in the case of Class A stations seeking to upgrade to Class C4, but for any proposed minor change by an FM station of any class.

    I think there’s general agreement that increasing opportunities for more coverage is a laudable goal, but is this too radial a change to the FM rules? Is this going to cause harm and is it even fair to stations that, for financial reasons or some other type of adverse circumstance, are operating below maximum class facilities, but would like to upgrade when things get better? Should the order to show cause provision of the PRM be strictly limited to reclassifying Class C3 stations not meeting the new proposed Class C3 minimum to Class C4? Authorization under Section 73.215 is currently only at the discretion of stations that request it on their own. Would a 73.215 designation by external force of administration be contrary to the original intent of Section 73.215? What about stations that are short-spaced under Section 73.213? I don’t see that those are addressed in this PRM.

    The second issue I see with this PRM is this: Should the FCC entertain Class C4 drop-ins as well as upgrades from A to C4? Would a counterproposal for a new drop-in be accepted in response to an upgrade by an existing station, and how would the mutual exclusivity be resolved?

    Replies to my post are most welcome.