Following up on Commission clarification of protection requirements, Bureau offers tips on tracking down data on translator input signals.
As we reported a couple of days ago, as soon as it cranked back up after the government shutdown, the FCC issued an order that, among other things, provided LPFM applicants additional guidance with respect to their obligation to protect FM translators’ off-air input signals on third adjacent channels. To provide for such protection, of course, the LPFM applicant must first know what off-air input signals it’s supposed to be protecting. And now, as a follow-up to the Commission’s order, the Media Bureau has released a separate notice providing some tips on tracking down that information.
The good news here is that data on FM translator input signals are available. The bad news is that, to get to those data, you’ll have to wade into the deep waters of the CDBS database and then grope around a bit. This is not for the faint of heart. (The Bureau “encourages” applicants to review the “readme” file before trying to download any data – a sure sign that accessing and understanding the data may not be as easy as one might think.)
According to the notice, FM translator input information can be found in either of two data tables (the “facility” table and the “int_translator” table). But the data fields to look for differ from one table to the other and the data entries may not be intuitively obvious to some folks.
For example, if you’re trying to determine the “delivery method” of an input signal, you go to the “delivery_method” field in the “int_translator” table. That makes sense, but when you get there you find either a “D” or a “V”, values that aren’t especially helpful unless you’ve read the notice’s footnote tipping you off to the less-than-obvious fact that “‘D’ denotes off-air signal delivery, ‘V’ denotes off-air signal delivery from (‘via’) another translator”.
Oh, and did we mention that the data in one table may be inconsistent with data in the other? Acknowledging that, the Bureau advises that applicants should rely on the “assoc_facility_id” data in the “facility” table to identify the station being rebroadcast by the translator. But sometimes that “assoc_facility_id” field is empty. When that happens, applicants should use the “int_translator” table.
And despite traditional cautions against making assumptions, the Bureau instructs that:
[i]n instances where the “assoc_facility_id” specifies the facility ID number of an authorized translator, LPFM applicants should assume that the translator is rebroadcasting the signal of the referenced authorized translator, directly off-air, and thus entitled to Section 73.827 protections. Furthermore, in instances where there is no information available about the delivery method, applicants should assume that the input signal is received directly off-air.
FM translator licensees should be comforted – and LPFM applicants concerned – by the Bureau’s further admonition that specific determinations concerning any particular translator’s input signal and/or delivery method may be made if the translator licensee can “document proper and timely notification”. In other words, it’s possible that some data that were submitted to the Commission never made it into the database at all.
All of this is a good faith effort on the Bureau’s part to deal with the grim and ugly truth that the information about translator input signals stored in the FCC’s databases is less than complete and reliable. That’s partly because some translators were authorized before the Commission even started collecting and recording these data. It’s also partly because, since collection/recordation began, input station and delivery method data have been submitted in several different forms. It’s probably also at least in part attributable to the fact that, historically, such data have not been of particularly great importance in the overall scheme of FCC regulation.
Whatever the source of the problem, the Bureau’s public notice (and the FCC’s latest order), provide LPFM applicants with considerable guidance for navigating that problem. LPFM applicants should be sure to take advantage of that guidance.
