[BC] Re: [Tech-Assist] STL question

[Scott Fybush]

Mike McCarthy wrote:
> I'm seeing two different questions...
> 
> I don't see any reason using the AM as a ICR or STL could not be done.  
> There is nothing in Part 73 which limits the means to transport program 
> audio in either the final hop or intermediate hop.

Agreed. Here in Rochester, our public broadcaster WXXI (where I work 
part-time in the news department, in what I laughingly call "spare 
time") uses an AM off-air pickup as a backup STL to WRUR, the University 
of Rochester FM station that WXXI operates under an LMA-ish deal. (The 
main STL, when WXXI is feeding programming to WRUR, is a subchannel of 
WXXI-TV's DTV signal.)

> HOWEVER, be careful of the translator rules because a sharp attorney 
> might see that as a translator without a parent FM station and press 
> that matter. Especially if the programming is 100% duplicated day after 
> day.

This, I don't agree with. A translator is a translator and a full-power 
licensed AM or FM station is a full-power license. There is a clear 
prohibition in the translator rules on using an AM to originate 
programming, but those rules explicitly apply only to facilities 
licensed as translators, which this one wouldn't be.

> I would suggest you install a codec of some sort (or P2P IP--Barix 
> boxes) and maintain that for proving the program carriage is not a 
> translator and that the AM is simply a convenient relay. You could use 
> that means at night when the AM may have skywave or lightning problems.  
> Then make sure you shut off the stereo sub-carrier as the programming 
> brought in on the AM (or codec) will be mono unless you are using C-QUAM.
> 
> That said, in order to avoid all of this and if it's possible, I would 
> install a digital STL or something between the AM and FM TX's.

Agreed, again. If the stations in question are the ones I think they 
might be, the AM is all of 200 watts at night on a Mexican/Canadian 
clear channel, 67 km from the FM that will be relaying it. I'm not sure 
I'd trust that path to deliver clean audio on a regular basis, or even 
as a backup.

Heck, if there's POTS service at the FM site for telemetry, I'd look at 
using a POTS codec as an STL before I'd want to trust an AM-on-FM 
relay...but if that's what needs to be done, it does look legal to me.

(Usual disclaimers: IANAL, I don't speak for WXXI or anyone but myself, 
etc.)

s