[BC] STL question

[Mike McCarthy]

With all due respect Scott, I beg to differ.  While the rules are 
clear about what's considered a translator and what isn't, its the 
world of legal eagles which cause many rules to be tossed out or 
their interpretations shifted to meet the situation at hand.

The issue here is whether the FM is not servicing it's community of 
license as a result of a 100% duplicative program received by an OTA 
relay which centers on a different community. This IS a defacto 
condition of translators and is the point some sharp lawyer might 
make about that case.--The FM being a defacto translator regardless 
of what the rules say about full class stations.  This could apply to 
any station (AM or FM) duplicating program via an OTA relay AND not 
having an alternate means of delivery.

Having said that, if the licensee feeds Station B by something NOT 
derived from the actual OTA signal of Station A, that argument is no 
longer valid and the station is simply simulcast.  A whole different 
scenario with very different issues.

MM

At 10:17 PM 4/8/2007 -0400, Scott Fybush wrote:
>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.)