[BC] SCA ON TRANSLATORS

[Tom Taggart]

I would agree with Mike:

Sec. 74.1231 provides:

"(c) The transmissions of each FM translator or booster station shall be intended only for direct reception by the general public. An FM translator or booster shall not be operated solely for the purpose of relaying signals to one or more fixed received points for retransmission, distribution, or further relaying in order to establish a point-to-point FM radio relay system."
However, the section goes on to say:
"(d) The technical characteristics of the retransmitted signals shall not be deliberately altered so as to hinder reception on conventional FM broadcast receivers."
Given the design of the original translators, which simply received the main station's signal, dropped it down to IF, then beat it back up to the "translated" frequency, it would have been somewhat difficult to remove the 67 or 92 khz subcarriers then commonly in use--without "deliberately altering" the retransmitted signals.
HD signals and RDS signals are designed to be received by the general public, so adding HD along with an SCA--it becomes a major endeavor to remove the SCA without also removing the HD signal.  Unless, of course, they are regenerated at the translator site.
Further, as a practical matter, the most common use of SCA anymore is probably radio reading services.  Given that the Congress mandated the Commission to provide provide protection to stations with such services when considering 2nd adjacent LPFM's, I would argue by implication that a translator would be allowed to carry such an SCA and would receive protection as well on the input frequency.