II A. Access By Public Broadcasters To Frequencies Outside of the Reserved FM Band Is Often Essential To Extend or Maintain Service
Public radio broadcasters often require access to frequencies outside of the reserved noncommercial educational band for both full-service radio stations and FM translators in order to extend or maintain service. The portion of the FM band reserved for noncommercial educational broadcasters (87.9-91.9 MHz) is very small in proportion to the entire FM band (87.9-107.9 MHz). In many areas of the country, the reserved FM band is either filled or unsuitable for additional full-service stations because of FCC rules requiring stations in the reserved FM band to protect against interference to television channel 6 stations or to other spectrum users. Thus, public broadcasters often must look outside of the reserved FM band if they seek new FM frequencies. There are no reserved channels in the AM band, which means that public broadcasters must apply for frequencies outside of the reserved band if they wish to provide a noncommercial educational AM service.
Approximately 37 NPR members have already established full-service noncommercial educational stations outside of the reserved FM band, including eight stations in Alaska (which are also NFCB members), seven stations in Michigan, three stations in Indiana and three stations in New York. Three NFCB members in addition to the Alaska members mentioned above have established full-service FM radio stations outside of the reserved FM band: one in each of New York City, Berkeley, CA, and Provincetown, MA. Approximately 29 NPR members have established full-service noncommercial educational stations on the AM band, including three stations in each of Alaska, Iowa and New York. Three NFCB members are located on the AM band: one in each of New Mexico, North Dakota and West Virginia. The flexibility of these public radio stations to make changes that would improve, extend or even maintain their service could be restricted if the Commission adopted rules subjecting mutually-exclusive modification applications to auctions. Public radio stations cannot afford a loss of flexibility at a time when the conversion to digital television may force many public radio stations to relocate or otherwise modify their facilities.
In addition to these existing noncommercial educational radio stations on the AM band and unreserved FM band, approximately 30 of the mutually-exclusive applications currently pending for radio frequencies outside of the reserved FM band were filed by applicants proposing a noncommercial educational service. Some of these applicants are NPR or NFCB members. While the number of noncommercial educational applicants is small in comparison with the total number of pending applications, the allocations are important to the public broadcasters who have applied for them. Indeed, given public broadcasters’ lack the resources, they typically have identified a critical need before filing an application for a new license.
Many rural and isolated communities rely upon FM translators to receive public radio station signals. However, due to the limited number of reserved FM frequencies, unreserved frequencies are often essential for the establishment of noncommercial FM translators. The number of reserved FM frequencies available for translator use is limited further by FCC rules that require FM translators to protect against interference with television channel 6 stations and other spectrum users. These rules and spectrum crowding frequently render the reserved FM band off-limits to FM translators throughout much of the country. Thus, public radio stations from such states as Arizona, Iowa, Minnesota, New Mexico, and Wisconsin, to name just a few, have established or applied for FM translator stations on frequencies outside of the reserved FM band. For instance, twelve of Minnesota Public Radio’s 18 FM translators are currently located outside of the reserved FM band.
Public radio stations require access to frequencies outside of the reserved FM band for FM translators not only to extend public radio service to underserved communities, but often simply to maintain existing service. Since FM translators are a "secondary" service, they frequently must be relocated in order to ensure that the translator does not cause any actual interference to a new or newly-modified full-service station. For example, the University of Northern Iowa estimates that it has been forced to relocate FM translators five times over the last ten years. As the FM broadcast spectrum gets more and more crowded, and as the conversion to digital television proceeds, the relocation of FM translators will become even more commonplace. If public broadcasters must participate in auctions every time they are forced to relocate a translator, there could be a downward spiral in the coverage of public radio and, hence, a silencing of diverse programming in many parts of the country.