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Implications of abandoning the Table of Allotments

Under the current rules, if you want to upgrade or move an FM station, you have to show that there is a location at which a fully-spaced allotment can be made. It does not have to be large. It does not have to be practical. It can be under water. You don’t even need to tell the FCC that you plan to build there. And time and again, I have looked at upgrades that could not be done because there was no such theoretical location.

Under this proposal, that requirement would disappear. From the standpoint of facility improvements, it is hard to imagine a more positive action that the FCC could reasonably take. If a transmitter site or upgrade of a current site works under 73.215, then you could apply for it as a minor change as long as the city of license is the same. And even the city of license requirement may go away, as discussed in Newsletter #1.

The existing presumption of non-interference with any station for which the 73.207 fully-spaced distance requirement is met will continue. Interference will still need to be studied for conflicts within the 73.215 distance bands. In this respect, there is no proposal from the FCC to change the rules. Eliminating the requirement for a fully-spaced allotment location would make it far easier to get to the point where you need to look at such things.

At least one commenter suggested that the FCC should do away with all mileage separation requirements in rule 73.215, which would provide even more flexibility. It remains to be seen whether that idea will gain any traction in this proceeding.

This proposal to eliminate the Table of Allotments is not a done deal by any means. But if it comes to pass, you will be granted extraordinary flexibility to upgrade your FM facilities. It won’t work for everyone, of course, but it will make the odds a lot better.

And here is the key point: Consult with your technical and legal experts early. What applies to you applies equally to your competitors and to the other stations on your frequency. Those who are best prepared, who jump at the opportunity, will have the most to gain.

We don’t know how the FCC will implement this new rule, if they do it at all. There may be a filing window, or it may be a first-come, first-served free for all. However they do it, the better prepared you are, the more likely you are to have an outcome that can significantly increase the value of your station!

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