The Trouble with Translators

March 29, 2012

What are translators, and what do they have to do with community radio?

Translators are repeater stations that rebroadcast other stations. Translators were originally intended to help nearby stations to extend or strengthen their signal, especially to reach remote or mountainous locations. But large translator networks have used translators to rebroadcast the same content nationwide, taking up space on the dial that could go to local community radio stations. The conflict between translators and low power FM (LPFM) goes back to 2003, when the FCC nearly gave away all available spectrum for community radio to translators.

In 2003 the FCC opened an auction for translators, and over 13,000 applications were filed. Many were from just a few companies planning to sell their (free) translator licenses for a profit or to blanket the country with the same content in every market. These translator applications threatened to use up all the space available for LPFMs, especially in cites where the FM dial is already crowded. In 2005, Prometheus filed a petition pointing this out and the FCC froze the translator applications. The freeze lasted from 2005 until March 2012, when the FCC released rules to set a balance between LPFM and translators. 

How did the FCC resolve the backlog of translator applications?

In July 2011, the FCC released proposed rules to handle the translators, and in March 2012, the FCC released the final version of those rules. The rules dismiss certain translator applications in 80 "spectrum limited" markets where the FCC determined that there is not sufficient room for LPFM. In order to thwart speculators seeking to profit off selling hundreds of licenses without actually using them to serve the public, the rules also set a cap of 50 translator applications per applicant, as well as a cap of one application per applicant per market. 

This plan replaces an earlier FCC proposal, the "ten cap," which would have capped each translator applicant at ten applications each. The ten cap would have thwarted speculators by limited the number of licenses they could sell, but the ten cap didn't actually preserve frequencies for LPFM. Read more about the ten cap.

How did the FCC determine which markets are "spectrum limited"? 

The FCC studied LPFM availability in the core urban area of the Top 150 radio markets, counting the number of channels available for future LPFM stations. If that number met a minimum "floor" set by the FCC, that market was designed as "spectrum available," meaning that there were sufficient channels available to process the translators in that market. If the number did not meet the market's floor, then the market was designed as "spectrum limited," triggering a different set of translator processing rules.

In spectrum limited markets, the FCC will dismiss any translator application that blocks an LPFM opportunity identified by the FCC in core urban area of the market. Outside that core urban area, the FCC will dismiss any translator application unless that applicant can prove there's room for an LPFM at the same location on a different frequency.

The floor set in each market depends on that market's Arbitron Metro ranking, so that larger markets have a higher minimum number of LPFM channels needed before translators could be processed.

 To determine whether the number of available channels in each market met the floor, the FCC did a study of the central area in each market. An Arbitron market is big, encompassing several counties, so the FCC used a grid covering the central area of each market, the urban core with the densest population that could benefit from community radio. The grid area was 30x30 minutes (a measure of latitude/longitude) in size. The FCC did a study of the spectrum in each grid to predict how many channels are likely to be available for LPFM if all pending translator applications were processed. If the number of available channels was equal to or less than the floor, the pending translator applications  that conflict with future LPFM opportunities will be dismissed. 

The FCC originally designated 66 markets as spectrum limited, but they added 14 more markets to their list thanks to advocacy from Prometheus, Common Frequency, and REC Networks. We argued that the FCC's grid was too big, covering areas with little or no population, and advocated for a 20x20 minute grid rather than the 30x30 minute grid. The FCC partially agreed, and decided to apply our 20x20 grid, but only in markets with lower  population density. This resulted in 14 more markets listed as spectrum limited.

What's next?

The FCC has to process the translator applications, which will take months, and complete the rules for LPFM, before setting a timeline for accepting LPFM applications.