FM6 stations have until Jan. 29 to officially state their intention to continue service and to confirm their operational parameters to the FCC.

These stations are the low-power TV broadcasters that operate as radio stations on frequencies just below the FM band, a practice that earned them the nickname Franken FMs.

Last summer, the FCC ruled that 14 such stations in nine states can continue to provide these analog radio services. They essentially have been grandfathered in, resolving the longstanding regulatory issue.

Many of the stations are in or near major markets, so this outcome essentially means that several big U.S. cities now officially have one more FM station for the many consumers whose radios can pick up the frequencies.

The authorized stations are KBKF(LD), San Jose, Calif.; WMTO(LD), Norfolk, Va.; KXDP(LD), Denver; WTBS(LD), Atlanta; WRME(LD), Chicago; KZNO(LD), Big Bear Lake, Calif.; KEFM(LD), Sacramento; WEYS(LD), Miami; WDCN(LD), Fairfax, Va., near Washington, D.C.; KRPE(LD), San Diego; KGHD(LD), Las Vegas; WPGF(LD), Memphis; and WNYZ(LD), New York. 

The FCC also permitted WVOA(LD) in Westvale, N.Y., near Syracuse, to provide FM6 service subject to certain requirements. That FM6 went back on the air in December at 87.7 MHz.

The commission will not allow new FM6 entrants or the return of other legacy analog FM6 stations that ceased or never previously provided radio service. “Effective immediately, the bureau will not process STA extension requests filed by any FM6 LPTV stations … The bureau also will promptly dismiss any STA requests for new FM6 operations.”

The Media Bureau has set Jan. 29 as the deadline for the 14 stations to notify it of their intent to continue to provide FM6 service and to confirm their operational parameters.

The bureau said all FM6 LPTV stations with unexpired STAs or pending STA extensions will be considered in compliance with its rules as long as their operations adhere to the recent order. Once an operational notice is received, the bureau will add a notation to each LPTV station’s license to reflect that it is permitted to provide FM6 operations as an ancillary or supplementary service. 

These stations are required to maintain online public inspection files for their FM6 service. The FCC also reminded them that television stations that offer feeable ancillary or supplementary services are required to submit an annual report and pay a fee on the revenues from those services. If an FM6 LPTV station offers such services it must pay the fee. 

Details and instructions for the stations are outlined in the order (read it here).

This article originally appeared on TV Tech sister brand Radio World. 

WASHINGTON, D.C.—Following the July 20, 2023 FCC Report and Order adopting new rules regarding low power television stations operating on TV channel 6 (FM6, aka “Franken FM” LPTV stations), the FCC is reporting that most of those rules will go into effect on Sept. 28, 2023.

The Report and Order permitted a limited number of 14 low power TV stations operating on TV channel 6 (FM6) to maintain their existing analog FM radio services on an ancillary or supplementary basis subject to specific operational rules and requirements. TV Tech's extensive coverage of this issue can be found here. 

The FCC noted that on “August 29, 2023, the Office of the Federal Register published a summary of the Report and Order.  Accordingly, the effective date for the rules adopted in the Report and Order is September 28, 2023, except for those that require approval from the Office of Management and Budget (OMB)  including new sections 74.790(o)(9) and 74.790(o)(10) of the Commission’s rules;  the requirement for FM6 LPTV stations to maintain an online public inspection file;  and the requirement that FM6 LPTV stations notify the Commission of their intent to continue FM6 operations, provide their FM6 operational parameters, and notify the Commission of any changes to their operational parameters.” 

The FCC added that until the Commission receives OMB approval on the remaining rules and requirements, FM6 LPTV stations should continue to seek extensions of their current FM6 engineering special temporary authorizations (STAs).

The FCC also reported  that Metro TV, Inc. has until December 22, 2023 for WVOA-LD, Westvale, New York, to commence ATSC 3.0 and FM6 operations by filing an application to convert the station to ATSC 3.0 and a request for engineering STA.   

WASHINGTON, D.C.—As expected, the Federal Communications Commission has voted to permit a limited number of low power television (LPTV) stations operating on TV channel 6 (TV6) to maintain their existing analog FM radio services (FM6 operations). 

The operations are only permitted on an ancillary or supplementary basis subject to specific operational rules and requirements.

The FM6 or so-called “Franken FM” stations have emerged as an interesting issue in the transition to NextGen TV/ATSC 3.0 broadcasts, with the NAB and others backing the idea that some of these FM6 stations should be allowed to continue operations.

In July of 2022, the NAB filed comments with the FCC rejecting a proposal by NPR to repurpose some unused channel 6 spectrum for use as FM radio stations because that spectrum is playing an helpful role in the rollout of NextGen TV/ATSC 3.0 services and because it allowed those stations to deliver addition services to communities. 

Following the July 20 vote, the NAB issued a statement applauding the action. 

In the July 20 vote at the FCC’s August open meeting, the Commission voted on a Report and Order relating to the issue. 

In the Order, the FCC noted that since the 1980s, some TV6 LPTV stations have provided listeners local radio programming that could be picked up at the bottom of the FM dial, specifically on 87.7 MHz and 87.75 MHz. 

Because the TV6 band is directly adjacent to the FM band, it is accessible using standard FM receivers. Listeners have tuned to existing FM6 LPTV stations for foreign language, religious and sports programming, and emergency and public information, in addition to programming to support underserved populations including native Spanish speakers and immigrants, the FCC reported. . 

The FCC also explained that following the July 2021 LPTV digital transition, newly digital LPTV stations operating on TV6 and providing this audio service were no longer able to reach their analog radio audience through their digital TV transmission.

After examining the issue, the Report and Order found that it is in the public interest to permit a limited group of 14 TV6 LPTV stations to continue to provide analog audio service if they can be operated on a non-interference basis.  

Preserving the long-time audio programming offered by these remaining stations aligns with the Commission’s core principles guiding the digital transition—minimizing service disruptions, the FCC said. 

The Order also adopts technical rules and requirements governing how FM6 LPTV stations will be permitted to continue to operate in order to prevent interference to their own digital TV operations and adjacent channel FM radio stations, preserve their free over-the-air TV service, and ensure their FM6 operations continue to serve the public interest. 

However, the FCC's Order declined to repurpose TV6 spectrum (82-88 MHz) for FM services in locations where it is not currently being used for television service. It also declined to amend current TV6 interference rules at this time.

In response to the Federal Communications Commission's approval of an order allowing existing channel 6 low power television stations to continue to provide analog FM radio service, NAB president and CEO Curtis LeGeyt said: "NAB thanks the FCC and the Media Bureau staff for its fair and efficient resolution of the use of the TV channel 6 frequency band by low power TV stations to provide ancillary audio programming. The order adopted by the Commission today will protect channel 6 television operators while recognizing the audience built by existing FM6 stations. We support the FCC’s balanced approach that addresses long-standing questions surrounding this complex issue."

In the vote on the Report and Order (FCC 23-58),  Chairwoman Rosenworcel, Commissioners Carr, Starks, and Simington voted to approve it. 

Extensive coverage of the issue can be found at our sister publication Radio World and at TV Tech in a series of articles on the subject by James O’Neal.  

WASHINGTON, D.C.—During its July meeting on July 20, the FCC will vote on issues relating to FM6 stations, aka “Franken FMs” and consider a Report and Order allowing a limited group of existing channel 6 low power television stations to continue to provide analog FM radio service as an ancillary or supplementary service.

The issue has emerged as an interesting one for the rollout of NextGen TV/ATSC 3.0 services as some LPTV stations converted to ATSC 3.0 broadcasts while offering a analog FM service. 

Last July, the NAB filed comments with the FCC rejecting a proposal by NPR to repurpose some unused channel 6 spectrum for use as FM radio stations because that spectrum is playing an helpful role in the rollout of NextGen TV/ATSC 3.0 services.   

The FCC issued Notice of Proposed Rulemaking last year and will now vote on an Order that allows 14 LPTV stations to continue to operate on 87.7 MHzs. The full order is available here.   

In announcing the agenda for the July meeting, FCC chair Jessica Rosenworcel noted that: “We’re preserving established local programming for radio audiences. For years, some low-power television stations licensed on Channel 6 have provided listeners local radio programming that was picked up on the FM dial. The Commission will vote to allow these so-called FM6 stations to continue providing their existing analog radio service by authorizing them as “ancillary or supplementary.”

In the proposed Order, the FCC noted that "Although FM6 LPTV stations were required to discontinue analog television operations and convert to digital in July 2021, there were 13 FM6 LPTV stations that were able to complete their digital transition and resume their FM6 operations with an FM6 STA with limited, if any, service interruptions.  We find that preserving the long-time audio programming offered by these remaining FM6 LPTV stations aligns with one of the Commission's core principles guiding the digital transition minimizing service disruptions. FM6 LPTV stations provide free, over-the-air synchronized video and audio programming using a standard-compliant ATSC 3.0 signal and supplement that programming with additional free, over-the-air analog audio broadcast services....[T]he availability of these additional audio services has provided programmers with a platform on which to invest in programming directed to unserved or underserved audiences that may not be available on any other stations in their markets all while continuing to provide free over-the-air video programming pursuant to their television licenses. To remove this service that radio listeners have relied on for many years would contravene the
Commission's goal of preserving service."   

While the FCC grandfathered those 13 stations. it did not allow new stations to offer the service in areas where it had not already been launched. Additional research by Radio World found that 14 stations, not 13, would be protected. 

Extensive coverage of the issue can be found at our sister publication Radio World and at TV Tech in a series of articles on the subject by James O’Neal.  

WASHINGTON D.C.—The NAB has filed comments with the FCC rejecting a proposal by NPR to repurpose some unused channel 6 spectrum for use as FM radio stations because that spectrum is playing an important role in the rollout of NextGen TV/ATSC 3.0 services. 

The comments were made in response to an FCC notice of proposed rulemaking relating to FM6, a.k.a. Franken FMs and on a proposal from National Public Radio that urged the FCC to repurpose channel 6 spectrum not being used by TV stations for FM radio.

The FM6 issue has reemerged as part of the transition to NextGen TV services and has been extensively covered by a TV Tech series of articles on the subject by James O’Neal. FM6 stations operate on 87.75 MHz. 

The FCC's notice of proposed rulemaking on the subject is asking for comments on whether it should allow future FM6 operations and on a wider issue of whether it should license radio stations on the 82–88 MHz spectrum in areas where Channel 6 LPTV and full-power stations are not operating. 

This would open up opportunities for new educational FM stations in underserved rural areas., NPR had argued in comments to the FCC. 

In its comments the NAB noted that “Channel 6 television stations provide critical service and…television service must have unconstrained primacy in that spectrum. NAB further submits that the existing 13 FM6 stations in that spectrum have developed a listener base, with no reports of interference, and therefore should be allowed to continue operation as presently authorized.”

In its arguments against repurposing the spectrum, the NAB reported that currently there are “presently 98 television stations authorized to operate on channel 6 in the United States. While some of these stations serve large, sparsely populated areas where the relatively low power consumption of channel 6 transmitters makes the provision of television service economical to rural Americans, others serve densely populated urban areas where no alternative channels exist in more desirable spectrum (i.e., VHF-High Band and UHF TV channels). A number of channel 6 stations also serve as `lighthouse' stations for NextGen TV, providing a critical transition path for television broadcasters as they migrate to ATSC 3.0.”

“Authorization of new FM stations in an FM expanded band created from television spectrum could also preclude new television stations,” the NAB said. “[T]here are already some channel 6 television stations serving as ATSC 3.0 lighthouse facilities, and additional such facilities may be needed as the rollout of NextGen TV progresses. The opposite need may exist near the end of the ATSC 3.0 transition. That is, DTV `nightlight' facilities on channel 6 may be needed to help ensure that legacy viewers still receive a signal. As television broadcasters voluntarily transition to ATSC 3.0 with no additional spectrum allocated by the Commission, it is important that existing television spectrum be preserved to help make this difficult transition as efficient as possible. Further, as the Commission has observed, consumer FM receivers cannot tune below 87.7 or 87.9 MHz and cannot be upgraded to do so, creating a massive legacy receiver base that cannot tune to most expanded FM band channels and discouraging FM broadcasters to propose operation in an expanded FM band. The expansion of the AM band 25 years ago may serve as a cautionary tale, with many of the expanded band channels originally allocated still fallow. NAB thus urges the Commission to reject NPR’s proposal to repurpose television channel 6 spectrum for FM services.”

While the NAB argued that the 13 existing FM6 stations be allowed to continue to operate as presently authorized as ancillary or supplemental services, it also said they should not be allowed to arbitrarily modify their operations. 

“It seems certain, however, that those 13 FM6 stations might impact FM stations operating in the reserved band (88--92 MHz), other channel 6 television stations, or their own TV6 video services, if they are allowed to arbitrarily modify their operations, for example, by increasing power, relocating, or adding Subsidiary Communications Services or In-Band On-Channel digital audio broadcasting services to their signals,” the NAB added. “There are presently no regulatory requirements that directly address FM6-to-reserved band FM (or other) interference and NAB submits it is critical to avoid increasing the risk of interference without a technical record to justify expanded uses. NAB therefore urges the Commission to restrict FM6 operations to the 13 FM6" stations currently operating. 

However, the NAB also stressed that FM6 stations must not degrade the ATSC 3.0 service and must comply with EAS requirements.

“NAB supports the proposed requirements that the channel 6 television (TV6) operation transmit rule-compliant ATSC-3 video and associated audio at all times the associated FM6 is in operation and that that the FM6 coverage area and populations may not exceed that of the TV6 operation,” the NAB said.

To avoid interference, NAB believes that “the requirement to transmit FM6 at 87.75 MHz is unnecessary and is linked to the now-obsolete NTSC television transmission system. Instead, NAB proposes requiring the 13 FM6 stations to operate on 87.7 MHz in order to give licensees the opportunity to improve analog FM6 reception while maintaining ATSC-3.0 compatibility. This small 50 kHz shift in frequency away from the FM band would presumably reduce the potential for interference to FM stations operating in the reserved band while improving compatibility and fidelity for FM receivers that can tune only in 200 kHz steps. Indeed, NAB notes that many or most FM6 operations apparently operate at 87.7 MHz and that the technical analysis done in support of FM6 operation in conjunction with ATSC 3.0 involved testing at 87.7 MHz.”

The NAB also argued that no change in the distance separation rules were justified at this time.

(Editor's note: This article originally appeared in Radio World.) 

The FCC has opened a notice of proposed rulemaking intended to decide whether FM6 stations have a permanent place in the U.S. broadcast landscape.

Chairwoman Jessica Rosenworcel may have indicated which way she is leaning on the issue when she previewed the NPRM by saying the commission would be “asking about preserving established local programming for radio audiences.” 

James O’Neal wrote about the new wave of FM6 stations in our March 30 and May 11 issues. He concludes the series here; this article was prepared prior to the release of the actual NPRM, summarized here and which you can read here.

Although many thought “Franken FMs” would quickly fade from the scene when the FCC pulled the plug on the last of the analog Ch. 6 LPTV operations last summer, this has not been the case. 

By now several of the new wave of ATSC 3.0 digital TV/87.75 MHz FM audio broadcasters are going strong, enabled via some 21st century RF filtering technology and FCC-issued STAs, of which 13 have been issued. 

The original (analog Ch. 6 video/FM audio carrier) Frankens certainly drew their share of comments from the radio broadcast community, and now this new wave of hybrid DTV/analog FM operations is coming under scrutiny, with some sharply divided opinions. 

We begin with comments from the implementer of the first of these “second-gen” Frankens.

Possibly the biggest proponent of the hybrid DTV/FM technology is Paul Koplin, CEO of Venture Technologies, which owns KBKF(LD), a San Jose, Calif. low-power Ch. 6 TV station that switched on its ATSC 3.0 DTV/analog FM operation in March of 2021.

“When we converted to digital [TV broadcasting], we thought about the best way to achieve a hybrid model and to the FCC, this works well,” said Koplin. There’s no interference between the two services per FCC rules.”

Koplin observed that VHF TV spectrum — especially the low-band Channels 2 through 6 — has become “low-rent” real estate due to the ever-increasing amount of manmade noise in that region, and says these new Frankens are able to wring some utility out of this region.

“This spectrum was a lemon and [with the hybrid broadcasting] we made it into lemonade,” said Koplin. “It’s a win-win solution.”

He noted that the initial STA on which KBKF was operating had been renewed, and looked forward to the day when the FCC officially recognized Ch. 6 hybrid broadcasting by codifying rules and regulations for it. In doing so, this would become an additional revenue stream for the commission.

“The FCC is getting additional revenue from what we’re doing as we’re paying supplemental fees,” he said, adding that “there’s no technical reason for anyone to oppose this. We’ve had no technical issues, and there’ve been no interference complaints. No major radio groups are opposing this sort of operation, only NPR. They don’t want anyone to the left of their dial position.” [In fact the National Association of Broadcasters and other major broadcast groups have filed vocal opposition.]

Koplin expects other Ch. 6 licensee to follow his lead, and perhaps even build on it by providing services that go beyond radio and television.

“It’s one step at a time right now,” he said. “We’re the first in the country to provide this service. The Channel 6 supplemental use case we’ve established is a pathway for other stations to use their spectrum for even more innovative services.”

“I just wish I’d thought of it!” remarked Chuck Conrad, the owner and general manager of Tyler-Longview, Texas radio stations KZQX(FM), KDOK(AM) and KYZX, when asked for his take on the Franken resurgence.

“If nothing else, I admire the ingenuity of whoever first implemented it. I’m sure a lot of other broadcasters will disagree with me because the industry doesn’t like additional competition. Why would they? If people are listening to the Franken FMs, it means they are not listening to their station. It’s a simple as that.”

A lot of objections past and present stem from potential interference to existing broadcast operations, and this concern is registered in the STAs under which the new Frankens are operating. Conrad was asked about this possible downside.

“When these Franken FM stations were riding along with an analog Channel 6 TV signal, the reports of interference to the lower end of the FM band were few and far between,” he said. “As far as I know, all were resolved. Some of those stations became quite successful. I see no reason to not give them the blessing of the commission.”

Aaron Read, the IT and engineering director at Rhode Island Public Radio, has a different opinion. Read, speaking only for himself and not for his employer, says the technology that’s enabling these new hybrid broadcasters might be valid, but the application of it is not.

“Technology is a tool, and tools are value-neutral,” said Read. “It’s how you use the tool that matters. And that’s why I have a problem with this use of the tech. It has nothing whatsoever to do with providing any television service, much less an improved television service. It’s merely an end-run around all the existing rules for creating FM radio stations. And worse, it bypasses most of the technical rules that protect FM radio stations from interfering with each other, and it also bypasses the FCC fee structure that the agency depends on for its operating revenue.” 

Dave Kolesar, a senior broadcast engineer at Washington’s WTOP and Federal News Network, shares the belief that the first- and second-gen Frankens are a somewhat misdirected application of technology for creating an FM radio service.

Kolesar, also speaking for himself and not on behalf of his employer, stated: “I think the evidence for this is based upon the fact that in the analog days such operations were generally not marketed to the public as television stations, and so 6 MHz of RF spectrum was effectively allocated for just one analog FM signal. 

“In an ideal world,” he said, “I’d like to see 87.7 and 87.9 opened to commercial FM service if there are no TV stations on Channel 6 in the area. In that ideal world, a Ch. 6 TV station could surrender its TV license and apply for an FM license on that channel.” 

He added that he did not favor a downwards expansion of the current FM band to occupy all of the TV Ch. 6 region, as there are no readily available receivers that cover this. He also feels that any new radio broadcasting spectrum allocations should be for digital services.

[Related: “Letter: We Don’t Need This Franken“]

Given the apparently popularity of these new DTV/analog FM stations, the FCC seems obliged to make a binding decision about them, rather than continue to renew STAs.

“I think if this concept is allowed to stand in any form,” Aaron Read said, “it’ll be inevitable that the FCC will be ‘forced’ to legitimize them, and also that you’ll see greater proliferation of LPTV-6s operating as ‘Franken FMs,’” said Read. “I put ‘forced’ in quotes since they are, of course, ‘forcing’ themselves by not blocking this service from existing in the first place.

“There has always been a strong ‘pro-TV at the expense of FM’ bias written into the Part 73 rules in the Code of Federal Regulations,” he continued. “But more than that, there literally is no regulatory structure in place to manage interference from these ‘Franken FMs.’”

He said regulation 47 CFR 73.525 has many rules and engineering specs, but they’re all in reference to the NTSC television standard, which no longer exists. 

“There [are] no rules for dealing with ATSC. How is anyone supposed to know when prohibited interference is legally occurring? And to say that these TV stations ‘aren’t allowed to interfere’ with FM is wildly disingenuous. How are FM stations supposed to prove that interference exists? By listener complaints? Does the FCC seriously expect your average listener to even realize when they’re hearing interference, much less recognize what the interference is, and know enough to contact the FM radio station about it?

“At a bare minimum, if the FCC is going to allow this terrible idea to proceed, a complete rewrite of 47 CFR 73.525 is an absolute necessity so that FM stations have something to fall back on.”

National Public Radio long been critical of Frankens due to the proximity of their 87.75 MHz operating frequency to that of non-commercial broadcast allocations, and it has filed objections about their operation. 

Asked about its stance on this second wave of Frankens, Marta McLellan Ross, the organization’s vice president of government and external affairs responded: “NPR continues to monitor the use of STAs and whether interference occurs as a result of their use. We remain vigilant for any actions that would result in interference with our member stations’ ability to reach their audiences.” 

[The FCC said in the new NPRM that it wants comments on an NPR proposal that the commission should license additional NCE FM radio stations on 82–88 MHz in areas where Channel 6 LPTV and full-power stations are not operating.]

[Related: “NPR Hopes Franken FM Resolution Includes New NCE Stations“]

As for the FCC’s position, a commission spokesperson provided this statement in May, prior to release of the NPRM:

“The provision of so-called ‘FM6 services’ has been going on for over a decade. Today, there are actually fewer stations that are operating in this manner. We have permitted these stations to continue operating pursuant to STAs, as we evaluate the technical, legal and policy issues surrounding these services. 

“In mid-2021, with the LPTV digital transition deadline fast approaching, the Media Bureau began granting six-month digital engineering STAs to some of the previous analog FM6 stations,” the spokesperson continued.

“This was an effort to minimize consumer disruption by allowing these previous analog FM6 stations to continue their FM6 operations after they converted to digital. To date, only 13 of the original analog FM6 stations have been granted these digital engineering STAs. The previous analog FM6 stations were required to convert to ATSC 3.0 digital operations and could continue FM6 operations separately through the six-month digital engineering STA. These STAs were granted with several conditions to ensure that there would be no harmful interference to other users and to also ensure that the station fulfilled its obligation to provide TV programming to its TV audience.”

The spokesperson said stations are required to report every three months on any interference complaints they had received, and that none of the stations has reported interference to date. Several of the STAs have been renewed for an additional six months since their initial grants.

Just as with about everything else these days, there seems to be no middle ground concerning these hybrid digital TV/analog FM operations. 

It would seem that the appeal to operators is biased on the radio side due to the potential ad revenue, a decline in off-air TV viewers, the relative scarcity of ATSC 3.0 receivers and the limited availability of LPTV stations on cable systems. 

However, this could change, making television broadcasting activities more viable. Also, given the continuing shift away from analog broadcasting, perhaps it’s just a matter of time before Major Armstrong’s wonderful, 90-year-old, interference-free broadcasting modality will be relegated to the history books; if so, even these “second-gen” Frankens will have no relevance and there will no longer be an issue. Only time will tell. 

Meanwhile, these hybrid DTV/FM stations continue to attract niche audiences and generate operating revenues for their owners or operators. 

[Related: Radio World Editor in Chief Paul McLane celebrates James O’Neal]

Comment on this or any article. Email radioworld@futurenet.com with “Letter to the Editor” in the subject line.

Saying it wants to bring “final resolution” to the Franken FM issue, the Federal Communications Commission has opened a notice of proposed rulemaking.

The debate over whether to allow FM6 stations could have a much broader impact than expected, depending on how the FCC ultimately acts. Because among the questions it is asking are these two: whether to allow future FM6 operations beyond those that currently have STAs; and more dramatically, whether to license additional NCE FM radio stations on 82–88 MHz in areas where Channel 6 LPTV and full-power stations are not operating. The latter idea has been proposed by NPR.

FM6 stations are the low-power digital television stations whose audio can be heard on many radios at 87.75 MHz — just below the official FM broadcast band — and which are essentially operating as FM stations. Thirteen stations currently have special temporary authority to do so.

Chairwoman Jessica Rosenworcel had indicated that the commission would take some action on the matter this month. But the FCC did not wait for that meeting, it has opened the NPRM asking for comments on whether it should allow FM6 as an ancillary or supplementary service under specified conditions.

It is also asking whether it should eliminate or revise the television Channel 6 distance separation rules for low-power FMs, noncommercial educational FMs, Class D (10 watt) FMs and FM translators that operate on reserved band FM Channels 201–220, which is 88.1 to 91.9 MHz.

Background
The commission thinks that nearly 30 FM6 stations existed prior to the digital TV transition. But many in the industry expected the question of Franken FMs to go away once LPTVs were required to go digital in the summer of 2021, because the digital portion of their signals could no longer be received by FM radios.

However, as has been documented on in a series of articles on TV Tech, FM6 stations have sought to maintain their service in the new digital TV age, arguing that they provide an important service.

As long ago as 2014, the FCC noted, Venture Technologies Group proposed to use an ATSC 1.0 digital television transmitter on Channel 6 and a separate analog radio transmitter tuned to 87.75 MHz to simultaneously operate a digital LPTV station on Channel 6 and an analog FM radio-type service. It asked the FCC to treat the analog FM audio transmission as an “ancillary or supplementary” service under the commission’s rules.

That year the commission took industry comments on the concept. A coalition of broadcasters supported it, while FM broadcasters, including National Public Radio and other noncommercial educational FM broadcasters, as well as full-power television stations licensed on Channel 6 opposed it, citing interference concerns. In 2019 the commission took another round of comments, again without taking final action.

But the LPTV digital transition was completed in July 2021. Shortly beforehand, Venture filed a request for STA to convert its Channel 6 TV station in San Jose, Calif., to ATSC 3.0 digital and to operate an ATSC 3.0 transmitter and a separate analog FM radio transmitter on 87.7 MHz in an analog format as an ancillary service. The Educational Media Foundation, which provides programming to the station, supported that request.

The Media Bureau granted its STA subject to a number of conditions. The station must operate in ATSC 3.0, not 1.0; it cannot create interference; it must file regular written reports; the audio and video coverage must reach similar populations; and the station must provide at least one full-time stream of synchronized video and audio programming on the ATSC 3.0 portion of the spectrum. There are several other requirements as well.

Twelve more STAs have since been granted under the same stipulations.

NPRM
The FCC now is asking:

• Whether FM6 operations serve the public interest and should be authorized to continue in any capacity.
• If existing FM6 operations should be authorized as “ancillary or supplementary” services and, if so, be subject to a rule that contains provisions similar to those in the 13 current STAs.
• Whether the FCC can or should limit FM6 operations to only those LPTV stations with active FM6 STAs right now.
• Whether to adopt NPR’s proposal to license additional NCE FM radio stations on 82–88 MHz in areas where Channel 6 LPTV and full-power stations are not operating.
• Whether to eliminate or revise the TV6 distance separation rules for LPFM, NCE, Class D (10 watt), and FM translator stations operating on reserved band FM Channels 201–220.

Those are the broad-brush questions. Among the many specific issues being raised in the FCC NPRM are these:

• Is it an efficient use of spectrum to use a 6 MHz television channel to provide a 200 kHz aural service?
• Could FM6 programming be delivered in a more spectrum-efficient way, e.g. as a digital audio-only stream on one of the LPTV’s multicast channels, through the internet or via traditional FM or LPFM licenses?
• How is analog use of a digital channel “consistent with” the digital technology mandated by the FCC for the provision of advanced TV services?
• Should the FCC limit LPTV stations providing FM6 operations from modifying their facilities?
• Should it limit such stations from being transferred while FM6 operations are being conducted, to avoid license speculation?
• Does the fact that stations are using ATSC 3.0 change the potential for analog FM6 to interfere with or disrupt the station’s digital TV service?
• Should FM6 stations be held to the rules that require public inspection files, border frequency coordination and other aspects of Part 73?
• If FM6s are allowed, should they be subject to a 5% fee, as required of certain digital TV ancillary or supplementary services?
• If the FCC decides to limit FM6 only to stations that currently have STAs, should it “grandfather in” any LPTVs that have pending applications for CPs that conducted FM6 operations in the past?

Since 1985 the FCC required FM stations on the reserved band to protect Channel 6 stations. In the NPRM it noted that four years ago, in weighing tweaks to the LPFM rules, it had considered whether to change that requirement, the idea being that the current provisions “significantly overprotect” TV6 stations and could be reduced with little impact. But it didn’t act.

So now that “analog television is … truly a legacy service” and the industry has experience with respect to digital TV6, the FCC asks again about the continued need for TV6 interference protection rules, including the possible impact if FM6 operations are retained — “that is, if FM6 and LPFM and NCE FM stations are allowed to come into closer proximity if the TV6 protection rules are eliminated, would that increase concerns about interference from FM6 to LPFM/NCE FM stations — an important factor in our FM6 considerations?”

The deadlines to comment in MB Docket No. 03-185 have not yet been published.

You can read the full NPRM here.

This article originally appeared in Radio World. 

FRESNO, Calif.—KMCF-LD Channel 6 in Fresno, Calif., has launched NextGen TV on VHF Channel 6 and expects to offer a full-power FM service at 87.7 on the radio dial. Once approved by the FCC, the hybrid service from the Cocola Broadcasting-owned low-power TV station would be among the first in the nation to offer a so-called “Franken FM”—TV stations that offer audio services via the 87.7 MHz audio carrier— enabled by ATSC 3.0. 

Fresno-based Cocola said “an early start on securing the equipment and FCC permission” allowed the company to be one of the first in Fresno to launch ATSC 3.0 and added that, unlike its full-power counterparts currently offering ATSC 3.0, it will broadcast in 4K.

“Programming for KMCF will be 4K productions including super high-definition NASA programming,” the company said in a statement. “There is a limited supply of 4K programming available at this time but with the launch of ATSC 3.0 now, Cocola Broadcasting will be able to add new 4K programming as it becomes available.”

The “Franken FM” would broadcast the signal of Fresno’s KJOI—known as "Your All Time Favorites"—through Channel 6. The FM signal doesn’t require special equipment but to watch the video portion of ATSC 3.0 requires a TV, tuner box or DVR designed to broadcast the upgraded signal to take advantage of the audio and video improvements.

Cocola Broadcasting was founded in the early 1980s by broadcasting veteran Gary Cocola who operates 56 channels in Fresno and 18 in Bakersfield. The launch of ATSC 3.0 is the latest example of Cocola Broadcasting embracing the most up-to-date technology to ensure the best digital service for local viewers. When Cocola launched his initial television station in 1985—Channel 59—it was the first TV station in Fresno to broadcast in stereo.

“I have always tried to be on the cutting edge of new technology,” Cocola said.

Franken FM is on the agenda at the FCC.

Chairwoman Jessica Rosenworcel has released a list of topics for the commission’s June meeting and FM6 is on it.

“We’re asking about preserving established local programming for radio audiences,” she wrote.

“For years, some low-power television stations licensed on Channel 6 have provided listeners local radio programming that was picked up on the FM dial, so-called FM6 stations. These stations sought to maintain this service to their existing audiences after the LPTV digital transition by seeking commission approval to provide their analog radio service as ‘ancillary or supplementary services.’”

Rosenworcel said the commission will consider a proposal to allow these broadcasters to continue their existing FM6 radio service, “provided that they meet certain conditions, including interference protection and the provision of a synchronous TV service to consumers.”

The Educational Media Foundation has been among those pressing the FCC for approval and clarification on policies around FM6 stations.

Tv Tech contributor James O’Neal has an ongoing series of articles on these stations; the first provided an overview, the second focuses on the tech behind the stations in the era of ATSC 3.0.

NEW YORK—The latest of the new wave of hybrid DTV/analog FM radio stations—WNYZ-LD—took to the air on March 22 as a fully-licensed “NextGen TV” station in the New York City borough of Queens, and in doing so, bested the full-power TV operations for the title of being the first in the Big Apple to air ATSC 3.0 broadcasts.

The 3 kW ERP TV Ch. 6 (82-88 MHz) station is licensed to Sound of Long Island Inc. (SOL) and transmits Korean language TV and radio broadcasts to the metropolitan New York City area and eastward towards Long Island, using a directional antenna in order to avoid interference with a full-power Ch. 6 operation in Philadelphia, southwest of WNYZ-LD’s transmitter location.

(Read: Next-Generation ‘Franken FMs’ on the Rise, Part I & Part II)

According to Clarence Beverage of Communications Technologies, Inc., the consulting engineer who set up the station, it’s one of a dozen or so second-generation hybrid TV Ch. 6 DTV/FM stations that had previously operated as analog “Frankens” for a number of years before the FCC sunset all remaining analog LPTV broadcasts last July. 

Beverage said that Young Kwon, SOL’s president, knew about the Venture Technologies' team in California and their groundbreaking work employing the new NextGen TV broadcast TV transmission standard, developed by the Advanced Television Systems Committee (ATSC), which enables broadcaster to deliver an array of new services and enhanced content features to consumers. 

Beverage observed that he gives a lot of credit to Venture, as they looked very carefully at FCC rules and realized that the implementation plan for ATSC 3.0 was not to just allow for television, but for other signals such as data, narrow-band audio, and the like as well.

He explained that Mr. Kwon had followed the progress of Venture Technologies in licensing their KBKF-LD former analog Ch. 6 LPTV for ATSC 3.0 and in obtaining an STA in early June to allow it to transmit an analog FM signal on their former analog TV 87.75 MHz audio carrier.

“When Mr. Kwon saw KBKF’ s success, he felt it was time to go forward to order equipment and formalize a lease for the new facilities for the [NYC] Ch. 6 DTV with ancillary audio signal,” said Beverage. “KBKF, in receiving their approvals, gave the SOL team a basis to begin to move things forward and allowed Mr. Kwon to plan to use the facility to provide separate minority-focused program content, 24 hours per day, for both television and radio signals. “ 

Beverage noted that WNYZ-LD’s transmission setup closely mirrors that used by Venture Technologies’ KBKF-LD with an equipment package provided by the Italian firm, SYES.

“There were really a limited number of people talking about manufacturing equipment for this application,” said Beverage. “SYES started early for the operation in California, and we thought they were the best choice. When we were ready to place the order, SYES was the only company with a station on the air with this configuration.”

He added that key to implementation of any NextGen TV operation is the ATSC 3.0 encoding gear, and the current price tag of around $80,000 for this technology has made it prohibitive for many low-power TV broadcasters.

“SYES worked with an encoder manufacturer to produce an encoder without a lot of bells and whistles,” said Beverage. “This one was $40,000, but is able to be expanded.” He added that many people probably are not aware of what it takes to put an ATSC 3.0 TV station on the air, and that unlike some of their earlier analog TV Franken precursors, the current stations are designed and operated to fully comply with extremely specific FCC rules and regulations.

“This is a really professionally-engineered no-interference very, very controlled implementation.”

Part 2 of 2

In the first installment of this article on the recent development of a “new breed” of Ch. 6 “Franken FM” TV/radio operations, several members of the ATSC 3.0 standards group voiced their opinions as to the validity and usefulness of these hybrid facilities that began popping up last year.

This time, we look at the engineering side of the “May/December” marriage of broadcasting that’s been around for such a short time that the “new” hasn’t even begun to wear off alongside one that’s existed for close to nine decades. This is, of course, the combining of an ATSC 3.0 digital television signal with that of an analog FM audio transmission.

The first station to try out the technology was Venture Technologies’ San Jose, Calif. Station, KBKF-LD, which began airing “second-gen” Franken signals last spring via an FCC Special Temporary Authority (STA) arrangement. 

This initial hybrid configuration was actually the creation of two RF technology companies, SYES (System Engineering Solutions) and Com-Tech. SYES’s vice president of sales for the Americas, Alessandro Annoni, provided a short history of the project.

“We worked together on this low VHF TV/FM combiner, beginning back in the late spring of 2020,” he said. “We designed a low-V transmitter working with a specific modulation/bandwidth and distortion, and a hybrid filter to avoid any type of interference or intermodulation. The amazing tech team of Venture Technologies, Daniel Bisset and Will Brownlie helped us to get this new system working in San Jose, back in February 2021.”

Jampro Antennas has also been working with LPTV Ch. 6 licensees to move to this new digital/analog broadcasting platform, with the company’s president, Alex Perchevitch, noting that while some amount of engineering effort was necessary to get the technology to the point where it could serve as a “proof of concept,” his company had earlier assisted analog Ch. 6 stations in delivering “standalone” FM radio services on 87.75 MHz.

“We were approached by a well-known consulting group on how to combine the FM audio with the Ch. 6 [video], and used modified diplexers similar to those we have produced since the 1960s for analog TV stations of various power levels,” he recalled.

Perchevitch said that his company’s recent grafting of 3.0 DTV with analog FM required the use of a modified Jampro VHF mask filter and some reworking the FM side of the operation to achieve a happy marriage. However, his company had a lot of experience working with installations involving the combining of multiple FM signals into a common antenna.

“This was not a new endeavor for us or one that required development of a new product group,” said Perchevitch. “We often supply FM combiners for frequency spacings as close as 400 kHz and this experience and product group provided the [expertise] and product to use for this hybrid TV/FM application.”

Even so, the initial assembly of a hybrid 3.0 DTV/analog FM Ch. 6 station did not exactly follow a “plug and play” script.

“We spent several months re-developing the filter technology to meet the requirements,” said Perchevitch. “Certainly, any time you are trying to combine frequencies which are so closely spaced and achieve high isolation with low insertion loss, it is a challenge.”

Franken FMs and ATSC 1.0?
In as much as the technology for combining closely spaced dissimilar RF signals has been available for some time now, one might naturally ask why such hybrid DTV/analog FM operations were not attempted by Ch. 6 licensees much sooner—perhaps coincident with the start of ATSC 1.0 broadcasting?

Actually, at least one full-power Ch. 6 station experimented with such a mixed transmission mode, but the results were less than satisfactory and the FCC refused to sanction it.

As explained by the Sinclair Broadcasting Group’s senior vice president of advanced technology, Mark Aitken, the reason for the failure of 1.0/FM pairing is simple. 

“ATSC 1.0 really precluded bifurcating spectrum occupancy,” he said. “As soon as you tried to shorten the bandwidth of the1.0 signal, you broke it; 3.0 is a different story.”

The Beginning of a Tsunami?
Could the apparent success of KBKF-LD and the other “second-gen” Frankens now on the air lead to the adoption of this hybrid mode of broadcasting by full power Ch. 6 operations? Perchevitch was asked if he saw any barriers that would preclude these Ch. 6 stations from airing dual-audience broadcasts.

“It’s certainly possible,” he responded. “And we believe it’s very possible that there will be more hybrid Ch.6 stations in the future.”

Perchevitch views this new breed of hybrid stations with optimism, as they squeeze additional utility of their 6-MHz chunks of spectrum, and added that he was not at all surprised at their rapid emergence.

“Lower power broadcasters and the consultants serving that industry have always been very creative in seeking ways to be competitive and generate revenue,” he said. “The use of CPOL (circular polarization) and EPOL (elliptical polarization) by LPTVs is a great example. Long before large numbers of full-power stations broadcast signals with EPOL or CPOL, LPTVs often were operating with elliptical or circular polarization. Franken FMs are all about addressing radios and the revenue from radio listeners, something [mainstream] TV to date has not been able to capitalize on.”

Bill Harland, vice president of marketing at Electronics Research, Inc. (ERI), was also not particularly surprised with the launching of what might be the vanguard of a common broadcasting practice.

“There are a number of Channel 6 LPTV stations in the U.S. that have been operating in major markets as FM stations for many years,” said Harland. “These are established facilities with significant listenership and the FCC rules do not specifically prohibit offering these ancillary services.”

On the other hand, Keith Pelletier, vice president and general manager of Dielectric, Dielectric, did express some surprise at the suddenness of the arrival of “second-gen” Frankens.

“It certainly caught me off guard,” he said, explaining that “the business model seems to be targeted for older vehicle receivers. In the future, as the older receivers get replaced it will be important to have a receiver that will go below 88 MHz, and not just vehicle receivers. Also, it will be an all-digital world at some point I would think, so analog services even in the FM world may go away.”

Nonetheless, Dielectric is ready to supply Ch. 6 TV stations with the technology needed to add analog FM if they desire to do so.

“Our sales team has been approached by multiple license holders,” said Pelletier. “We have manufactured two antennas to date and have discussed multiple more deployments that should happen in 2022."

He added that while the antenna portion of such a 3.0/FM installation wasn’t especially challenging, the combiner was a somewhat different story.

“In contrast to the antenna, the combiner needed more simulation work as well as development in the lab,” he continued. “This work was done using circuit simulation tools, HFSS (3D electromagnetic simulation software), and finally a prototype was manufactured to prove out the system.”

ERI’s Harland noted too that such combining of dissimilar signals was not especially challenging.

“ERI manufactures filters and diplexers that could be adapted for this application and we would design and manufacture the components required for a transmitter supplier to build systems for this application.”

At this point, the technology is in place, as are operators and their audiences, so it appears that only time will tell as to whether or not these Ch. 6 hybrid DTV/FM stations will proliferate, and whether the FCC will sanction their operations beyond STAs by moving the matter to the next rung and taking the necessary steps to codify their existence and operating practices.

WASHINGTON—LPTV Channel 6 stations aren’t the monsters that NPR argued they were and should be allowed to remain operating on analog radio signals, says the Preserve Community Programming Coalition (PCPC) in a filing to the FCC.

The FCC Media Bureau had previously requested comments on whether analog LPTV stations should be able to continue to program an analog radio service on 87.7 FM after the final digital television conversion deadline, currently set for July 2021. NPR filed comments in which it said that these Franken FMs, as it referred to LPTV Channel 6 stations, caused “harmful interference to public radio stations operating in the immediately adjacent FM band.”

Now PCPC, a group of FM Channel 6 broadcasters, has submitted a filing of its own refuting NPR’s arguments, saying that “although many of these stations have been broadcasting analog audio carriers on 87.7 FM for more than a decade, the record does not include a single instance of actual, unresolved interference resulting from such operations. Furthermore, there is no dispute that the FCC can easily modify its rules to ensure that these existing services can continue after the digital transition.”

PCPC notes in its filing that NPR, a programmer, and the low power FM advocacy groups REC Networks and Common Frequency have been LPTV Channel 6 stations’ strongest opposition. It says only one full power FM licensee (California State University Long Beach Research Foundation and Educational Media Foundation) has commented, in which it says any concerns about interference to adjacent FM stations are unfounded or can be mitigated.

NPR also argued that the services provided by these LPTV stations don’t serve the public interest because the programming—sports, contemporary, religious and foreign-language broadcasts—are offered by other FM stations. 

“This is the equivalent of arguing that NPR-member station WNYC does not serve the public interest because it is one of five stations with news/talk format serving the New York area,” PCPC said. “Just as NPR-member stations provide unique programming and services to serve their communities in ways that other stations with similar formats do not, so too do analog channel 6 TV stations providing aural programming on 87.7 FM.”

PCPC believes that the FCC should authorize currently operating analog LPTV Channel 6 stations to continue transmissions at 87.7 MHz without interruption after the digital transition deadline passes.

The full filing can be found online. 

WASHINGTON—Insinuating a connection between Dr. Frankenstein’s monster, National Public Radio wants to see an end to low-power television Channel 6 stations from using analog FM radio services and has asked the FCC to refuse future authorization of such use of what are called “Franken FM” stations.

NPR filed its comments in response to the FCC Media Bureau’s request for feedback on whether analog LPTV stations should be able to continue to program an analog radio service—available on the FM dial (87.7)—after the final digital television conversion deadline.

NPR says that LPTVs’ use of radio airwaves can occupy 30x the spectrum a traditional FM station would use and would cause problems if permitted to continue to operate on analog.

“Franken FMs pose an ongoing threat of harmful interference to public radio stations operating in the immediately adjacent FM band reserved for noncommercial educational broadcast stations,” NPR’s comments to the FCC read. “Moreover, the grossly inefficient use of spectrum adjacent to the NCE reserved FM band ultimate prevents public radio stations from expanding their signal coverage or otherwise offering a multiplicity of additional public service programming for the American public.”

LPTVs believe that these concerns are exaggerated.

“There [are] currently over 20 LPTV stations transmitting analog audio carriers available on 87.7 FM, yet the LPTV-C is not aware of any outstanding (not resolved to satisfaction of the listener) complaints about actual interference between the audio signal transmitted by these analog LPTV stations and nearby FM stations on Channels 201 or 202,” the LPTV Group's Mike Gravino told the FCC. “However, if the commission chooses to be overly cautious, it can adopt both contour overlap restrictions and prohibitions on actual interference that would eliminate any theoretical risk of interference between 87.7 FM audio carrier and nearby NCE FM stations. In everyday, real-world operating conditions, the current or proposed expanded 87.7 FM services will not cause impermissible interference to other broadcast licensees in their markets.”

LPTVs also have argued that their stations benefit unserved or under-served audiences, though NPR counters that these stations typically offer country, contemporary, Spanish language, religious and sports programming, areas that it says are well served by FM radio stations.

This can all be traced back to the digital conversion of 2009. At that time, full power stations were required to go all digital, but the FCC allowed LPTVs to continue to broadcast in analog until 12 months after the completion of the post-incentive auction repack. The auction is currently scheduled to be completed on July 3, 2020, giving LPTVs until July 3, 2021, to switch completely to digital.

NPR, in its argument, says that its position of ending operation of Franken FMs is supported by the Communications Act, FCC regulations and federal communications and spectrum policy. If LPTVs were allowed to continue Franken FM operations, “[the FCC] would have to develop additional rules to govern these Franken FM services to avoid interference to adjacent reserved band NCE FM stations and to assure reception of the LPTV’s primary video service by DTV receivers.”

NPR concludes the commission would better serve the public by reaffirming the DTV conversion deadline.