This Web posting is associated with CGC Communicator newsletter #873 and contains material too lengthy to appear in our regular e-mailed newsletter.

Following are two sets of comments.  The first set regards Randy J. Stine's recent cover story in Radio World entitled, "Concerns Raised About 'Franken FMs'" (http://www.rwonline.com/article/71552).  The second set contains letters addressing the operation of KSFV-LP, an apparent Franken FM in the Los Angeles area.

QUESTIONS (FROM READERS) AND ANSWERS (BY CGC STAFF) RE RANDY J. STINE'S ARTICLE ON FRANKEN FMs


Q.  Where did the term "Franken FM" come from?

A.  The Term "Franken-FM" (with a hyphen) was coined by Ed Tipler, P.E., of southern California who, after hearing a CH-6 LPTV acting like an FM station for first time, said, "It upset me so much that I called it a name, Franken-FM, as in the famous Frankenstein Monster that was made up from miscellaneous body parts, in this case an unholy alliance of FM equipment and a TV license."



Q.  Regarding FCC Rule 73.653 mentioned in Randy's article, what in the [heck] was the FCC thinking in allowing separate audio, unrelated to the visual content?

A.  FCC Rule 73.653 is entitled, "Operation of TV aural and visual transmitters" and reads as follows:

"The aural and visual transmitters may be operated independently of each other or, if operated simultaneously, may be used with different and unrelated program material."

One reader recalls that this rule was created specifically to help over-the-air Pay TV get off the ground at a time when UHF-TV was in financial distress and cable TV was coming on strong with pay channels.  [Another reader believes that Channel 52 on Mt. Wilson may have been pay at one time and says, "Weren't they called, "On-TV" or something like that?"]  The bottom line is that there was never any talk about using this rule to allow TV stations to become FM stations.  Anyone attempting to use this rule for that purpose today should research the history of the rule.  Further, Part 73 rules do not necessarily apply to LPTV stations, so careful research is needed there as well.



Q.  Is there any FCC Rule that lets LPTVs become FM stations, jumping from one service (TV) to another (FM)?

A.  None that we are aware of.  However, Franken FMs maintain that the lack of a specific prohibition is their invitation to use their TV allotment for FM broadcasting purposes.

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LETTERS RECEIVED BY THE CGC COMMUNICATOR RELATED TO KSFV-LP WHICH IS REPORTEDLY OPERATING AS A FRANKEN FM STATION

(CGC Communicator readers are welcome to comment on these letters or any of the points raised above.  Please remember our 100 word limit when submitting comments.)


LETTER #1:

Your commenters about KSFV-LP [in previous newsletters] are badly confused.  LPTVs and Class As operate under Part 74; full service stations operate under Part 73.  The criticisms they offer of this station are based on Part 73.  There are no normative links between Part 74 and Part 73 that apply to RF; acting as if there are is simply missing the point.

I take no position on KSFV's [power increase] petition.

John Willkie,  jwillkie (at) etherguidesystems.com


LETTER #2:

[Following is a draft letter of complaint to the FCC that has been edited by others and may or may not make its way to the FCC.  Nevertheless, the points are well worth considering.  -Ed.]

I live...near Los Angeles and receive over the air what I understand is KSFV-LP on TV channel 6.  The only problem is that it's not really a TV station.  It has made itself into an FM station.  This represents a huge waste of electromagnetic spectrum.

KSFV's video is just a series of still pictures with a "Guadalupe Radio 87.7 FM" logo at the lower left.  This means that while KSFV is allocated a full 6 MHz wide TV channel for the purpose of television broadcasting, the only real use of the channel is 0.2 MHz (or less) to convey the audio programming for Guadalupe Radio.  Guadalupe even has its own web site:

http://www.guadaluperadio.com

Another problem with KSFV-LP is what appears to be grossly excessive aural carrier frequency deviation.  The deviation is so wide that the audio on my TV is distorted and I have trouble understanding it.

I hope you will act quickly to bring this spectrum abuse to a halt.


LETTER #3:

My first point regards the claim by Mr. Henry in CGC #872 that, "LPTVs can legally operate with equal aural and video power as well as 75 kHz deviation and standard FM stereo."

Comment: The part about 75 kHz deviation and FM standard stereo is incorrect.  75 kHz deviation will overload a TV receiver.  75 kHz deviation will also increase the TV channel bandwidth beyond that permitted.  Per 74.750, transmitters have to be certified for TV use.  75 kHz deviation transmitters cannot be certified.

Regarding Mr. Henry's claim pertaining to the FCC's inspection of KSFV-LP that, "The antennas are fed by two different sized feedlines so that accounts for some of the difference.  One can conclude nothing from the transmitter power measurements without knowing the details of the antenna/line system gains and losses."

Comment: The FCC could have used the TPO, line loss and antenna data on the station's license application to determine if the TPO was correct.  The license shows a JAM Model JADP-1/3(3)OMG antenna.  Is that what is being used?

Below is the technical data from their license application:

Item 1, Channel: 6

Item 4, Operating Constants:

Transmitter power output (after vestigal sideband filter,
if used, and after multiplexer, if combined) 1.455 dBk 1.398 kW

Multiplexer loss in dB, if separate 0 dB

Input to transmission line 1.455 dBk

Transmission line power loss 1.2 dB

Antenna Input power 1.257 dBk

Maximum antenna power gain -3.28 dB

Maximum effective radiated power -3 dBk 0.499kW

Item 5, Antenna Data: Manufacturer: JAM Model JADP-1/3(3)OMG

....

Raymond C. Benedict, rcbenedict (at) cbs.com
December 17, 2008

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Editorial Comment:  If you have comments about Franken FMs that deserve national attention, please send them to <radioworld (at) nbmedia.com> with "Letter to the Editor" in the subject line.

Posted by Steve Blodgett, at Earthsignals.com