Time to Rethink Pre Sunrise and Post Sunset Authorizations?

New York

Congress’ change to the dates for Daylight Savings Time has madePre-Sunrise authorizations more important than ever. Operation of daytime stations and fulltime stations with weak night power is seriously impacted. Daylight will come even later in the morning this March and next October and November, and for each year thereafter.

As I reported earlier, the FCC’s Pre-Sunrise and Post Sunset Authorization calculator is seriously broken, and won’t be fixed until at least next fall. The Commission has implemented a stopgap measure to patch the system for this spring for many stations, but it is pretty bad news for stations with no pre-sunrise authorizations at all.

I am filing a Petition for Rulemaking that proposes a more rational set of rules that will significantly increase expanded hours authorizations to permit all class B and D stations to operate during the transitional hours on a non-interference basis. Those stations now eligible for 500 Watt (or lower) PSRA operations under the current rules would still be eligible, but those stations that can run more power without interference could do so.

The petition calls for:

  1. Stations could operate during expanded hours with any power, up to their licensed day, night or critical hours power, whichever is highest, that causes no interference to other stations.
  2. Stations now eligible for PSRA and PSSA before 6 PM to take advantage of present limits.
  3. PSRA authorizations with power over 500 Watts would specify power levels in 15 minute increments
  4. Extend PSRA and PSSA eligibility to all class B and D stations. Many class B stations have service limitations ontheir night facility which would be relieved by being able to use the night antenna at greater power, or the day antenna for extended hours.
  5. Define the intermittent service area of domestic Class A stations to be the actual location of the 0.5 mV/m 50% skywave contour as modified by the dinural curves. This means that the western end of a secondary service area does not exist until well after sunset, and the eastern end of the secondary service area disappears before sunrise. This will permit much more extensive PSRA or PSSA authorization for Class D stations on US clear channels
  6. Permit flexibility in what antenna system is used for PSSA and PSRA. The FCC staff decided that class D stations using separate night antennas could use their authorized night antennas instead of the day antenna, which makes a lot of sense. In some cases, one element of a directional day antenna system, or the auxiliary antenna near the center of town makes more sense. Stations should be able to request which antenna they want to use for their PSRA and PSSA operation. The petition also asks the Commission to use a slightly different method for calculating radiation from directional antennas at low power. Scaling the “Q” value will effect the amount of power and sometimes the ability of a station to operate at all using PSSA and PSRA.
  7. PSSA and PSRA which specify more than 500 Watts should also fully protect first adjacent channel domestic stations, which is not presently done.
  8. The petition suggests that the additional complexity of PSSA and PSRA applications might cause an additional workload on the Staff which might be compensated by making the authorization request a minor change application.
  9. The present PSSA and PSRA does not properly protect foreign class A stations. The procedure should include correct treatment of protection of these stations where their secondary service areas extend beyond national boundaries. The present scheme grossly overprotects some foreign stations.

Daytime broadcasters should review this proposal and make appropriate comments once the FCC’s ECFS has provided the proper rulemaking links.

This is the right time for the FCC to act, as the Commission must pay attention to the problems that the system has right now. Pre Sunrise Authorizations were initiated almost 50 years ago, before sophisticated computers and the FCC has patched it several times since. Updating the system to provide a rational expanded hours regime should be done now, instead of just fixing the clunky, antiquated system of regulation now in place.