Report No. MM-855            MASS MEDIA ACTION             October 13, 1994


       FCC AFFIRMS BUREAU ACTION ANNOUNCING INTERFERENCE IMPROVEMENT
     FACTORS FOR STATIONS PROPOSING TO MIGRATE TO THE AM EXPANDED BAND

     The FCC has denied a petition filed by Polnet
Communications, Ltd., licensee of WKTA(AM), Evanston, IL,
requesting reconsideration of the December 3, 1993 action by the
Chief, AM Branch, Mass Media Bureau, announcing interference
improvement factors for stations that have petitioned to migrate
to the AM expanded band.

     Polnet contended that the Bureau erroneously interpreted
Section 73.35 of the Commission's rules, which sets forth the
formula for calculating improvement factors for prospective
migrators to the expanded AM band.  Polnet further contended that
the asserted error resulted in WKTA(AM) being credited with a
lower than warranted improvement factor, adversely affecting
WKTA(AM)'s eligibility to migrate to the expanded band.

     Polnet asked the Commission to recalculate the improvement
factors in view of an asserted error in excluding multiple-
station interference areas from the daytime caused-interference
areas of prospective migrators.  Polnet contended that in
calculating the composite degree of service lost by co-channel
and adjacent-channel stations as a result of interference caused
by a  prospective migrator, and, specifically, the amount of
interference improvement that would be obtained through migration
of that station to the expanded band, FCC staff improperly
excluded from the calculation of interference caused by the
prospective migrator those areas in which the migrator is not the
exclusive contributor of interference.  Polnet maintained that
this methodology contravened Section 73.35 of the rules, and that
the asserted error resulted in unrealistically small improvement
factors for stations such as WKTA(AM).

     Denying reconsideration, the Commission stated that the AM
Improvement Order sought to restore the overall integrity of the
AM service by reducing over time, the interference with which AM
broadcasters must contend in their primary service area.


                                  (over)




                                    -2-

      The Commission stated further that expanded band
improvement factors are based on two distinct considerations: a)
service area lost by other stations due to interference caused by
the present facilities of the prospective migrator, and b)
present service area of the prospective migrator.  The rules
define an AM station's primary service area as that area in which
the groundwave is not subject to objectionable interference or
objectionable fading.  Upon completion of the channel change by
such a migrator, the service areas of existing band co-channel
and adjacent channel stations in which the migrator currently
causes objectionable interference would become truly 
interference-free. 

      Conversely, if the improvement factors were to include
areas in which a migrator's co-channel and first-adjacent channel
stations receive objectionable interference from stations other
than the migrator, the interference reduction benefit of a
migrator's proposed migration in a multiple-station interference
area would be marginal, as the co-channel and first-adjacent
channel stations would continue to receive objectionable
interference in the relevant area from other assignments.  The
Commission stated further that excluding multiple-station
interference areas from a prospective migrator's caused-
interference area is also consistent with the prescribed method
for calculating the migrator's actual daytime service area, which
excludes any area lost to interference from other assignments.

     The Commission noted that the service-provided component of
the daytime improvement ratio only credits the proposed migrator
with that area of interference  improvement actually afforded by
its proposed migration.

     Consequently, the Commission said it saw no reason to
reconsider the Bureau's action determining the interference
improvement factors for stations that have petitioned to migrate
to the AM expanded band.

     Action by the Commission October 7, 1994, by Memorandum
Opinion and Order (FCC 94-257).  Chairman Hundt, Commissioners
Quello, Barrett, Ness, and Chong.

                                  -FCC- 

     News Media contact: Patricia A. Chew at (202) 418-0500.
     Mass Media Bureau contact: Brian Browdie at (202) 254-9572.