For full-service non-directional stations, a modification of license application can be submitted to correct geographic coordinates within a range of up to 3 seconds in latitude and/or up to 3 seconds in longitude (§73.1690(b)(2)). The actual distance allowable for adjustment varies due to the curvature of the Earth but generally falls within about 300 to 350 feet in latitude and 200 to 250 feet in longitude. However, any changes or corrections involving full-service directional antennas necessitate a construction permit.
For full-service non-directional stations, a modification of license application can be submitted to correct geographic coordinates within a range of up to 3 seconds in latitude and/or up to 3 seconds in longitude (§73.1690(b)(2)). The actual distance allowable for adjustment varies due to the curvature of the Earth but generally falls within about 300 to 350 feet in latitude and 200 to 250 feet in longitude. However, any changes or corrections involving full-service directional antennas necessitate a construction permit.
In the FM Translator service, you can make horizontal changes, excluding those that require FAA notification, of up to 500 feet from the authorized coordinates without needing a construction permit (§74.1251(b)(5)).
Conversely, in the LPFM service, according to §73.875(b)(2), a Modification of Licensed Facility application (formerly known as Form 318) must be filed for any alteration in station geographic coordinates. This includes both coordinate corrections and adjustments to another tower at the same coordinates.
It’s essential to keep in mind that operating with unauthorized facilities, whether it pertains to location, height, or channel, can have serious consequences. Such unauthorized operation can be considered equivalent to operating “silent” and may subject the station to Section 312(g) of the Communications Act, which states that stations failing to transmit signals for over 365 consecutive days can face license cancellation. The FCC has interpreted this law in the past to include unauthorized operation.
To emphasize the importance of accurate coordinates, it’s worth noting previous actions taken by the FCC:
- In 2018, a Notice of Violation was issued to American Multi-Media Syndicate, Inc. for operating an LPFM station 3.88 miles from its authorized location.
- In 2019, the FCC canceled the license of Chinese Voice of Golden City after discovering that the station operated from unauthorized locations, including one as close as 256 feet from its authorized location.
- In 2020, the FCC proposed a forfeiture to Jupiter Community Radio for various violations, including operating the station at a location one-third of a mile (1,742 feet) from its authorized location.
Therefore, it is crucial for applications to reflect the correct coordinates. Organizations considering acquiring an LPFM station from another entity through the license assignment process should conduct due diligence to ensure the station is operating at its authorized location, as the receiving organization may become responsible for the previous owner’s errors.
It’s important to note that LPFM is not akin to CB radio, where stations can be moved without authorization. In LPFM, operations must be conducted from the exact authorized coordinates. While there is some allowance for antenna height adjustments (between 2 meters higher and 4 meters lower than the authorized vertical height, per §73.875(b)(3)), there is no leeway for horizontal location changes.