Freshly-filed, these comments more deeply document the shenanigans of the Edgewater Broadcasting/Radio Assist Ministry/World Radio Link triad, with deeplink footnotes to illustrate the speculation and trafficking in action. The are four simple conclusions:

1. Incremental changes to the FCC’s translator rules over time created the conditions that brought about the use of translator stations to build broadcast networks, which in turn helped engender a vibrant marketplace for translator stations themselves.

2. The doings of RAM/EB/WRL and all of its principals deserve serious, focused scrutiny, in the form of an active investigation.

3. RAM/EB/WRL’s transactions are just the tip of the iceberg. The FCC should freeze all translator applications from the 2003 filing flood and examine them systemically for similar behavior from other parties.

4. The FCC should revisit the concept of translators as a class of service and, where necessary, better define its secondary status relative to other FM services.

The bottom line is, translator stations were never intended to be used as low-cost network broadcast nodes, for godcasting or otherwise. Using translators in such bulk fundamentally changes their actual use into something that’s hard to classify as a secondary service.

The FCC has yet to demonstrate any initiative to properly deal with the translator situation and deserve the prodding. Comments on the current proposal to modify the LPFM service – including discussion of the translator issue – can be filed electronically, either via the FCC’s own interface or the Prometheus Radio Project’s more user-friendly hack.

The comment period on this proceeding is open for another week (until August 8) with a further two weeks for replies. Make sure to file under the correct proceeding number (99-25).