Two suspicious proposals to expand the FM spectrum have surfaced at the FCC. While on its face the idea seems promising, the devil, as always, is in the details.

The first proposal was filed in late July by the Educational Media Foundation – parent company of the K-LOVE and AIR-1 Christian music radio networks, which can already be heard on more than 150 full-power, low-power, and FM translator stations.

A second, new group, called the “Broadcast Maximization Committee,” which represents the interests of AM broadcasters, followed up with its own proposal within days of EMF’s filing. It is difficult to believe the timing of the filings were coincidental.

EMF and the BMC both assert that when the digital television transition is complete next February, the spectrum currently reserved for analog TV channels 5 and 6 – which is immediately adjacent to the existing FM broadcast dial – should be re-appropriated to expand the FM dial to accommodate new users.

The kicker is who those new users would be. In its proposal, EMF tacitly supports the reservation of some of this new spectrum for LPFM stations, but only as a ruse to advance its main agenda, which is to make sure most of it goes to FM translators. Citing the “embarrassment of riches” seen in 2003, when tens of thousands of applications for FM translators were filed (many of them arguably fraudulently), EMF implicitly suggests there is more demand for translators than for true, live-and-local LPFM stations. The truth is that the proliferation of FM translators has already detrimentally affected any future expansion of the LPFM service.

The Broadcast Maximization Committee, on the other hand, represents incumbent broadcasters who have long had their eye on the FM dial. Two years ago, the National Association of Broadcasters initiated a proceeding with the FCC, requesting that the agency assess the state of AM broadcasting. The endgame proposed a bounty of up to as many as five FM translators per AM station. AM broadcasters cite the degrading quality of the AM dial, due to interference issues (some of which they themselves have caused), as the rationale for giving these beleaguered incumbents new spectrum on an already-overcrowded FM dial.

The BMC’s plan is essentially an expansion of the NAB’s original scheme. Only eight of the 100 proposed FM channels would be reserved for LPFM expansion; another eight would be reserved for full-power, noncommercial educational stations. The rest would be employed to potentially liquidate the AM dial: existing AM broadcasters would move to full-power FM stations in the expanded band; the AM dial itself could then be possibly repurposed.

The irony in all of this is that both proposals use the guise of LPFM – something neither constituency has looked favorably upon in the past – as cover for their own greed. It’s doubly-ironic for the fact that during the initial LPFM rulemaking in 1999 the FCC considered and rejected the notion of appropriating analog TV channels 5 and 6 to expand the FM band.

It’s anyone’s guess as to whether or not the FCC will seriously entertain these proposals. It would be a shame if it did, at least in their current forms.