Translators: The Back Up Plan to HD?

Pity the poor FM translator: a book could be written about the way it has been used – and abused – over the years. Primarily just in this last decade. First, there was the religious broadcaster-led Great Translator Invasion; then, AM broadcasters asked for (and received) permission from the FCC to operate their own FM translator stations. Finally, some full-power FM stations that also happen to be running HD multicast streams are finding the analog translator a lucrative outlet for its previously digital-only content.
It is the latter two developments which concern us here, because both are direct offshoots of HD Radio. AM stations petitioned the FCC (via the NAB) to allow them to assemble clusters, if necessary, of FM translators to at least replicate their primary (protected) service coverage areas. Among the reasons given for this was the increasing level of interference on the AM band, part of which has been caused by the implementation of HD Radio.
In fact, in a hypothetical future where AM-HD adoption was widespread, the plethora of noise would essentially confine all AM stations to their primary service areas anyway. FM translators not only serve as redundancy, but allow them to continue service at night, when AM-HD interference can be especially fierce.
On to the FM convolution. As early as 2008, FM radio station owners have been applying for (or buying existing) translators and feeding them with their “HD2/3” multicast streams, which – until the intervention of the translator – were only available to those that have HD-capable receivers. The practice has been applied in markets in Pennsylvania, Michigan (student-run station), New York, Georgia, Missouri, and Illinois (public radio). There are undoubtedly more – these are the ones uncovered with a cursory Google search. Most are marketed to the listening public as stand-alone stations.
In the case of FM translators being used to replicate AM broadcasters, HD is at fault partly because of the interference it generates on the AM band. But simulcasting FM-HD content on an analog FM transmitter is a case of circuitous idiocy.
Here goes the apparent business model: first, launch a technology capable of multicasting, but prone to listening problems. When listeners don’t adopt said technology in droves, take the content you made for that platform and put it on the old analog medium to maximize your investment in the technology.
Note the end result is not a net benefit for the proliferation of HD Radio. Instead, it’s more stress put on the FM spectrum through everybody’s favorite pet loophole, the translator. Translators, as a class of radio station, were never designed to be a primary broadcast provider, but more and more the industry seems to be treating them like they are.
In a technical working paper on a completely different policy issue (the recycling of spectrum for wireless broadband), the FCC somberly described the the task it faced with these words: “Spectrum policy is not easy. Technology changes. Consumer preferences and habits change. Business models change. Allocation priorities change. And this change can be daunting.”
It is amazing that, in the case of spectrum-regulation work being done in a different division or bureau within the same agency, that the FCC can talk with such apparent seriousness and then, in the case of broadcast radio, act with such carelessness. And the fact that a growing number of radio stations (both AM and FM) appear to be flocking to the use of FM translators as a form of refuge (although their practices are legal) should be ringing some bells in the heads of FCC staff tasked to monitor HD Radio’s vitality.