Before the Federal Communications Commission Washington, DC 20554 In the Matter of ) ) RM-11338 AM Radio Stations’ Use of FM Translators ) ) To: The Commission COMMENTS OF THE CROMWELL GROUP, INC. These comments are submitted by the Cromwell Group, Inc. to support those of the National Association of Broadcasters, and the Tennessee Association of Broadcasters of which I am past Chairman. I and my companies have been the licensee of broadcast stations for 34 years. During that time, our company has built or upgraded in excess of 20 stations, mostly in small towns. We currently operate the following AMs: • WPMB-AM 1500, 250 watts, Vandalia, Illinois. This station has 2 watts of nighttime power. • WCRA-AM 1090, 1000 watts, Effingham, Illinois. This station has no nighttime authority. • WTCJ-AM 1230, 880 watts, Tell City, Indiana. Very limited and interfered with nighttime coverage. • WKCM-AM 1160, 2500watts/1000watts ND, Hawesville, Kentucky. Two tower directional with very tight coverage at night and high interference. • WVJS-AM 1420, 5000watts/1000watts N, Owensboro, Kentucky. Different directional patterns day and night. WCSR 3416921v1 • WQZQ-AM 1550, 2500 watts / 20+watts night, Clarksville, Tennessee. Of these stations, WQZQ-AM is the newest of the AMs, built in the 1980s and purchased by us out of bankruptcy. WTCJ-AM and WVJS are heritage AMs built in the 1940s. WVJS and WTCJ were both purchased in financial distress. WKCM was built from scratch by us in 1972 and kept going, even when it should not have been. WCRA is a heritage small community central Illinois call sign. WPMB is similar. When these stations were built they had clear signals that served their communities well. As the number of AMs expanded and interference grew from other sources, their ability to serve their communities and be a listener choice has diminished. Most could not survive were they not shored up financially by us. Because all either need to go off the air, or significantly reduce coverage at night, the coming of a new daylight savings time arrangement will further damage them and threaten their survival. If the services that these AMs provide during daytime hours are valued, and I believe they are, the ability to operate on a translator will benefit their small communities. In winter, some will be operating less than 9 hours a day. Being carried on a translator will enhance that to 24 hours in the primary area. During daytime, the translator will get into some buildings that AMs can not now do because of the electrical interference that did not exist in times past. Most translator frequencies that can be made available exist in smaller communities where this service is most needed and the AMs are least viable financially. Taking the step to allow FM translators to rebroadcast an AM will provide more continuous service from an important local resource, and also make that resource more able to support itself in a competitive marketplace, which most can not do now. 2 WCSR 3416921v1 We/I ask you to favorably consider the submissions of the NAB and the TAB and to act promptly on this and their request. Respectfully submitted, THE CROMWELL GROUP, INC. By: __/s/ Bayard H. Walters___________ Bayard H. Walters President The Cromwell Group, Inc PO Box 150846 Nashville, Tennessee 37215 615-361-7560 (office) [email protected] August 23, 2006 3 WCSR 3416921v1 .