Monday, February 15, 2016


Philip Shappard, National Operations Manager for Radio at Moody Bible Institute (MBI) kindly provided me with the baseline material detailing MBI’s foundational role establishing national satellite-to-FM translator operations. MBI called the new FM service “satellators” and dreamed of a national satellator network.

Ironically, Moody’s satellator network was never built but the FCC ruling initiated by MBI opened the door to today’s proliferation of religious noncommercial satellite-fed FM translator stations. Today we will look at the provisions of the FCC’s 1988 rulemaking and its relevance now.
In Shappard’s letter (scroll down to read it) he cites a key FCC document summarizing the 1988 ruling.  You can download it at [link]. 

Moody Broadcasting Institute (MBI), based in Chicago, is a long-time noncommercial religious broadcaster and program syndicator. By the early 1980s MBI had seen the success of satellite distribution of radio programming. NPR was an early leader in the use of satellite distribution.  Satellite Music Network (SMN) and Transtar were distributing 24/7 music formats to stations by reliable and rather inexpensive satellite feeds.
MBI filed a rulemaking petition with the FCC in 1985 to allow programming to  be fed to FM translators nationwide. At that time there were many open, unused spaces in the noncom part of the FM dial (88.1- 91.9).
MBI’s 1985 proposal met fierce resistance from the National Association of Broadcasters (NAB), NPR and others. After extensive comment periods, the FCC finally made a ruling in 1988. They added provisions advocated by NAB. NAB's restrictions that caused MBI not to pursue their satellator network. Though MBI did benefit from the FCC's 1988 ruling, they built the foundation for Educational Media Foundation (EMF), American Family Radio, Pensacola Christian College and many others to establish nationwide networks through satellite-fed FM translators.
MBI received little credit or press attention at the time for their pivotal role in the FCC’s action. Most of the coverage was about NAB’s efforts to deny, delay and restrict the change. But, in the end, MBI prevailed.
In 1992 the FCC revised the 1988 ruling.  It clarified delivery methods and opened the door a bit for independent FM translator operators to repeat satellite feeds in some situations. 1992 is when EMF’s 24/7 K-LOVE format began its amazing growth. EMF inspired many other religious noncom operators to create their own satellator networks. Today a substantial portion of nonncom FM translators are  satellators.
Below are specific items in the FCC’s REPORT AND ORDER Adopted March 24, 1988; Released: April 15, 1988 By the Commission [I’ve added BOLD emphasis of key phrases]:
• By this action, the Commission is adopting changes to its rules to allow noncommercial educational FM translator stations assigned to reserved channels and owned and operated by their primary stations' to receive signals for rebroadcast via any technical means the licensee deems suitable.

The Commission authorized FM translators for the specific and limited purposes of providing FM radio service to underserved areas, extending additional FM service to underserved areas, and improving service to areas within the predicted 1 mV/rn contours of primary FM stations.

• The Commission…was concerned about the use of translators as a means to expand competitively the service area of a primary FM station. Consistent with these objectives and concerns, the Commission authorized FM translators for the specific and limited purposes of providing FM radio service to underserved areas…

• Moody stated that signals delivered by satellites could be distributed to remote locations, thus extending service to underserved areas.

• [The Commission] also stated that it appeared that this proposal would not impede the growth of full service radio stations since noncommercial educational translators would continue to be authorized only on a secondary, non-interference basis.

In addition, [The Commission] stated that [they] did not intend to change [the] policy requiring translators to… permit the establishment of a network of only translators.

My how things have changed. Satellite-fed FM translators now operate in most the nation's largest markets, hardly under-served area. The FCC did not want national networks of satellite fed FM translators but that is what we have now. You and I can hear K-LOVE almost anywhere in the country via translators. Translators can now repeat any primary station they choose provided the owner of that station approves. They can even repeat commercial stations, HD channels and AM stations.  Today EMF owns an estimated 500 translators. They buy, sell, trade and lease them like real-estate brokers in a boom town. 

It is clear that this is not what the FCC intended in 1988 or 1992. Perhaps the FCC should reconsider its satellite-to-translator policy.
MBI is a very successful noncom broadcaster.  It has reinvented itself many times.  Now MBI programming is available online and on mobile devices. Here is how Philip Shappard of MBI told the story in his email to me:
Hi Ken,
I just read your blog detailing the history of FM translators. I was hoping to see in your timeline mention of Moody Bible Institute’s foundational role in petitioning the FCC for the change in FM translator rules that allowed for alternative means of program origination. 
Robert Neff
 Original proposals of rulemaking change were first submi6ed by MBI under the leadership of the late Robert Neff, Vice President of Moody Radio at the time with vision and technical assistance from Jim Goodrich, a former radio station owner from Montana who used translators extensively and brought that expertise to Moody upon his arrival in 1979. Our communications attorney, Jeff Southmayd guided the entire legal process for MBI.
I have the original petition in my possession along with knowledge of the circumstances that led to the creation of the Moody Broadcasting Network in 1982. While we expanded into many affiliate relationships with Christian broadcasters across the country in the 80s and 90s, it was first the desire to feed a network of satellite-fed FM translators that led us to use our more than fi[y-plus years of experience and good standing before the FCC and make the first proposal for alternative means other than off-air signals to feed FM translators.
It was a very long road from the original proposal of rulemaking change before the Commission in the early 80s until the rule change was actually effective in April 1988. After eight long years of petitioning, pushing and praying, we at long last were able to submit applications for “satellators” as we first called them. 
Moody Bible Institute's Theater.Chapel

 It was from this foundation that we believe God used the Moody Bible Institute and Moody Radio to open up the doors for relatively new organizations such as Education[al] Media Foundation, American Family Radio, Pensacola Christian College and others to establish and expand their ministries through satellite-fed FM translators.

I believe if you check the public records at the FCC, you will find my recollection is factual. The FCC has provided access to the rulemaking change with an historical accounting of the process at /Daily_Releases/Daily_Business/2015/db0714/FCC-88-125A1.txt 
Moody Radio's Studio A in 1945
 I hope you find this helpful in telling the story of Moody Bible Institute’s role in the expansion of FM translator use. In addition to Harold Enstrom’s contribution, I would hope that you could give mention to Mr. Jim Goodrich who had the vision, knowledge and desire to see Moody Radio expand across the United States serving unserved and under-served locations, especially in the vast Western state region.
All the networks and broadcasters who have benefited from the use of satellite-fed FM translators owe Mr. Jim Goodrich, Attorney Jeff Southmayd and the Moody Bible Institute a debt of gratitude for the many years and thousands of dollars it took to make FM translator broadcasts available to locations beyond the off air signal range of a primary radio station.
Thank you. Phil Shappard

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