If you are filing Form 318 for any kind of change and you are second-adjacent channel short-spaced, you must acknolwedge and address the short spacing. Whether you need to submit a new study depends on the change you wish to do.
If you are making a change to the technical parameters of the station including:
- change in the radiation center height (either higher or lower)
- change in the tower location (even if it is an adjacent tower on the same property) that is the same distance (rounded to the nearest km) or further away but still short-spaced
- request for an increase in power based on GLOBE terrain data
then you should enclose a new showing and waiver request.
The study must conclude that the new parameters will continue to assure that the interfering contour from the LPFM station based on the undesired/desired (U/D) method (also known as the Living Way method) or antenna manufacturer's specifications, does not reach any occupied areas that would create interference for listeners and potential listeners of the short-spaced second-adjacent channel station(s).
If you are proposing to move to a location that is closer to the short-spaced second-adjacent channel station, then you must include a new waiver request.
For new stations, if your original license to cover has not yet been granted and the Form 318 is being filed in order to update the board members or a change to the time-share agreement and none of the technical parameters of the station has not changed, you must still address the short spacing and either attach the original study performed on the application that granted those physical facilities or make a reference to that application.
