Last night in the wee hours, unable to sleep (being still a bit jet-lagged and half-napping through the Veep Debate), I visited David Oxenford's invaluable Broadcast Law Blog, which is relentlessly sober and informative about the full range of broadcast law concerns.
At issue in his latest is Commissioner Pai Proposes Looking at Class C4 FM Stations – Good for Broadcasters? Bored yet? You should be, but believe me: this matters to a lot of broadcasters, especially ones operating stations grandfathered with coverage that might improve if they can get reclassified in a way that allows higher powers and antenna heights. That's what Class C4 would allow. For some, anyway.
My answer to the headline question, in the comments below the post, is a resounding maybe, but beside a larger point, which I also make: that FM radio is following AM on a death march to the grave for both of them. Specifically...
To illustrate what over-the-air broadcasting is up against, consider what my teenage son asked me several years ago: "What is the point of 'range' and 'coverage'?" In other words, why are either of those things features and not bugs? He asked that after we drove away from a station that faded on the radio but persisted for hours over a stream online, played by a cell phone through the AUX input into the same dashboard.
We live today in a fully networked world that puts everything on it a functional distance of zero from everything else. It is a world that is subsuming all legacy media, including radio and TV. In the long run legacy radio will supplement streaming, rather than the vice versa we still have today. And then legacy radio will go away, probably after the income from over-the-air transmission is exceeded by the cost of operating transmitters, or the sale value of real estate (which is already driving AM stations off the air or onto shared towers and acreage).
If you think of legacy radio as a Titanic very slowly taking water — which it is — proposals such as Class C4 are deck chair rearrangements: perhaps worth doing while the whole thing is still floating, but still in some degree of denial toward the inevitable.
The actual cause of death will be a form of asphyxiation: drowning in the Net after radio's air supply is cut off by car makers that finally choose to save money by not paying for the chip in the dashboard that picks up FM radio waves. (As some makers are already doing with AM chips.) The NAB will fight against that, but not so hard when actual listening verges on zero, simply because most people would rather listen to commercial-free (or -few) streams and podcasts.