AM revitalization comments

I have been reading the comments regarding the FCC’s NPRM (13-249).  Clearly, many people are interested in keeping the AM broadcasting band both active and relevant.  Some of these suggestions have merit but are unlikely to be adopted by the FCC.  Others are viable and could alleviate at least a few of the technical shortcomings of the AM band.  The rest fall along expected positions.  Here is a brief rundown:

  • Clear Channel, iBiquity: Allow stations to transmit in all digital mode.  Likelihood: Possible.  The hybrid version of AM HD Radio has been a failure on several fronts; added interference to adjacent channels, self-interference, poor adoption, wonky CODECs, etc.  However, letting stations choose to broadcast in all digital AM HD Radio may decide the issue once and for all.  As long as the all-digital carriers fall within the current analog channels, this would be fine.  Actually, I would add that stations transmitting in all digital be allowed to choose DRM as well as HD Radio
  • REC Networks, MMTC: Move AM stations to former TV channels 5 and 6.  Likelihood: Unlikely.  It would be a neat solution, however, there are currently many full and low-power TV stations still using those frequencies.
  • Clear Channel, SBE, MMTC, Crawford, et al: Allow AM stations a special translator filing window.  Likelihood: Almost assured.  This has been broached by the FCC itself.  I would add that Class D and Class C stations be given priority.
  • SBE, du trial, Lundin and Rackely, MMTC et. al: Remove the “ratchet rule,” reduce antenna efficiency requirements and city of license contour requirements.  Likelihood: probable.  Over the years, the FCC’s rules and regulations designed to help AM broadcasting’s technical product have done the opposite in many cases.  This is especially true of the “ratchet rule.”
  • SBE, du Trial, Lundin and Rackely, MMTC: MDCL (Modulation Depended Carrier Level) Likelihood: Possible.  MDCL does not do much to improve AM signal quality, but it can save the station owner some money on the electricity bill.
  • Alabama Broadcaster’s Association, et al: Better FCC enforcement.  Likelihood: Not very.  This is another area where interference and AM noise problems can be fixed.  Given Ajit Pai’s desire for “non-regulatory” relief, stepped-up enforcement seems to be a non-starter.
  • Hatfield and Dawson: Eliminate substandard AM stations.  Likelihood: Not very.  Getting rid of substandard stations and letting the remaining AM stations enjoy a little breathing room is actually a big step in the right direction.  H&D notes that the FCC should petition congress for tax relief for those stations that choose to surrender their licenses.  Unfortunately, it does not appear likely that the FCC, congress, and the current station owners would go for it.
  • du Treil, Lundin, and Rackely: Do away with skywave protection for class A stations  Likelihood: Possible.  The argument goes; skywave listening represents a very small number of mostly hobbyists (AM DXers) as other, better methods for program distribution exist for serious listeners.  Sad but true.
  • du Treil, Lundin, and Rackely: No more new AM stations.  Likelihood: Possible.  There is a cogent argument to be made regarding the overcrowding of the AM band.  Stopping any further crowding is a good idea.
  • SBE, Cohen, Dippell, and Everist, et al: Tighten regulations on electrical noise emitters.  Likelihood: Unlikely.  The FCC does not have the mettle to tighten regulations against powerful manufacturing and technology lobbies.
  • iBiquity: Do not let anything get in the way of the HD Radio rollout.  Likelihood: Is it possible to get in the way of something that is standing still?

Talking amongst engineers and AM broadcasters, many of these ideas have merit.  The real question is, will any of this bring more listeners?