Engineering Radio

The house passed the “LOCAL COMMUNITY RADIO ACT OF 2009 ” (aka HR 1147) last night in one of the last legislative acts of 2009.  This is the companion bill to S. 592, which is still in committee.

The need for LPFM stations is justified thusly:

• In part due to consolidation of media ownership, there have been strong financial incentives for some companies to reduce local programming and rely instead on syndicated programming produced for hundreds of stations, though noncommercial educational radio stations, including FM translator stations, currently provide important local service, as do many commercial radio stations. A renewal of commitment to localism–local operations, local research, local management, locally originated programming, local artists, and local news and events–would bolster radio’s service to the public.
• Local communities have sought to launch radio stations to meet their local needs. However, due in part to the scarce amount of spectrum available and the high cost of buying and running a large station, many local communities are unable to establish a radio station.
• In 2003, the average cost to acquire a commercial radio station was more than $2,500,000.
• In January 2000, the Federal Communications Commission authorized a new, affordable community radio service called `low-power FM’, or `LPFM’, to `enhance locally focused community-oriented radio broadcasting’.
• Through the creation of LPFM, the Federal Communications Commission sought to `create opportunities for new voices on the airwaves and to allow local groups, including schools, churches, and other community-based organizations, to provide programming responsive to local community needs and interests’.
• The Federal Communications Commission made clear that the creation of LPFM would not compromise the integrity of the FM radio band by stating, `We are committed to creating a low-power FM radio service only if it does not cause unacceptable interference to existing radio service.’.
• Currently, FM translator stations can operate on the second- and third-adjacent channels to full-power radio stations, up to an effective radiated power of 250 watts, pursuant to part 74 of title 47, Code of Federal Regulations, using the very same transmitters that LPFM stations will use. The Federal Communications Commission based its LPFM rules on the actual performance of these translators, which already operate without undue interference to FM stations.
• Small rural broadcasters were particularly concerned about a lengthy and costly LPFM interference complaint process. Therefore, in September 2000, the Federal Communications Commission created a process to address interference complaints regarding LPFM stations on an expedited basis.
• In December 2000, Congress delayed the full implementation of LPFM until the Federal Communications Commission commissioned and reviewed an independent engineering study. This action was due to some broadcasters’ concerns that LPFM service would cause interference in the FM radio band.
• The Federal Communications Commission granted licenses to over 800 LPFM stations despite the congressional action. These stations are currently on the air and are run by local government agencies, groups promoting arts and education to immigrant and indigenous populations, artists, schools, religious organizations, environmental groups, organizations promoting literacy, and many other civically oriented organizations.
• After 2 years and the expenditure of $2,193,343 in taxpayer dollars, the independent engineering study commissioned by the Federal Communications Commission concluded that concerns about interference on third-adjacent channels were unwarranted.
• The Federal Communications Commission issued a report to Congress on February 19, 2004, which stated that `Congress should readdress this issue and modify the statute to eliminate the third-adjacent channel distance separation requirement for LPFM stations.’
• On November 27, 2007, the Federal Communications Commission again unanimously affirmed LPFM, stating in a news release about the adoption of the Low-Power FM Third Report and Order and Second Notice of Proposed Rulemaking that the Federal Communications Commission recommends `to Congress that it remove the requirement that LPFM stations protect full-power stations operating on third-adjacent channels’. Until the date of enactment of this Act, Congress had not acted upon that recommendation.
• Minorities represent almost a third of the population of the United States. However, according to the Federal Communications Commission’s most recent Form 323 data on the race and gender of full-power, commercial broadcast licensees, minorities own only 7 percent of all local television and radio stations. Women represent more than half of the population but own only 6 percent of all local television and radio stations. LPFM stations, while not a solution to the overall inequalities in minority and female broadcast ownership, provide an additional opportunity for underrepresented communities to operate a station and offer local communities a greater diversity of viewpoints and culture.
• LPFM stations have proven to be a vital source of information during local or national emergencies. Out of the few stations that were able to stay on the air during Hurricane Katrina, several were LPFM stations. In Bay St. Louis, Mississippi, low-power FM station WQRZ remained on the air during Hurricane Katrina and served as the Emergency Operations Center for Hancock County. After Hurricane Katrina, when thousands of evacuees temporarily housed at the Houston Astrodome were unable to hear over the loudspeakers information about the availability of food and ice, the location of Federal Emergency Management Agency representatives, and the whereabouts of missing loved ones, volunteers handed out thousands of transistor radios and established an LPFM station outside of the Astrodome to broadcast such information.

Similar to S. 592, the bill aims to:

1. Increase the number of LPFM station by doing away with the 3rd adjacent protections.
2. Mitigate interference by creating a 1 year period during which a new LPFM station must broadcast “periodic announcements that alert listeners that interference that they may be experiencing could be the result of the operation of the new low-power FM station on a third-adjacent channel and shall instruct affected listeners to contact the low-power FM station to report any interference.”  LPFM licensees are then tasked with solving interference complaints with in a licensed full power FM station’s protected contour.
3. Protect translator input signals.
4. Protect reading for the blind services.

I am not finding fault with any of the justifications, they are all true and make a good point about the decline of Radio in general as I have discussed in previous posts.

The potential increase of LPFM stations is in the thousands.

The proposed interference mitigation is a pipe dream.  The FCC enforcement bureau is overworked as it is.  We have had a pirate on one of our frequencies for years, every once in a while they drive out and bust the guy, only to have him return a week or two later.   Somehow this group of overworked people will be able to process hundreds or thousands of interference complaints?

Unless there is increased funding for the FCC enforcement bureau, I am skeptical.  There is no specific discussion on funding, only specifying that the cost should be below $139 million.

We live in interesting times.

I recently got into an argument about the requirements for transmitter readings with a fellow engineer.  Said fellow stated that transmitter readings need to be taken every three hours and that all operators needed to sign on and off the station log.  Time was when those things were supposed to be done, that is true.  I believe the rules have changed a little bit since he last read them.  The current FCC rules (part 73.1820) state that the following items need to be in the station log:

1. Tower light malfunctions and repairs
2. Emergency Alert System (EAS) tests and activations
3. AM antenna field strength measurements (73.61) (monitor points)
4. Calibration of remote control equipment
5. Equipment performance measurements (frequency, harmonics, spurious emissions, etc) (73.1590)
6. Each entry must be signed
7. The logs are to be reviewed and signed by the chief operator

The exception to this is AM stations without an FCC approved antenna sampling system, which indeed require readings on the antenna system every three hours. Most AM stations have an approved antenna sampling system.

If an AM station has an approved sampling system, it will be noted on the instrument of authorization (license).

For transmitter operations, a review of part 73.1350 shows that the licensees are responsible for insuring transmitting apparatus complies with all FCC regulations.  Specifically:

73.1350 (b)(2)(c)The licensee must establish monitoring procedures and schedules for the station and the indicating instruments employed must comply with Sec. 73.1215.

And

73.1350 (b)(2)(c)(1) Monitoring procedures and schedules must enable the licensee to determine compliance with Sec. 73.1560 regarding operating power and AM station mode of operation, Sec. 73.1570 regarding modulation levels, and, where applicable, Sec. 73.1213 regarding antenna tower lighting, and Sec. 73.69 regarding the parameters of an AM directional antenna system.

One would assume that would mean some sort of logging. Further, a review of all recent NAL, NOV and citations from the FCC’s enforcement bureau shows that field agents investigating a radio station will make their own power measurements if they suspect a broadcast station is operating out of power tolerance. Most particularly with AM directional stations that are supposed to reduce power at night. I doubt very much that producing an operating log with in tolerance power readings would do any good in those circumstances.

For directional AM stations that change power/mode at night, some routine of checking the transmitter for proper power levels after power/pattern change needs to be established. If there is an auto logging system, such as a Burk Autopilot, then checking that system for proper time of day and/or proper pattern/power change functioning could take the place of checking the actual transmitter readings as long as there were an alarm (and notification) generated during an out of tolerance condition.

For most FM stations and AM non-directional stations, most modern transmitters have Automatic Power Control (APC) built in. As long as the APC is functioning properly and there is an alarm (with notification) generated when an out of tolerance condition occurs (under/over power), logging power output readings can be done on a weekly maintenance log.

Station logs are to be retained for two years (73.1840) and should be available to the FCC for inspection.  After two years, throw the logs out because anything that you have on file is liable to be inspected.   Any rules infractions found in the station logs can lead to a NOV or NAL, even if it happened more than two years ago.

For your reading pleasure:
73.1820

Sec. 73.1820 Station log.

(a) Entries must be made in the station log either manually by a
person designated by the licensee who is in actual charge of the
transmitting apparatus, or by automatic devices meeting the requirements of paragraph (b) of this section. Indications of operating parameters that are required to be logged must be logged prior to any adjustment of the equipment. Where adjustments are made to restore parameters to their proper operating values, the corrected indications must be logged and accompanied, if any parameter deviation was beyond a prescribed tolerance, by a notation describing the nature of the corrective action. Indications of all parameters whose values are affected by the modulation of the carrier must be read without modulation. The actual time of observation must be included in each log entry. The following information must be entered:
(1) All stations. (i) Entries required by Sec. 17.49 of this
chapter concerning any observed or otherwise known extinguishment or improper functioning of a tower light:
(A) The nature of such extinguishment or improper functioning.
(B) The date and time the extinguishment or improper operation was observed or otherwise noted.
(C) The date, time and nature of adjustments, repairs or
replacements made.
(ii) Any entries not specifically required in this section, but
required by the instrument of authorization or elsewhere in this part.
(iii) An entry of each test and activation of the Emergency Alert
System (EAS) pursuant to the requirement of part 11 of this chapter and the EAS Operating Handbook. Stations may keep EAS data in a special EAS log which shall be maintained at a convenient
location; however, this log is considered a part of the station log.
(2) Directional AM stations without an FCC-approved antenna sampling system (See Sec. 73.68). (i) An entry at the beginning of operations in each mode of operation, and thereafter at intervals not exceeding 3 hours, of the following (actual readings observed prior to making any adjustments to the equipment and an indication of any corrections to restore parameters to normal operating values):
(A) Common point current.
(B) When the operating power is determined by the indirect method, the efficiency factor F and either the product of the final amplifier input voltage and current or the calculated antenna input power. See Sec. 73.51(e).
(C) Antenna monitor phase or phase deviation indications.
(D) Antenna monitor sample currents, current ratios, or ratio
deviation indications.
(ii) Entries required by Sec. 73.61 performed in accordance with the schedule specified therein.
(iii) Entries of the results of calibration of automatic logging
devices (see paragraph (b) of this section) or indicating instruments
(see Sec. 73.67), whenever performed.
(b) Automatic devices accurately calibrated and with appropriate
time, date and circuit functions may be utilized to record entries in
the station log Provided:
(1) The recording devices do not affect the operation of circuits or
accuracy of indicating instruments of the equipment being recorded;
(2) The recording devices have an accuracy equivalent to the
accuracy of the indicating instruments;
(3) The calibration is checked against the original indicators as
often as necessary to ensure recording accuracy;
(4) In the event of failure or malfunctioning of the automatic
equipment, the person designated by the licensee as being responsible for the log small make the required entries in the log manually at that time;
(5) The indicating equipment conforms to the requirements of Sec. 73.1215 (Indicating instruments–specifications) except that the scales need not exceed 5 cm (2 inches) in length. Arbitrary scales may not be used.
(c) In preparing the station log, original data may be recorded in
rough form and later transcribed into the log.

73.1350:

Sec. 73.1350 Transmission system operation.

(a) Each licensee is responsible for maintaining and operating its
broadcast station in a manner which complies with the technical rules
set forth elsewhere in this part and in accordance with the terms of the station authorization.
(b) The licensee must designate a chief operator in accordance with Sec. 73.1870. The licensee may designate one or more technically competent persons to adjust the transmitter operating parameters for compliance with the technical rules and the station authorization.
(1) Persons so authorized by the licensee may make such adjustments directly at the transmitter site or by using control equipment at an off-site location.
(2) The transmitter control personnel must have the capability to
turn the transmitter off at all times. If the personnel are at a remote
location, the control system must provide this capability continuously
or must include an alternate method of acquiring control that can
satisfy the requirement of paragraph (e) of this section that operation
be terminated within three minutes.
(c)The licensee must establish monitoring procedures and schedules for the station and the indicating instruments employed must comply with Sec. 73.1215.
(1) Monitoring procedures and schedules must enable the licensee to determine compliance with Sec. 73.1560 regarding operating power and AM station mode of operation, Sec. 73.1570 regarding modulation levels, and, where applicable, Sec. 73.1213 regarding antenna tower lighting, and Sec. 73.69 regarding the parameters of an AM directional antenna system.
(2) Monitoring equipment must be periodically calibrated so as to
provide reliable indications of transmitter operating parameters with a
known degree of accuracy. Errors inherent in monitoring equipment and the calibration procedure must be taken into account when adjusting operating parameters to ensure that the limits imposed by the technical rules and the station authorization are not exceeded.
(d) In the event that a broadcast station is operating in a manner
that is not in compliance with the applicable technical rules set forth
elsewhere in this part or the terms of the station authorization, and
the condition is not listed in paragraph (e) or (f) of this section,
broadcast operation must be terminated within three hours unless antenna input power is reduced sufficiently to eliminate any excess radiation. Examples of conditions that require termination of operation within three hours include excessive power, excessive modulation or the emission of spurious signals that do not result in harmful interference.
(e) If a broadcast station is operating in a manner that poses a
threat to life or property or that is likely to significantly disrupt
the operation of other stations, immediate corrective action is
required. In such cases, operation must be terminated within three
minutes unless antenna input power is reduced sufficiently to eliminate any excess radiation. Examples of conditions that require immediate corrective action include the emission of spurious signals that cause harmful interference, any mode of operation not specified by the station license for the pertinent time of day, or operation substantially at variance from the authorized radiation pattern.
(f) If a broadcast station is operating in a manner that is not in
compliance with one of the following technical rules, operation may
continue if the station complies with relevant alternative provisions in
the specified rule section.
(1) AM directional antenna system tolerances, see Sec. 73.62;
(2) AM directional antenna monitoring points, see Sec. 73.158;
(3) TV visual waveform, see Sec. 73.691(b);
(4) Reduced power operation, see Sec. 73.1560(d);
(5) Reduced modulation level, see Sec. 73.1570(a);
(6) Emergency antennas, see Sec. 73.1680.
(g) The transmission system must be maintained and inspected in
accordance with Sec. 73.1580.
(h) Whenever a transmission system control point is established at a location other than the main studio or transmitter, a letter of
notification of that location must be sent to the FCC in Washington, DC, Attention: Audio Division (radio) or Video Division (television), Media Bureau, within 3 days of the initial use of that point. The letter
should include a list of all control points in use, for clarity. This
notification is not required if responsible station personnel can be
contacted at the transmitter or studio site during hours of operation.
(i) The licensee must ensure that the station is operated in
compliance with Part 11 of this chapter, the rules governing the
Emergency Alert System (EAS).

I read with interest the MMTC’s (Minority Media Telecommunication Council) ideas for rescuing radio.  In the summary, they make the statement:

By granting this Radio Rescue Plan quickly, the FCC can provide lenders and investors with assurance that the federal government stands behind the survival and sustainability of this industry that is so vital to public service, public safety, minority entrepreneurship and democracy

Red flag.  Anytime some groups want to rush something through because of some perceived crisis, it should be closely examined for potential conflicts of interest.

It is fine to look into the rules and make changes as technology evolves, rushing some change through because the economy has gone south is not the best plan.  If radio is in such bad shape that it needs a rules relaxation to survive, that indicates there is something seriously wrong with the underlying structure.  No amount of rules changing is going to help that.

Anyway, they lay out some ideas, most of which have been batted about before and have had little of the intended affects.

1. Re-purpose TV channel 5 and 6 to the FM broadcast band.  Allow AM station to migrate there with a priority given to relieve interference issues on the AM band.
2. Night time AM signal contour rules, relax requirement to cover 80 percent of city of license at night.
3. Modify or eliminate principle community coverage rules
4. Replace minimum efficiency standards for AM antenna systems with “minimum radiation standards”
5. Allow FM applicants to specify Class C, C0, C1, (etc) in zone I and IA.
6. Delete non-viable FM allotments from the table of allotments.

1.  The first idea is to re-purpose TV channel 5 and 6 to the FM band.  This would allow more FM stations to exist and presumably many AM station to migrate to the FM band.  Sort of like the expanded AM band project in the 1990s where AM stations moved to the 1600-1700 khz range and then turned in their old licenses in the 540-1600 khz range to reduce interference.  Worked out well except for the last part, almost no AM station that moved into the expanded band has ever turned in it’s original license.  I doubt that they would in an AM to FM band migration.

Perhaps using this expanded FM band to move all of the NCE stations from the commercial channels and allow for LPFM’s to proliferate would be a good idea.

Then there is the problem of what to do with the various LPTV-6 stations that are still around.

I doubt the FCC will go for this because they can make too much money auctioning off the spectrum in one whole chunk to the highest bidder.

2.  Night time AM coverage rules.  The proposal is to allow a relaxing of the night time AM coverage rules over the city of license.   Currently required to cover 80 percent of the area or population except in the expanded band, where the requirement is 50 percent.  Making it all one uniform standard (50%) would make the most sense.  Not that it would make a lot of difference listener wise, still, it might ease the burden on some AM station that would otherwise be solvent.

3.  Modify or eliminate principle community coverage contours.  This idea  just seems like a way to satisfy more big radio consolidators and have more stations move out of their communities of license, which they are supposed to be serving.  This is the money statement:

MTCC believes that modification fo these rules benefit small, women, minority, and all broadcasting licesnses by providing them with additional flexibility for site location

How?  I still cannot fathom how this will benefit those groups mentioned above, seems like a generic statement with no merit.

The rim shot signals which are at least providing some type of radio programming to rural areas would cease to exist as they would all pick up and move toward population centers.  This is a bad idea.  The owners who bought rim shots should have known they were buying rim shots in the first place and not be expecting too much in the way of moving things around to accommodate their idea of what the FM broadcast band should be.

4.  Replace minimum efficiency standards with a minimum radiation standard for AM antenna systems.   The proposal states that when those standards were adopted, land was plentiful and electricity was not.  I would comment that neither land nor electricity is plentiful today.  Reducing this standard would open up potential AM station buyers to risk of investing in a bigger money pit than what AM radio currently is today.

In other words, it is a bad idea which would only cause potential owners to be saddled with huge electric bills and hasten the end of AM radio.  As an engineer, I know that with the right amount of capacitance and inductance, I can load up an AM transmitter to a chain link fence.  That doesn’t mean it is a good idea.

5.  Allow FM applicants to specify class C, C0, C1, C2, C3, (etc) in zone I and IA.  I presume they mean to allow a class B to specify class C2 and a class B1 to specify a class C3.  This might make the application process a little more uniform, but I doubt it would make much difference in the FM band.

Also, they seem to use the term “spectrum warehousing” often.  What does that mean?  They make an elusion to the difference between a 54 dBu and a 60 dBu contour.  Is that 6 dBu a “spectrum warehouse?” It is really nonsensical, sort of like “precious bodily fluids” in Dr. Strangelove.

6.  Non-viable FM allotments.  Sure, delete them or re-align them so that they might be usable to someone.  Makes sense.

So here you are, minding your own business on a not so frantic Wednesday afternoon, when a guy shows up in the lobby and wants to see you.  The receptionist says he has a badge and he is from the FCC.

Oh no! Panic! Mayhem! Chaos! Etc!

Actually, things are not so bad as they might seem, after all, this is not your father’s FCC.

Many stations use the state broadcaster associations Alternative Inspection Programs (AIP).  This is where you pay a contractor from the broadcaster’s association to come out and do a mock inspection of your radio stations.  After the station “passes” the “inspection” it is issued a “certificate” that “insures” it won’t be inspected by the FCC for three years.

Totally bogus, or as the French might say, complete bull shit.

The stations I currently work for had those “certificates.”  When the FCC inspector showed up, he laughed at them and inspected us anyway.  We complained to the state broadcasters association and the head of the FCC enforcement bureau at the local field office, all to no avail.   This happened four times.  Each time the FCC inspectors found nothing and went on their way.

What did I learn from this?  Why bother with the stupid AIP’s when all that needs to be done is comply with the FCC’s rules.  After all, the so called “inspector” from the broadcaster’s association is merely going to use the same FCC check list that is down loadable from the FCC web site.  Anyone can do that themselves.

I also learned that the FCC inspectors check a few things more closely than others.  For example:

1. The public inspection file should be perfect.  Since they inspect these stations all the time, they know what is usually missing; Issues and quarterly reports, Contour maps and license renewal cards.
2. EAS logs and procedures.  Make sure that every operator knows how to send and EAS test.  Make sure that all the EAS logs have been check and signed by the chief operator.  Make sure that any discrepancies are noted.
3. Directional AM station operating parameters.  Still a hot button issue and one area that trips up a lot of people.  All antenna parameters within 3 percent of licensed values.  All monitor points below maximum allowed.
4. Equipment performance measurements.  These are needed on all AM stations every year.  They are carrier frequency harmonic measurements and NRSC-2 mask compliance measurements.
5. Tower fences and tower registration numbers.  Big one and easy to spot and fix.  All AM towers need to have a locked fence around the base insulator.  Any tower over 200 feet tall needs to be registered and have a sign with the registration number posted.  The sign needs to be accessible and legible.

So prepare ahead of time for the inevitable visit.  It is very easy to comply with the FCC rules using the FCC checklists.  Both the AM station checklist and the FM station checklist can be down loaded and used to self inspect any radio station.

Here is something else that I have found.  Clean up the transmitter site.  Sweep the floor, replace the burned out lights, empty the garbage, keep a neat maintenance log, etc.  These things go a long way to making a good first impression, which can make the inspection go a lot better.

Once, myself and the FCC inspector pulled up in front of the transmitter building of an AM station.  The grass in front was mowed, the bushes were all trimmed back, the field was mowed, the towers had new paint on them, The fences were in good shape, the place just looked good.  We were about to go inside when he asked “Does the inside of that place look as good as the outside?”  Which it did and I said yes.  Then he said he had seen enough, have a nice day.

So, when the FCC guy shows up, offer him a cup of coffee and relax, things are going to be alright.

Update: This is the actual check list that an FCC inspector will use if he is inspecting a broadcast station.

You can download the .pdf version here.

Because of this post, I have received some e-mail asking why I am against community radio.  I am not.  In fact, I support community radio.  I think that community radio done well is a wonderful tool in our democracy, giving a voice to those that are watching government.  It also promotes other locals interests, events, music, etc.    I would like to see more failing stations bought by community broadcasters and turned into something that is a public trust and responsive to the local population.

What I was trying to get at in the previous post was that over crowding the FM band with more and more small signals will degrade it.  There is no ifs, ands or buts, removing third adjacent protections on the FM band will increase the noise floor.  This will lead to more interference on the average FM radio, which will lead to more people getting fed up and tuning out.

Here is why:  You cannot change the laws of physics.  FM transmitters have output filters that attenuate side band energy, that is to say, energy transmitted on 1st, 2nd and 3rd adjacent channels.  A 50,000 watt FM station on 100.3 MHz will have side band energy on 100.1, 99.9 and 99.7 MHz as well as 100.5, 100.7 and 100.9 MHz.  Due to the limitations on the components used to construct those filters, they can only be designed with the accuracy of the components used.  In other words, most electrical components have a tolerance given in percent, example +/- 10%.  That means that the value of the component will change, usually because of heating.  Therefore, output filters cannot be constructed to limit emissions to only the main channel and say one adjacent channel, they would drift off frequency.

Also, creating a brick wall filter that cuts everything off at the second adjacent channel will cause distortion of the RF signal on the main channel.  With analog AM and FM transmitters it cannot be done.  Digital transmissions are another story, but that is not what we are talking about here.

That is an engineer’s point of view.

One other thing about adding hundreds more LP FM signals.  There should be something that stipulates most (say >50%) of the programming be locally originated.  Recorded for later playback is fine.  Having thousands of LP stations broadcasting the same syndicated shows or running voice tracked automation 24/7 would be a recreation of the AM band as it currently exists.  If you want to listen to that, then it already exists, help your self.  I, on the other hand, would like to avoid the AMization of the FM band.

That is all.

I sent off a letter to my Senators and Congressman this morning regarding HR 1147/S 592 AKA Local Community Radio Act.  Basically I am against this.  Not that I don’t appreciate what it is trying to accomplish.  I believe the technical degradation of the FM band is a higher concern.  After all, if we turn the FM band into what the AM band has become, nobody will listen to radio.

Radio is too important to ruin.  Here is what I wrote:

I strongly urge you NOT to support the bipartisan Local Community Radio Act (HR 1147/ S. 592) sponsored by Reps. Mike Doyle and Lee Terry and Sens. Maria Cantwell and John McCain.

In spite of what many have said, Low Power FM (LPFM) contributes to the technical degradation of the FM service.  By adding more and more signals covering every possible spot in the FM spectrum, the noise floor is raised causing many FM receivers to “picket fence” which is annoying to most listeners.

Radio has suffered enough degradation over the last few decades.  AM radio is now so fraught with interference, especially at night, most people do not even consider listening to it.  Packing the FM dial with thousands of low power operators will create the same problems and cause most people to abandon radio altogether.

I am a strong proponent of 1st amendment rights.  I believe the sponsors of this bill are well intentioned, however misinformed. I believe that the deregulation of commercial radio allowing one company to own 1,200 radio licenses has created most of the problems we see today.

Clear Channel, in particular, has removed almost all localism from radio, creating bland canned music channels.  Their modus operandi was to buy a group of radio stations in a market, combine the stations under one roof, get rid of most of the staff, and drop the advertising rates so other local stations could not compete.  Non-Clear Channel stations were then forced to make cuts in there advertising rates and or expenses to stay in business.

The answer is not to create a bigger mess.  Instead:

1.  Push the FCC to tighten ownership rules.  In some ways the horse is already out of the barn, but it would prevent another Clear Channel from forming in the future.
2.  If major radio groups go bankrupt and are broken up, allow it to happen, do not intervene.  This will allow real radio broadcasters to pick up the pieces and put something together.  Perhaps investigate supporting small radio owners by waiving FCC fees and limited tax breaks for a period of time.
3.  Push the FCC to continue with the localism hearings they were conducting.
4.  Push the FCC to update the EAS and make a workable Emergency Alert System in the US.

Radio is too important a resource to have it ruined.  Of all the media outlets, radio is the most robust.  During an emergency often times the utility grid is down.  Many radio stations have backup power generators and can provide vital information when the internet, phone system, cable TV network, cellphone system, e-mail, etc are down.

Radio can provide local government important mass access to their constituents during elections and at other important times.  Radio is free, there are no subscription fees, no service providers, etc.  Almost everyone owns a radio, most people own several.

Small savvy radio owners can make a go of it, provided the deck is not stacked against them.

Please DO NOT support the Local Community Radio Act. Thank you.

If you want to get involved, you can go the the Free Press website, there you will find a link to a “Take Action” page (not sure that link will work).  Again, I am not opposed to Free Press, or even Free Radio.  Packing the FM spectrum with LPFM, translators and the like will only create reception problems.  This is just become another reason for people not to listen to radio.

Emergency warning siren station

EAS, or more properly, the Emergency Alert System, is a government mandated system of encoders and decoders designed by the federal government to alert the public in case of war or other emergency.  It, and it’s predecessor, EBS (Emergency Broadcast System) have never been activated by the federal government.  Both systems, however, are used extensively by local and state governments for things like weather alerts, amber alerts, etc.

Back in the mid-90’s the FCC had a chance to redo the EBS and produce something that was a streamlined and effective tool for public warning.  Unfortunately, the EAS system is neither.  Rather, it is a cumbersome system of weekly and monthly tests scheduled around pre-conceived notions that how the system is tested every week will be how the system works in an emergency.  In practice, this is generally a good theory of system design, but it has failed miserably with EAS.  The reasons why are thus:

• Most all emergencies are local or at most state wide events.  To this day, very few state and or local government emergency managers would be able to activate EAS for their area.  The reason is there is minimal if any interface with the LP-1 EAS stations or station personnel.  Ignorance and apathy on behalf of both radio station personnel and government officials is the main culprit.
• Most stations are un-maned for large portions of the day.  Even if government official could/did call the station, chances are, nobody would be there.  If by chance, arrangements were made to contact station employees at home, they would have to interface with the EAS equipment remotely, which ads complexity to an already complex system.
• EAS messages are still mainly relayed from radio station to radio station, the so called daisy chain net work that has been shown numerous times to be unreliable.
• The system of SAME codes, FIPS identifiers is not necessarily bad, the application in this case leaves something to be desired.  The FCC had a chance to update EAS before the HDTV rollout.  One would assume that any improvements could have been built into the new TV sets that are now being sold, but again, that opportunity was missed.  For example, I suggested that each TV have a set up screen option where the owner could input their zip code.  They could also choose what types of alerts they would want to know about and even base the alerts types on the time of day.  Live in a flood zone, the FFW (Flash Flood Warning) 24/7.  Live in tornado alley, TOR (Tornado Warning), etc.  The cable companies then pipe in the local NOAA all hazards radio station.  All the sudden there is a real national alert system in place using mostly non-broadcast wireless systems.  Add to that the ability to sign up for emergency e-mails and text messages for specific areas (many places are currently doing this) and there is multiple message paths.

The system as is is not reliable and sooner or later that will be shown with a large scale failure.  Recently, the FCC held a summit with the Department of Homeland Security.  The cliff notes version of this event is: Yes, the system can be made better.  Let’s keep throwing the same ideas at the wall and see if anything sticks this time.  Excuse me if I don’t do back flips, this is the same information that was discussed during the last “lets revamp EAS” discussion back in 2005 (04-296).

In the mean time, the EAS continues to be a good fund raiser for the FCC enforcement bureau.  Which, you know, it is easier to go to a licensed radio station and bust them for not re-transmitting the RMT (Required Monthly Test) than it is to go out and bust some of the numerous pirate radio operators, some of whom are operating in the same city/metropolitan area as a field office.

The shame of it is, it could work without a great deal of cost, very well.