Status of AM revitalization

It has been about five years since the AM revitalization initiative was first proposed by the FCC and about five years since the first rules changes took place.  Those rules changes included:

  1.  FM translators for AM stations
  2. Allowing stations to use MDCL (Modulation Dependent Carrier Level)
  3. Changing some of the antenna radiation efficiencies requirements
  4. Changing some of the allowable interference towards other stations requirements
  5. Loosening some rules regarding proofs, MOM, night time coverage over city of license, etc

Things that were not addressed:

  1. Receiver quality and technical advances
  2. Ambient noise levels on Medium Frequency (among other) bands
  3. HD Radio or any other digital modulation scheme

Things that were discussed then changed subsequently as a separate initiative:

  1. The main studio rule, which was eliminated for all broadcasting stations

What has been the net effect of these changes?  Has any of this revitalized AM radio?  The net effect has been approximately more of the same.  There have been many stations that have applied for and received licenses for FM translators.  Those stations, in most cases that I am aware of, receive some benefit of extra revenue because of this.  Stations with carrier power levels of 10-50 KW have taken advantage of MDCL technology to save some money on their electric bill.  Nothing wrong with that.

For stations that use a directional antenna, proofs of performance and other DA matters with the FCC have become slightly easier.  Medium Frequency (MF) directional antennas are very large, require a lot of land, are expensive to build, license and maintain.  I know of several stations which have downgraded from a class B station with a directional antenna to a class D station with a single tower and greatly reduced night time power.   Those downgraded stations certainly benefit from an FM translator.

I have heard from more than one AM station owner who says after four years, they are going to “turn in their AM license and just keep the FM.”  I am sure that they are not informed regarding translator rules.  Perhaps, however, the FCC will allow this in the future; a sort of back door commercial low power FM station classification.

The AM band zenith occurred in November of 1991, when there where 4990 licensed AM stations in the United States.  As of June 30, 2018, the total stands at 4633.  That is a decline of 357 stations.  There are currently 90 AM stations listed as silent.  That represents a decline of approximately 9 percent or less than 1/2 of one percent per year.

The last number of AM stations actually transmitting HD Radio that I found was approximately 110, which differs from the iBiquity (and FCC) number of 240.  The FCC data base includes stations which are currently dark, or stations which where transmitting HD Radio at one time but have since turned it off.  Either way, it is a small percentage of licensed stations.  As of this time, AM HD Radio appears to be a non-starter.  In other parts of the world, Medium Frequency DRM seems to be doing well.  The difference seems to be that the DRM operation is all digital and the digital carriers have a much higher power level than that of the hybrid AM HD Radio being used here.

Of those 4633 standard broadcast stations, approximately 260 belong to iHeart radio, Cumulus owns approximately 120 and Townsquare owns approximately 80.   That accounts for 460 stations.  The remaining 4000 or so stations currently on the air are owned by medium sized corporations or individual owners.  The reason for the distinction; I have noticed that the large corporate owners tend to concentrate resources and effort on those licenses that will make the best return, e.g. FM stations.  Of course, there are a few exceptions to that trend, often in major markets.

Of those 4000 or so remaining AM stations, most seem to be treading water.  They are making enough money to stay on the air.  There are a few AM stations that are doing remarkably well.  Those are the ones with primarily  local content.  The vast majority of AM stations are running some type of syndicated talk.  News/talk and sports radio are the two most common formats.  Conservative news/talk seems to be the bread and butter.  Liberal news talk has been tried, but none have succeeded.

Last May, the Supreme Court overturned the Professional and Amateur Sports Protection Act of 1992.  That federal law prevented gambling on outcomes of professional and college sports games.  With the overturn of that rule, individual states can now legalize sports betting.  It will be interesting to see what states allow legalized sports gambling and whether that has any effect on the various sports radio formats.  I can see where individuals and odds makers may want to get good inside information regarding team dynamics and so on.  The sports network that can furnish such information may be in a good position to carve out a niche.

Music can and does sound good on AM when it is done correctly.  There is a great misconception that AM fidelity is poor.  That is not necessarily so.  There are a good many AM receivers these days which have much better bandwidth than the previous generation receivers.  I am noticing that car radios in particular sound much better.  Yes, there are still problems with electrical noise and night time interference.  There are still technological improvements that can be made for analog AM on the receiver side.

In summary; the revitalization efforts have benefited some AM stations in some areas.  The truth is, that many AM stations have been let go for so long that there is no saving them.  Other AM stations that are still viable are making a go of it.  In nautical terms; there is six feet of water in the hold, the pumps are working and the ship is not sinking… for now.

No, this time we really mean it

The FCC is stepping up enforcement on pirate radio. They have released an enforcement advisory, which you can read here.

The advisory starts out like this:

WARNING: Unauthorized Radio Broadcasting is Illegal
Persons or Businesses Operating “Pirate” Broadcast Stations
Are in Violation of Federal Law and Subject to Enforcement Action

Okay, so when you stop laughing, here is what will really happen: They will go out, bust a few pirates, issue larger than normal Notices of Apparent Liability, collect none of the money from them and call it a huge success.  I doubt very much that the FCC or congress has the wherewithal to wage an all out effort against pirate broadcasting. This is the same FCC that eliminated most of its field enforcement agents and closed most of their field offices.  But that doesn’t matter either, because the NYC field office is still open and within a ten mile radius of that, there are likely a dozen or more unlicensed broadcasters.

In the mean time, if you are a licensed broadcaster, God forbid you accidentally miss a Required Monthly Test or have an unlocked tower fence.

It is like the city police force that sits on a stop sign writing tickets to otherwise law abiding motorists when the next block over, kids are out in the street openly selling bricks of heroin.  Meanwhile, the chief of police sits in his office furiously typing blistering memos saying that the sale of heroin is illegal.

The side mounted FM antenna

In an interesting development, the FCC has taken notice of some pattern distortion from the side mounted FM antenna of KFWR, Jacksboro, Texas.  For those, like myself, not familiar with Texas Radio, that is in the Dallas/Fort Worth market.  The crux of the issue is co-channel interference to KCKL in Malakoff, Texas.  These two locations meet the spacing requirements in 73.207 (215 km).  The issue is with the side mounted ERI antenna and what appears to be intentional pattern optimization.

From the FCC order to show cause:

ERI’s president, Mr. Thomas Silliman, acknowledging that KFWR’s antenna “was mounted in a favorable direction, but… has not been directionalized and therefore is legal.” Mr. Silliman adds that the custom lambda tower at the top of the new KFWR tower was specifically designed for operation at KFWR’s frequency of 95.9 MHz, and that the tower’s lattice structure is “repetitive at the half wave of the specified FM frequency.” Thus, “if one picks a favorable mounting position on the tower, every element in the array sees the same favorable mounting result. Mr. Silliman also states that vertical parasitic elements are used to make the vertical radiation pattern “more circular” and reduce the vertically polarized gain to the east. In a subsequent pleading, ERI elaborates that its computed values “are relative to an RMS measured field of 1.0.” Mr. Silliman concedes that the mounting of the antenna on a certain tower face constitutes “pattern optimization,”arguing later that this is a common practice used by all antenna manufacturers, but states that it is the ERI’s policy “not [to] increase the directivity of the antenna pattern.”

The FCC concludes that the directionality of the side mounted antenna, in this case, is clearly intentional. The radiated power towards co-channel KCKL was calculated to be 274.5 KW, which is in excess of the 100 KW limit and orders KFWR to reduced TPO from 25 KW to 9.1 KW.

We have lots of these out in the field:

Side-mounted Shively 6810 antenna.  WSPK, Mount Beacon, NY
Side-mounted Shively 6810 antenna. WSPK, Mount Beacon, NY

In fact, I believe the majority of our FM stations use side mounted antennas.  Some of them are mounted to a leg and some are mounted to a face.  Usually, I try to place the antenna on the tower so that the bays are facing the desired audience.  This information is given to the manufacture when ordering the antenna so that proper mounts can be furnished and the mounting distance between the tower and antenna properly calculated.  That is about the extent of any “optimization” that is allowed.

As the FM band gets jam packed with FM signals, this may become more of an issue in the future, particularly around dense signal areas around major metropolitan areas.

Filing an STA

FCC rules stipulate that when a station is operating at a variance from its licensed parameters for more than 10 days, Special Temporary Authority (STA) is required.  The reasons for requesting an STA are varied but could include things like:

  • Damaged transmission equipment
  • Loss of transmitter site or building use
  • Loss of tower
  • Eviction
  • Facilities upgrade or renovation
  • Natural disaster

The loss of transmission tower at WUPE-FM falls into one of those broad categories.  Thus, we have filed a STA with the FCC for temporary transmission facilities while a new tower is being constructed.  Since the old tower is completely lost, we specified a new tower location, new height above average terrain (HAAT), new ERP and environmental certification.  To gather that information, several steps were needed:

  • Obtain new tower location.  This was done with a GPS receiver and verified on itouchmap.com.  Once the NAD83 position was obtained, it needed to be converted to NAD27 for the FCC filing.  The FCC has a conversion tool on their website.
  • HAAT calculation is fairly simple, use the HAAT calculator tool on the FCC website.  For this, the antenna radiation center height Above Mean Sea Level (AMSL) is needed.  Using a topographical map, find the ground level AMSL, convert it to meters, then add the radiation center height above ground level (AGL).
  • The Effective Radiated Power (ERP) calculation is also simple; Transmitter Power Output (TPO) minus system losses (transmission line and antenna gain). It is easiest to do this in dBm, e.g. convert the TPO from Watts to dBm, then add or subtract the gain or losses in dB, convert the final product back to Watts.
  • The environmental statement is slightly more tricky.  Basically, the filer is certifying that the STA complies with all environmental regulations including OET-65 (RF exposure limits).  Since the temporary antenna is significantly lower than the original, some investigation is required.  For this, there are two methods to demonstrate compliance; ground measurements with a NARDA meter, or RFR worksheets which are a part of the broadcast station renewal form, FCC-303s.

I have taken the RF worksheet sections out of the 303s and separated them into the FM RF Worksheet and the AM RF Worksheet.  These worksheets are not effective for large tower farm type sites where there are too many variables and RF contributors to be accounted for.  The calculations on the worksheets are not conclusive, however, if the facility in question falls under the limits, it is generally accepted as being in compliance.   Taking ground measurements with a NARDA meter is the definitive method for determining RFR compliance.  Since this is a relatively simple site, the worksheet calculations should be sufficient.

The worksheet calculations show that the RFR is with in both the controlled occupations limits and the uncontrolled general population limits.

WUPE-FM temporary antenna RFR worksheet
WUPE-FM temporary antenna RFR worksheet

The position of the new temporary pole verified on itouchmap.com:

itouch_nadams

It is never good to be operating at a varience from licensed parameters without notification of the FCC. Such things could lead to fine or other problems for the broadcaster.