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 station 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 were 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 let 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?

Pai says “No fighting!”

In the putsch to revitalize AM, FCC Commissioner Ajit Pai advises that it would be best if we did not argue about solutions.  Actually what was said was this:

On the other hand, if too many broadcasters allow the perfect to become the enemy of the good, our efforts could be doomed by infighting.

That is well and good, so long as the proposed solution does not make things worse.  I would posit that worse is already the enemy of the good, so any proposal that would make things worse should be protested vigorously.

I have written quite a bit about AM, its relevance and possible revitalization.  There is no one sized fits all solution to the problems facing AM broadcasters.  In the final equation, stations should be judged on their viability as a business and service to the community.  Those that fail to measure up should turn in their licenses.

Update: And so it begins. The narrative is already being shaped, as Darryl Parks (original post has been removed) has found out.  After posting in his blog a few comments on the FCC’s revitalization efforts, he was excoriated by several high profile broadcasters calling his comments “Beyond not helpful.”  For those not versed in double speak, that means it is harmful.  While Parks may not have gotten all the technical jargon exactly right, his points are valid and are in agreement with the widely accepted laws of physics.  I know, I know, quoting science is dull and boring, something that conspiracy theorists are well practiced with.

Now, SHUT UP AND GET BACK IN LINE

Stay sharp, do not be fooled

I am wondering what is going on with the HD Radio roll out these days. Particularly the all digital AM conversion scheme being bantered about so often last spring. Not much is being discussed publicly about that or the AM revitalization.  I have found FCC Commissioner Clyburn’s remarks at this week’s NAB Confab interesting.  HD Radio is paid lip service here:

There are hurdles: if broadcasters do not broadly embrace the HD technology and the multicasting and other enhancements that it makes possible, listeners will have few incentives to buy digital receivers. Likewise, if no consumers own digital receivers, then there is no reason to broadcast in digital.
But I’m not worried. More than 15 million digital receivers have been sold so far, and that number will only rise. Thirty-three auto manufacturers include or plan to include digital receivers in their cars, and those receivers are standard equipment in over 80 models. This will dramatically increase the number of digital receivers in the coming years.

But in the solutions for AM broadcasters, HD Radio is not mentioned at all.  What is put forward as a six (actually five) step plan to revitalize AM radio turns out to be some rearranging of the deck chairs and little more. Cliff notes version for the FCC’s AM revitalization:

  1. Open a one time filing window for AM license holders to acquire an FM translator
  2. Relaxing community coverage rules for AM licensing allowing greater flexibility for transmitter siting
  3. Eliminating the “Ratchet Rule” used in night time allocation studies for new facilities
  4. Permitting more widespread use of MCDL technologies by eliminating STA requirements
  5. Reducing minimum field strength requirements by twenty five percent allowing the use of shorter towers

While those options may save an AM license holder some money, none of them do anything to improve the technical quality of AM broadcasting.  Several of them (#2, 4 and 5) will, in fact if widely implemented, reduce signal levels over cities of license, making electrical noise and interference problems more prevalent. This is a step in the wrong direction.

These points are basically a rehash of some to the MMTC’s (Minority Media Telecommunication Council) ideas for a radio rescue first bantered about in 2009.

This demonstrates that the NAB and the FCC are not at all serious about revitalizing the AM band but merely marking time and making it look good until the final transmitter is switched off.

AM licensees are on their own, but all is not lost.  I have noticed several successful stand alone AM station that are not only surviving but thriving.  The common thread in these station is good local programming.  On the technical side of things; a well maintained plant with good quality audio feeding a properly operating transmitter and antenna array will go a long way to providing good service to the city of license.

Et tu, Massachusetts?

The Massachusetts house is considering a bill to outlaw unauthorized transmission in the AM and FM broadcast band. The bill, H.1679 is included here for your reading pleasure:

SECTION 1: The General Laws, as appearing in the 2010 Official Edition, is hereby amended by inserting after chapter 93I, the following chapter:-

Chapter 93J. UNAUTHORIZED RADIO TELECOMMUNICATION

Section 1. As used in this chapter the following words shall, unless the context clearly requires otherwise, have the following meanings:—

“Emission”, radiation produced, or the production of radiation, by a radio transmitting station.

“License”, a radio frequency assigned by the Federal Communications Commission for use by amplitude modulation (AM) radio stations between the frequencies of five hundred thirty kilohertz (kHz) to seventeen hundred kilohertz (kHz), or frequency modulation (FM) radio stations between the frequencies of eighty-eight megahertz (MHz) to one hundred eight megahertz (MHz).

“Person”, a natural person, corporation, association, partnership or other legal entity.

“Radio telecommunication”, any transmission, emission or reception of signals and sounds or intelligence of any nature by wire, radio, optical or other electromagnetic systems

Section 2. Any unauthorized radio telecommunication or emission to, or interference with, a public or commercial radio station licensed by the Federal Communications Commission are prohibited.

No person shall (a) make, or cause to be made, a radio telecommunication in the Commonwealth unless the person obtains a license or an exemption from licensure from the Federal Communications Commission under 47 U.S.C. s. 301, 47 U.S.C., s. 605, or other applicable federal law or regulation; or (b) do any act, whether direct or indirect, to cause an unlicensed radio telecommunication to, or inference with, a public or commercial radio station licensed by the Federal Communications Commission or to enable the radio telecommunication or interference to occur.

Section 3. The attorney general may bring an action pursuant to section 4 of chapter 93A against a person or otherwise to remedy violations of this chapter and for other relief that may be appropriate.

Section 4. A person may assert a claim under this section in superior court, whether by way of original complaint, counterclaim, cross-claim or third-party action, for money damages, injunctive relief, and forfeiture of any property used in violation of this section. Said damages may include double or treble damages and attorneys’ fees and costs.

No forfeiture under this section shall extinguish a perfected security interest held by a creditor in a conveyance or in any real property or in any personal property at the time of the filing of the forfeiture action. Said forfeiture action shall be commenced in superior court.

This legislation is slightly different from the anti-pirate laws in NY and Florida as it appears the unauthorized operators would be liable for civil and not criminal penalties.  That is an interesting twist; potentially, a commercial broadcaster could sue an interfering pirate operator for loss of revenue, etc.  At least that is my interpretation of the above text and as I am not an attorney, I could be wrong.

It is also interesting to me that very few pirate operators in NY have actually faced a non-FCC law enforcement agency as of yet.  I have heard about only one, which was in NYC.  Is the criminalization of unauthorized broadcaster really affective in curbing pirates?  A quick tune around the NYC FM dial says no.  There are more pirates than ever and the NYPD seems to be too busy with other issues to go after them.