It’s time to start another cycle of radio station license renewals. From an engineering standpoint, there are a few things that may or may not fall under the engineering department:
RFR exposure to the public
Environmental impact of towers and buildings
Technical aspects of public file
These items have not changed extensively from the last renewal cycle. A quick review is in order to make sure that all the FCC’s requirements are being met.
RFR exposure to public
Protecting the public from over exposure to RF has been an FCC hot button issue for the last 15 to 20 years. There are numerous places where radio station need be concerned about this. AM and FM transmitter sites, as well as mountain top tower farms are prime enforcement areas for the FCC when it comes to RFR. In a few well known incidents, the addition of RF generators to a location in the form of cellular or other wireless carriers contributed to the overall RF levels and uncontrolled areas were found to be over the exposure limit. Mount Wilson is one of these.
Single transmitter sites or sites that have only broadcast signals can usually be calculated using the FCC formulas provided in supplement a of OET-65. In other cases, the use of a NARDA meter to complete an on site measurement and a detailed report of findings will need to be completed by the licensee and attached as a part of the renewal. Mount Beacon (Beacon, NY), where two DTV stations, media flow and several cellular, 3G and 4G wireless transmitters have been added since the last license renewal in 2006 is a prime example.
In addition to certifying the public exposure is below the Maximum Permissible Exposure (MPE), tower workers and other site workers also need to be protected. This includes working on or near antennas under power.
Power limits for working on "hot" AM towers
Estimated power levels to comply with occupational/controlled limits for on-tower exposure of persons climbing AM broadcast towers.
FM antennas are a little more complicated. Section 2 of OET-65 supplement a gives the breakdown on how to compute the theoretical power densities for FM broadcasting. It can get a little complicated and as noted above, in highly used tower farms and tower sites, actual on the ground measurements will likely need to be made. Tables 5 and 6 give best and worst case scenarios for public and occupational exposure to RF.
Table 5, OET65a
Best and worst case scenarios for RF exposure in the FM broadcasting band for public exposure. The upper number is worst case, the bottom number is best number.
Environmental impact
Licensees have been required to certify that there stations comply with FCC 1.1307, to the effect that environmental assessments must be prepared for certain situations where:
Facilities that are to be located in an officially designated wilderness area.
Facilities that are to be located in an officially designated wildlife preserve.
Facilities that: (i) May affect listed threatened or endangered species or designated critical habitats; or (ii) are likely to jeopardize the continued existence of any proposed endangered or threatened species or likely to result in the destruction or adverse modification of proposed critical habitats, as determined by the Secretary of the Interior pursuant to the Endangered Species Act of 1973.
Facilities that may affect districts, sites, buildings, structures or objects, significant in American history, architecture, archeology, engineering or culture, that are listed, or are eligible for listing, in the National Register of Historic Places. (See 16 U.S.C. 470w(5); 36 CFR part 60 and 800.) To ascertain whether a proposed action may affect properties that are listed or eligible for listing in the National Register of Historic Places, an applicant shall follow the procedures set forth in the rules of the Advisory Council on Historic Preservation, 36 CFR part 800, as modified and supplemented by the Nationwide Programmatic Agreement for the Collocation of Wireless Antennas, Appendix B to Part 1 of this Chapter, and the Nationwide Programmatic Agreement Regarding the Section 106 National Historic Preservation Act Review Process, Appendix C to Part 1 of this Chapter.
Facilities that may affect Indian religious sites.
Facilities to be located in a flood Plain.
Facilities whose construction will involve significant change in surface features (e.g., wetland fill, deforestation or water diversion).
Antenna towers and/or supporting structures that are to be equipped with high intensity white lights which are to be located in residential neighborhoods, as defined by the applicable zoning law.
While these statements/conditions seem to point towards new licensees, I recall there being an “Environmental Certification” on past FCC form 303-s where the licensee had to certify that they where meeting the above conditions, or provide an environmental assessment. This seems especially true for AM stations existing in a flood plain.
Public file items (radio perspective):
The License. Stations must keep a copy of their current FCC construction permit or license in the public file, together with any material documenting Commission-approved modifications to the authorization. The license or permit reflects the station’s authorized technical parameters (such as its frequency, call letters, operating power and transmitter location), as well as any special conditions imposed by the FCC on the station’s operation. It also indicates when it was issued and when it will expire.
Applications and Related Materials. The public file must contain copies of all applications involving the station filed with the Commission that are still pending before either the FCC or the courts. These include applications to sell the station or to modify its facilities (for example, to increase power, change the antenna system, or change the transmitter location). If a petition to deny any application was filed, the file must contain a statement to that effect, and the name and address of the petitioning party. Applications must be maintained until “final” FCC action on them, when the action can no longer be appealed or reversed.The station must also keep copies of any granted construction permit or assignment or transfer application if its grant required us to waive our rules. Applications that required a waiver, together with any related material, will reflect each particular rule that we waived, and must be maintained as long as any such waiver remains in effect.Also, if the FCC renewed the station license for less than a full term, the station must keep that renewal application (FCC Form 303-S) in the file until grant of its next renewal application by final FCC action. We may grant such a short-term renewal when we are concerned about the station’s performance over the previous term. These concerns will be reflected in the renewal-related materials in the public file.
Citizen Agreements. Commercial stations must keep copies of any written agreements that they make with local viewers or listeners. These “citizen agreements” may deal with programming, employment, or other issues of community concern. The station must keep these agreements in the public file for as long as they are in effect.
Contour Maps. The public file must contain copies of any station service contour maps or other information submitted with any application filed with the FCC that reflects the station’s service contours and/or its main studio and transmitter locations. The Commission’s application forms require submission of contour maps only from stations that do not certify that their signals cover their city of license. These documents must stay in the file for as long as they remain current and accurate regarding the station.
Material Relating to an FCC Investigation or Complaint. Stations must keep material relating to any matter that is the subject of an FCC investigation (including EEO audits) or a complaint that the station has violated the Communications Act or FCC rules. The station must keep this material in its file until the FCC notifies it that the material may be discarded. Since the FCC is not involved in disputes regarding matters unrelated to the Communications Act or FCC rules, such as private contractual disputes, stations do not have to retain material relating to such disputes in the public file.
Ownership Reports and Related Material. The public file must contain a copy of the most recent, complete ownership report (FCC Form 323 for commercial stations, FCC Form 323-E for noncommercial educational stations) filed for the station. Among other things, these reports disclose the names of the owners of the station licensee and their ownership interests, list any contracts related to the station that are required to be filed with the FCC, and identify any interests in other broadcast stations held by the station licensee or its owners.
List of Contracts Required to be Filed with the FCC. Stations must keep in the public file either copies of all the contracts that they have to file with the FCC, or an up-to-date list identifying all such contracts. If the station keeps a list and a member of the public asks to see copies of the actual contracts, the station must provide the copies to the requester within seven calendar days. Contracts required to be maintained or listed in the public inspection file include:· contracts relating to network service (network affiliation contracts);· contracts relating to ownership or control of the licensee or permittee or its stock. Examples include articles of incorporation, bylaws, agreements providing for the assignment of a license or permit or affecting stock ownership or voting rights (stock options, pledges, or proxies), and mortgage or loan agreements that restrict the licensee or permittee’s freedom of operation; and· management consultant agreements with independent contractors, and contracts relating to the utilization in a management capacity of any person other than an officer, director, or regular employee of the licensee.
Political File. Stations must keep a file which contains “a complete record of a request to purchase broadcast time that: (A) is made by or on behalf of a legally qualified candidate for public office; or (B) communicates a message relating to any political matter of national importance, including: (i) a legally qualified candidate; (ii) any election to federal office; or (iii) a national legislative issue of public importance.” The file must identify how the station responded to such requests and, if the request was granted, the charges made, a schedule of time purchased, the times the spots actually aired, the rates charged, and the classes of time purchased. The file also must reflect any free time provided to a candidate. The station must keep the political records in the file for two years after the spot airs.
EEO Materials. As noted earlier, licensees must submit certain forms containing EEO information and include copies in their station public files. Thus, all stations employing five or more full-time employees must put an EEO public file report in their station public file each year. We also require each radio and TV station licensee to file a Form 396 EEO Program Report with its license renewal application and to include the Report in its public file. Those licensees that file a Form 397 Broadcast Mid-Term Report must also include a copy in the public file. These materials must be retained in the file until final action on the station’s next license renewal application. A new station applicant or prospective station buyer, if it intends to employ five or more full-time employees, must file a Form 396-A Broadcast EEO Model Program Report with its new station assignment or transfer application and the Report must be included in the public file as a part of the underlying application and retained in the file until the grant of the underlying application becomes final.
“The Public and Broadcasting.” Stations must keep a copy of the current version of this Manual in the public file and provide a copy, upon request, to any member of the public.
Letters and E-Mails from the Public. Commercial stations must keep in their files, for at least three years, written comments, suggestions, and e-mails received from the public regarding their operation. (Noncommercial educational stations are not subject to this requirement.) This obligation is limited to comments, suggestions, and e-mails sent to station management or a publicized station address. Letters need not be placed in the public inspection file when the author has requested that the letter not be made public or when the licensee feels that it should be excluded from public inspection because of the nature of its content (such as defamatory or obscene letters). Moreover, although television stations that post their public file materials on their websites must include e-mails received from the public, they need not post letters from the public, as long as they include hard copies of such letters in their public files, and a notice on their website that the letters can be located in the file. As noted above, all or a part of a station public file may be maintained on a computer database, as long as a computer terminal is made available, at the location of the file, for members of the public who wish to review the file. Accordingly, as an alternative to maintaining hard copies of e-mails in the public file, a station may place the e-mails on a computer database, as long as a terminal is made available at the location of the public file to members of the public who wish to review the file.
Quarterly Programming Reports. Every three months, each broadcast radio and television station licensee must prepare and place in its station public file a list of programs containing its most significant treatment of community issues during the preceding three months (“issues/programs lists”). The list must briefly describe both the issue and the programming during which the issue was discussed, including the date and time that each such program was aired and its title and duration. The licensee must keep these lists in the file until the next grant of the station renewal application has become final. Television stations will be required to file a Standardized Television Disclosure Form instead of these lists once that form is approved and made available. The form, which will also be filed quarterly, will require commercial and noncommercial educational television broadcasters to provide detailed information on the efforts of their station to provide programming responsive to issues facing their communities in a standardized format.
Time Brokerage Agreements. A time brokerage agreement is a type of contract that generally involves a station’s sale of blocks of airtime to a third-party broker, who then supplies the programming to fill that time and sells the commercial spot announcements to support the programming. Commercial radio and television stations must keep in their public files a copy of every agreement involving: (1) time brokerage of that station, or (2) time brokerage by any other station owned by the same licensee. These agreements must be maintained in the file for as long as they are in force.
Lists of Donors. Noncommercial educational television and radio stations must keep in their public files a list of donors supporting each specific program. These lists must be retained for two years after the program at issue airs.
Local Public Notice Announcements. When someone files an application to build a new station or to renew, sell, or modify an existing station, we generally require the applicant to make a series of local announcements to inform the public of the application’s existence and nature. These announcements are either published in a local newspaper or made over the air on the station, and are intended to give the public an opportunity to comment on the application. A statement certifying compliance with this requirement, including the dates and times that notice was given, must be placed in the public file. The only exception to this public notice requirement is when the proposed station sale is “pro forma” and will not result in a change of ultimate control, or the modification application does not contemplate a “major change” of the station facilities.
Blanketing interference refers to the phenomena of receiving radio signals on devices not designed to do so. In broadcast radio, this is defined for AM stations in part 73.88 as:
The licensee of each broadcast station is required to satisfy all reasonable complaints of blanketing interference within the 1 V/m contour.
And for FM stations, it is part 73.318:
Areas adjacent to the transmitting antenna that receive a signal with a strength of 115 dBu (562 mV/m) or greater will be assumed to be blanketed.
Any interference to any device with that signal contour is blanketing interference. 73.318 further states that:
permittees or licensees who either (1) commence program tests, or (2) replace their antennas, or (3) request facilities modifications and are issued a new construction permit must satisfy all complaints of blanketing interference which are received by the station during a one year period.
I have always taken a more pragmatic approach to interference complaints. Rather than pass the buck and tell the home owner or business owner that it is not our (the radio station’s) problem, I’d go and try to help them out. Generally speaking, the interference problems are close to the transmitter site, so on the next trip to that site, I would bring RFI filters and my 25 years of RF experience and solve the problem. I would like to think this help the station’s and the company’s imagine in the community.
Most of the problems are pretty easily solved, although once in a while, I have come on some head scratchers. An AM station playing on the outlets in a guys garage, the mic cords on a church PA system, and an off switch on a blender, off all things. The Bare Naked Ladies had a line in the song Light up my Yard: “we can dance to the radio station that plays in our teeth.”
What I have found is start with the simple stuff first, check the ground on the electrical service entrance panel. One might be surprised to find it disconnected, corroded or missing completely. More than one occasion, I have fixed all of the RFI problems with a simple turn of the screw holding the ground wire to the grounding electrode. In my experience, this is the most common single failure point. A disconnected ground will cause the entire neutral wiring system to act like a giant AM antenna, with all sorts of bad outcomes.
RFI suppression ferrite
Most often, telephone answering machines, cordless phones and other devices powered by wall warts are suspect. Those devices do not have a path to ground. A few turns of all the wires coming and going from said device around a ferrite core such as a snap on TDK RFI EMI filter available from Mouser will take care of it. Mouser has several different versions available.
Occasionally, one needs to put on a detective hat and do some foot work. Mast mount TV antenna preamps can cause untold heartache and problems. One such incident involved the second harmonic of an FM station falling exactly on channel 11′s audio frequency. This was affecting several houses in a one block area. I finally found the problem at one of the complaintent’s house when I pulled the TV out and found the preamp power supply. Unplugging it made all the problems go away (I hate Radio Shack).
Usually process of elimination will discover the problem and thereby reveal a solution. The aforementioned church incident was discovered after I began unplugging microphone cords from the back of the Mackie mixer in the choir loft. It turns out several mic lines were plugged into the back of the mixer, unused and unterminated, creating a large long receiving antenna on the cable shield, which happened to be aligned perfectly to pick up RF from an AM station.
Shortwave Pirate broadcasting has been going on for years. While it is illegal to transmit radio signals without a license, it is not illegal to receive those signals. There is something sort of sneaky, like you are hearing something you shouldn’t, part of some underground thing, listening to these guys. I am almost remiss to write something about it because I don’t want anyone to get into trouble.
Anyway, on any given day or night, pirate broadcasters roam the shortwave airwaves. Much of what they do is typical sophomoric humor, such as playing a song where the only lyrics are “god damn you” over and over again. Some of it can be somewhat entertaining. A lot of what they tell as jokes are inside baseball, you have to listen and do a little research to get it, the Al Fansome reference is one. There are no set times or frequencies. It is quite common to hear one guy tuning up and getting ready to go on the air when the current frequency occupant signs off (happens often on 6925 KHz).
Most of these guys build their own transmitters based on designs found on various websites. Power levels vary, but 10 to 50 watts is common. Because of this, a good low noise receiving antenna is required to pull them out of the noise floor. I have used, with good success, a K9AY terminated loop antenna. We are in a rural area, so it is pretty low noise to begin with. Even so, the coverage with a 50 watt transmitter is remarkable when propagation conditions are good. Sound quality can be quite good for a homemade AM transmitter.
There is a lot of focus on FM pirates these days, that particular setup is likely the easiest to attain for most non-technical types. There are a few AM pirates floating about, those are likely the most difficult to construct and conceal once they are on the air. Both of those broadcast bands have the advantage in that there are many kits and or instructions on how to build a pretty good sounding transmitter. Shortwave seems to be a small cadre of dedicated hobbyists that simply like to fool around on the radio.
In any case, with the FCC stretched thin, it is unlikely that a SW pirate will be busted but not unheard of. One SW pirate station was busted in Florida about a month ago. Even so, that was the first one in almost five years.
For the most part, the activity seems to center between 6850 to 6970 KHz or so. Some others operate around 15055 to 15070 KHz. Here is a brief selection of what one might find on the SW pirate frequencies:
WHYP on 6925 USB “Who Wants To Be A Pirate Radio Operator” at 0156z.
WMPR on 6925 AM “This is WMPR Dancy Party” ID at 0040z.
Captain Morgan Shortwave Radio on 6925AM “Positive Captain Morgan Shortwave ID, email and twilight zone theme at 2209z.
Radio Ronin Shortwave on 6950AM oriental-sounding interval signal, id at 01:04, Outer Limits intro, “She Blinded Me with Science”, strange version of “SOS”, anti-BP comedy skits, id at 01:19
Indira Calling on 6925AM pop music that I can’t identify, “Rock-It”, Indian music, id at about 00:37, “Beach Party 2000″ show, Calcutta mail drop, Beach Boys medley
WEAK Radio on 6925 Shout out to Voice Of Honor. 0048z “Godzilla” 0055z Sabbath.
Channel Z radio on 15067AM 2218z ID and contact info, must be an old show (Blue Ridge Summit maildrop)
And so on. Those call signs are usually spoofs on something. Occasionally, contact information is given out, usually in the form of a mail drop. If so inclined, one might write a letter and receive a QSL card.
Radio Ronin QSL card
There is plenty of information floating around out there about shortwave pirate radio, if one cares to look for it. Two of the more popular discussion forums are HF underground and Free Radio Network Grapevines.
I was this interesting tidbit on the Radio World website the other day. The question is, how much authority does the FCC have to conduct a search of a private residence. The Electronic Frontier Foundation wanted to know therefore they sent a FOIA request to the FCC seeking documents supporting this claimed authority.
The documents received seem to be redacted and some are mostly blank, such as the training module on how to obtain permission to enter private property is supposed to take 6 hours to complete, but consists of 3 paragraphs and 2 questions. Hopefully that is redacted and does not reflect on the quality of agents the FCC is employing these days. The upshot seems to be the agent either needs a warrant or permission.
It may be surprising to some citizens, however, the FCC does have the authority to investigate radio signals, whether they are intentionally generated, as in a pirate broadcaster, or unintentionally generated, as in a piece of gear gone bad.
According to federal regulations, an FCC agent may request entry to inspect a private building anytime he/she believes there may be a device emitting radio frequency energy. This includes anything with a FCC part 15 sticker, which can be computers, TV remote controls, garage door openers, WiFi network routers, etc. This basically covers every house in the US as well as most businesses. Those rules were written when most homes and businesses did not have any RF generating devices and there was little to indicate that they ever would.
Consequences for failure to allow an FCC field agent into a residence or business appears to be the issuance of a citation in the form of a threatening letter. Continued intransigence would be met with a NAL (Notice of Apparent Liability) followed by a forfeiture notice also known as a fine. The typical FCC fine these days seems to be $10,000.00. If it is a repeated and willful violation, equipment can be ceased and the perpetrator arrested.
In instances where safety of life is in question, then every step necessary to disable the offending device needs to be taken. Things like transmitters spurring into aircraft frequencies or TV antenna amplifiers running wide open, also interfering with aircraft frequencies comes to mind.
One of the examples given details a field agent trying to track down a noisy cable TV amplifier. From the FCC field agent’s perspective, the homeowner appears to be a royal pain in the ass. In this day and age when everything has a computer and most of them generate RF, tracking down interference can be a painstaking process, especially where housing is dense. Uncooperative home owners, especially dumb ones, who have no idea what they have plugged in only make things worse.
Still, there is the issue of forth amendment rights, which, if the above law was misinterpreted, misused or applied with the wrong standard would likely be trampled. In these days of extra constitutional activity, giving Los Federales an entry into one’s house might invite unwanted scrutiny by other agencies. As far as changing the rules, with the current group of scoundrels and rouges in the legislative branch, one might end up with something ten times worse than before.
The DC circuit court struck a stinging blow to any thoughts about so called “Net Neutrality” when it overturned the FCC attempts to force Comcast the abide by its rules regarding internet access. The three judge panel ruled that the FCC does not have the authority to force Internet Service Providers (ISP) to give equal access to all its customers. In a nut shell, this means that companies like Comcast, ATT, Verizon, can filter search engine results and traffic, baning websites for no specific reasons.
So much for net neutrality. Say I type something here that is critical of one of those companies, or any ISP for that matter. With a few key strokes, my site will disappear. Gone. Just like that. For those that think the internet is this wonderful open global village thing that can spread the word and and as a sort of modern day check and balance system, think again. In this day and age, when corporations have the same rights as people, look for the large ISPs to spend significant lobbying dollars to keep the laws tilted in their favor. I would expect to also see quite a few campaign contributions to legislators that are friendly to large corporations.
There are several letterwritingcampaigns, urging the FCC to change its classification of ISP’s to a common carrier status, something that would put the ISP’s squarely under the FCC’s control. I look upon those with a jaundiced eye. Perhaps the FCC can be convinced to change the rules, this time. What will happen when a new FCC gets appointed? Will those changes stay in effect? The cynical side of me says no.
Independently run media outlets have traditionally acted as a backstop in our society. There are fewer and fewer of those left these days. I will readily acknowledge that the current crop of radio station owners, with some minor exceptions, have left the industry in a shambles. Their decision to place profit above all considerations, in spite of the license being granted in the public trust, has decimated news rooms, reduced staffing, and relegated community involvement to a minor paper work shuffle at license renewal time. All of this and more have conspired to make radio dull and uninformative. Bland canned formats created and programmed thousands of miles away have ruined local radio flavor. No wonder why people spend money to download from Itunes.
Yet, radio listenership is still high. Radio’s saving grace is it is nearly universal, everyone has a radio, most households have four or five radios. The technology is time tested and it works well. Almost every square mile of the US is covered by broadcast radio signals. Some areas are sparse, but there is at least one or two stations that come in. People are used to radio, there is no learning curve, no subscriber fees, no censorship from a huge faceless mega corporation. Well, that last part is in theory, anyway. It is almost too much of a coincidence that mega corporations also own the majority of radio stations too.
Television as a medium is almost gone. Very few people actually watch over the air TV, most people get their TV piped into their house via cable. Once again, as those in the NY metropolitan area know, there is no guarantee that the local cable operator will carry a broadcast station, vis a vis the WABC-7 Cablevision dispute from last month.
Newspapers are struggling to stay afloat, even the once mighty New York Times has seen better days.
That leaves us with Radio to fill in role of un-censored informer. Can they? Will they? It would be a radical departure from the current course and only time will tell.
The house version of this bill is HR 4809. It seems that in this day and age, as the country is becoming more and more technologically advanced, the communications regulation arm of the federal government is feeling a little left behind. This is a fairly common thing these days, companies are run by accountants and lawyers while the engineers and technologists that actually do what ever technical thing the organization is supposed to be doing are “those funny guys in the basement” or corner or wherever. The bill reads as such:
Section 4(f)(2) of the Communications Act of 1934 (47 U.S.C. 154(f)(2)) is amended by inserting after the first sentence the following new sentence: ‘Each commissioner may also appoint an electrical engineer or computer scientist to provide the commissioner technical consultation when appropriate and to interface with the Office of Engineering and Technology, Commission Bureaus, and other technical staff of the Commission for additional technical input and resources, provided that such engineer or scientist holds an undergraduate or graduate degree from an institution of higher education in their respective field of expertise.’.
That would be a step in the right direction. Hopefully said engineer has several years of experience also, field experience would be even better. As a radio engineer, I learned that theory is great and most of the time everything goes together exactly as it is supposed to. There are those occasions, however, where theory has to be thrown out and a prove-fail/prove-pass approach needs to be taken.
In any case, the bill appears to be on the fast track and hopefully the FCC commissioners will choose and use their staff engineers wisely.
Rumor has it that iBiquity is going to release a software upgrade for the AM IBOC system they peddle. Allegedly it is going to improve the sound quality of the digital signal, allow the analog signal to increase it’s bandwidth to 10 kHz and provide data such as song titles. No word on whether they will be providing software upgrades to consumers for the many HD radioTM receivers out there.
I have been following a discussion on AM quality over the last few days. It seems many engineering types at least, acknowledge that analog AM can sound good, if not more natural that FM. The addition of IBOC hybrid mode on AM station has created more noise and further degraded the station’s main signal by reducing the bandwidth to less than 5 kHz.
Tonight I am listening to WWVA on 1170 kHz, and there is this horrific white noise/hash over top of the station. Same thing on 1190 kHz, all courstesy of WHAM 1180′s IBOC transmission. It is one thing to trash your own station, limiting the analog audio response to 5 kHz. It is quite another thing to trash the adjacent frequencies with noise making them unlistenable.
Here is a brief clip (recorded at 8:00 pm EDT, March 24, 2010):
Second clip, WWVA has faded out (recorded at 9:10 pm EDT, March 24, 2010)
The audio in these videos is adequate but not the best, still, it is pretty clear that there is a whole bunch of white noise on top of WWVA’s signal and on 1190 where no station is coming in. The only conclusion that I can draw is that WHAM is operating with their IBOC turned on. This was recorded at a location that is 197 miles from WHAM and 364 miles from WWVA. I have made several better recordings directly into the computer without the video frequency readout reference.
In 1990, the FCC mandated NRSC-2 (73.44) spectral mask on all AM stations, requiring them to put in brick wall filtering to limit the bandwidth to 10 kHz or less. They also require all AM station to do “equipment performance measurements” (73.1590) to verify that the stations are complying with FCC regulations. This was done because of excessive sideband splatter by AM broadcasters creating interference to adjacent channel stations. I agree in principle with the NRSC-2 standard, I think it serves a purpose. Why then, are stations allowed to interfere with other stations with IBOC signals? Even though Ibiquity has put up a spectral mask that complies with NRSC-2, it still creates interference. Isn’t this a double standard? A station in Pennsylvania gets fined $4,000.00 for operating past its sign off time (because operating after sign off might create harmful interference), yet, WHAM gets to generate noise all night and drowned out adjacent channel stations that are hundreds of miles away?
In the mean time, if the FCC inspector shows up at a station that has not made the required “equipment performance measurements” they will get a fine too.
Am I crazy, or is it hypocritical bull shit to fine one station for potential harmful interference, but then the FCC to ignores its own rules and allows another type interference? Hint: I am not crazy.
I have recorded this in .wav format and I am sending it to the FCC with an interference complaint letter. It is about time somebody made some noise about this noise. Apparently, there are many engineers who feel the same way. Will Ibiquity listen, or will they keep doing CPR on a corpse?
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.
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.
Night time AM signal contour rules, relax requirement to cover 80 percent of city of license at night.
Modify or eliminate principle community coverage rules
Replace minimum efficiency standards for AM antenna systems with “minimum radiation standards”
Allow FM applicants to specify Class C, C0, C1, (etc) in zone I and IA.
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.
If I had to pick between allowing HD RadioTM a 6 dB increase or removing the third adjacent protection for LPFM stations, I’d choose LPFM.
In tests performed by NPR, Ibiquity’sIn Band On Channel (IBOC) digital radio scheme created significant interference to the first adjacent channel when running with 6% of the analog carrier power (-14 dB referenced to carrier) vs. the 1% (-20 dB referenced to carrier) currently allowed. The NAB has would like to see -10 dB referenced to carrier or 10% of the analog carrier power.
Remember Bill Clinton’s sign during his first election, something about the economy, stupid. In this case, it’s the Bandwidth, Stupid. In the US and Canada, FM stations are allowed 200 kHz of spectrum to transmit their analog signals. Analog signals include main channel mono (left plus right), and sub channels for stereo pilot (19 kHz) stereo matrix (left minus right), RDS (57 kHz) and any subcarriers in the 67-92 kHz range.
HD RadioTM radio requires 400 kHz of spectrum to transmit it’s digital carriers. Here come those laws of nature again, you can’t fit 400 kHz bandwidth into 200 kHz of spectrum.
Ibiquity decided to try it anyway, contravening the FCC’s rules about FM broadcasting bandwidthchannels which had been in place since the advent of FM broadcasting in the early 1940′s. What they attempted to do was make the power level on the adjacent channel so low that most analog radios would not have a problem with it while there was a strong signal from another station present. (hey buddy, how about a little of this new thing called crack?) This is known as the capture effect.
Now, Ibiquity created this whole thing to make some money. Nothing wrong with that, this is a market economy after all. They marketed the hell out of HD RadioTM radio, I saw them at various trade shows, they had full page advertisements in all the trade magazines, they hit the phones, it was a full court press (it’ll make you really cool, you’ll be able to do things you can do now and you’ll feel really good). They would even reduce or waive the license fee (here, just take a little rock, try it, on me, you’ll see).
So they were able to sell a very expensive system that has significant coverage issues because of the low power levels needed to satisfy the FCC’s concerns about adjacent channel interference. The NAB and many of the bigradiogroupsboughtin to it (gotcha, crackhead, you’re mine now).
Now, of course, those that bought into HD RadioTM radio want their investment to work, (which it doesn’t right now) so all the talk of power increases and hey, lets just disregard that pesky interference issue. If you ignore it, eventually it will go away (along with the entire FM band).
The problems with HD RadioTM radio are:
Inadequate building penetration at the current power level (1% of carrier power)
Bandwidth that exceeds current channel assignments on both AM and FM frequencies.
Proprietary nature of HD RadioTM‘s CODECs and licensing for second channels give Ibiquity too large a role saying how radio is broadcast in the US. Remember, radio station licenses are granted in the public interest, the owners are trustees of the public
Complete lack of public awareness.
It doesn’t really improve anything anyway.
By the way, shame on NPR (again) for their corporate stance contrary to maintaining good quality radio and serving public interest.
Compared to that, LPFM is a very minor thing. As I said before, removing the third adjacent protection will raise the noise floor in the FM band and by default cause more interference. However, I’ll take a little more interference created by community radio stations over the complete rack and ruin of the FM band.
Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof; or abridging the freedom of speech, or of the press; or the right of the people peaceably to assemble, and to petition the Government for a redress of grievances.
~1st amendment to the United States Constitution
Any society that would give up a little liberty to gain a little security will deserve neither and lose both.
~Benjamin Franklin
...radio was discovered, and not invented, and that these frequencies and principles were always in existence long before man was aware of them. Therefore, no one owns them. They are there as free as sunlight, which is a higher frequency form of the same energy.
~Alan Weiner
Everyone has the right to freedom of opinion and expression; this right includes the freedom to hold opinions without interference and to seek, receive and impart information and ideas through any media and regardless of frontiers
~Universal Declaration Of Human Rights, Article 19
Heard in the clear