LPFM – Page 4 – Engineering Radio

Welcome, LPFM 2.0

The FM band is about to get more crowded, courtesy of the legislative branch of the US government. I have been mixed on LPFM based on my own technical experiences. That being said, the FCC seems hell-bent on shoe-horning every possible signal into the FM band, so why not? It certainly won’t be any worse than IBOC or the ever-growing crop of translators. LPFM could possibly bring back local radio to some markets, depending on who gets the licenses and how they are acted on. A local school district around here picked up an LPFM license on the last go around. During the double blizzard of February 2010, they filled the shoes of the two former local stations, which have become remote-controlled repeater stations for a city 35 miles away, so there is a glimmer of possibility.

According to HR 6533, the original channel spacings (elimination of the 3rd adjacent channel protections) in MM Docket No. 99-25 are to be implemented. Additionally, LPFM stations are on the same footing as translators and FM booster stations, which is a slight change from LPFM 1.1

I’d expect to see an NPRM from the FCC rather quickly, as the bill is pretty specific. It may be interesting to see how possible frequencies are identified for LPFM service.

Low Power FM, House passes H.R. 1147

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:

Increase the number of LPFM stations by doing away with the 3rd adjacent protections.
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 within a licensed full-power FM station’s protected contour.
Protect translator input signals.
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.

S. 592: On your mark, get set…

Go!

The Senate seems to have it in its mind to release the LPFM genie from the bottle:

The Senate Commerce Committee unanimously approved a bill (Local Community Radio Act (S. 592)) today that would loosen regulations limiting low-power FM stations. It would abolish the third-adjacent minimum distance separation requirement except for stations that provide a radio reading service, as well as give FM translators and LPFMs equal access to spectrum. The House Commerce Committee has also cleared the bill.

The Local Community Radio Act (S. 592) official bill summary is:

3/12/2009–Introduced.Local Community Radio Act of 2009 – Repeals provisions in the Departments of Commerce, Justice, and State, the Judiciary, and Related Agencies Appropriations Act, 2001 that required the Federal Communications Commission (FCC) to:
(1) modify rules authorizing the operation of low-power FM radio stations to prescribe minimum distance separations for third-adjacent channels;
(2) prohibit applicants who have engaged in the unlicensed operation of any station from obtaining a low-power FM license; and
(3) conduct a program to test whether low-power FM radio stations will result in harmful interference to existing FM radio stations if minimum distance separations for third-adjacent channels are not required. Requires the FCC to modify its rules to eliminate third-adjacent minimum distance separation requirements between specified stations. Requires the FCC to retain rules that provide third-adjacent channel protection for full-power noncommercial FM stations that broadcast radio reading services via a subcarrier frequency from potential low-power FM station interference. Requires the FCC, when licensing FM translator stations, to ensure that:
(1) licenses are available to both FM translator stations and low-power FM stations; and
(2) such decisions are made based on the needs of the local community.

I would add to that list; Must be on the air at least 50% of the time and no more than 50% of that time is automated. Why not? If this is supposed to spur local (community radio) what would be the point of a whole bunch of low-power automated stations? Just more clutter in the FM band.

The lesser of two evils

If I had to pick between allowing HD Radio^TM a 6 dB increase or removing the third adjacent protection for LPFM stations, I’d choose LPFM.

In tests performed by NPR, Ibiquity’s In 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 would like to see -10 dB referenced to the 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 Radio^TM radio requires 400 kHz of spectrum to transmit its 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 bandwidth channels which had been in place since the advent of FM broadcasting in the early 1940s. 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 Radio^TM 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 big radio groups bought in to it (gotcha, crackhead, you’re mine now).

Now, of course, those that bought into HD Radio^TM 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 Radio^TM 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.
The proprietary nature of HD RadioTM’s CODECs and licensing for second channels give Ibiquity too large a role in 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 the 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.