fcc – Page 12 – Engineering Radio

What is really wrong with EAS?

Aside from it hasn’t worked… Over the last several, the FCC has released no fewer than five proceedings regarding EAS. To date, few, if any meaningful changes have taken effect. The stated purpose of the Emergency Alert System (EAS) is to:

provide the communications capability to the President to address the American public during a national emergency.
may be used by state and local authorities to deliver important emergency information, such as AMBER alerts and weather information targeted to specific areas.

Seems pretty straightforward. Local weather emergencies would seem to be the most likely reason for EAS activation, followed by things like Amber Alerts, chemical spills, evacuations, etc. To meet those ends, the FCC mandates that radio (traditional and IBOC), television, cable, wireless cable, direct satellite TV, and satellite radio participate in some way or another. So far, it seems like a fair idea. Then comes the implementation, which is flawed. To start with, EAS still relies on a daisy chain relay system designed during the 1960s for CONELRAD. The over-the-air monitor assignments of other broadcast stations are the only mandatory information sources in the system. Other, more relative local sources such as the national weather service, local government, and so forth are optional. Next, the most used and most useful part of the EAS, local and state-level alerts are completely optional. Very little or no information is provided to local government agencies on how to access EAS in the event of an emergency. Then the issue becomes one of unmanned stations. The initial EAS message goes out over the airwaves, which takes about 2 minutes at most, then it’s back to the music. No amplifying information, check back for more information when it becomes available, etc. Nothing. It has occurred in several cases where a radio show is voice tracked, complete with a weather forecast, which is the opposite of real-time weather warnings. If one happens to miss the initial EAS broadcast because they were listening to another station or whatever, well, too bad. Finally, the National Weather Service itself over-activates. One line of summertime thunderstorms passing through the area can trigger 10 or even 20 EAS alerts. Over-activating, with the same digital tones (rrrrrrannk, rrrrrrank, rrrrrank) followed by the EBS tone than some computer-generated voice just gets annoying. To summarize:

The national EAS has never been tested, who knows if it will work
The EAS relies on unreliable over-the-air daisy chain relays for its mandatory monitor assignments
Local and State level EAS (including weather-related alerts, something that could be really useful) is optional
When connected to the NOAA weather radio system, the NWS overuses the EAS activations

Here is an idea: For at least ten years now, the idea of a CAP has been batted around. It seems like a good idea, let’s do that. Get rid of EAS, send emergency information to everyone’s cellphones or whatever, and stop fining broadcasters for missing a monthly test. The weak link in the EAS is the broadcaster’s themselves. History has shown (over and over again) that the current crop of radio station owners cannot be bothered to meet even the simplest of their public obligations. The FCC has shown it is only interested in collecting big fines for missed EAS tests, not actually making the system work. The system is broken. As terrestrial radio (and TV) goes terminal, the public will still need to receive emergency information, the CAP idea can fill this requirement. It is time to pull the plug on EAS once and for all.

I-Buzz

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 its 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 radio^TM 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 than 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 courtesy 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):

The 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 stations 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 meantime, 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 potentially harmful interference, but then the FCC to ignores its own rules and allows another type of 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?

The lights are on, but we’re not home…

FCC fines on broadcasters are nothing new. Broadcasters have often tried to cut corners, hiring incompetent staff that cannot be bothered to report tower light outages, or simply not monitoring tower lights at all. Untrained operators who do not know the EAS rules, sloppy public files, unattended main studios, overpower operation, etc. Some AM stations have power changes at sunset and sunrise, most are now automated but who is checking the automation system to make sure the power changes?

The FCC does not have nearly enough field agents to monitor everything. Most rule infractions never get discovered, like the translator operating at double its licensed power. Or the FM station with the antenna at the wrong height on the tower. It never ends. When I first got into this business, I remember one FCC inspector that was going to issue a NOV (Notice of Violation) because the operator signed her name in red ink. RED INK, by god! It seems things have swung far in the other direction.

Fortunately for us, these infractions become public records, so we can all learn from other’s mistakes, right?

Here is the current crop of FCC fines being shuffled through the bureaucracy:

Clarion County Broadcasting Corp. the licensee of radio station WKQW in Oil City, Pennsylvania, apparently willfully and repeatedly violated Section 73.1745(a) of the Commission’s Rules by operating at times beyond the station’s post-sunset authorization. Clarion is liable for a forfeiture in the amount of four thousand dollars ($4,000.00). To determine whether WKQW was operating consistent with its authorization, an agent from the Philadelphia Office installed radio monitoring equipment in Oil City, Pennsylvania to record, on a continuous basis, the relative signal strength of WKQW’s transmission on the frequency 1120 KHz. The equipment was in place from October 28, 2008 to December 12, 2008.The agent reviewed and analyzed the radio transmission data recorded between October 28, 2008 and December 12, 2008, and found several violations. The agent determined that, between October 28, 2008, and October 30, 2008, the station operated after 8:30 p.m. local time, which is the end of the station’s post-sunset authorization during the month of October. The agent also determined from the recorded radio transmission data that, between November 1, 2008 and November 13, 2008 and between November 15, 2008 and November 25, 2008, the station operated past 7:00 p.m. local time, which is the end of the station’s post sunset authorization during the month of November. In response to an inquiry from Commission staff, the owner of Clarion confirmed that the station’s transmitter did not malfunction during the period between October 28, 2008 and December 12, 2008.

I find it interesting that the FCC has some sort of remote monitoring device that it can install and monitor an AM station’s power levels. I wonder where they installed it. I also have to wonder what it looks like. Is it an outdoor unit, like something one might see attached to a utility pole, or an indoor unit, stashed away in an office somewhere? Very curious, indeed. If I were the station owner, I might ask to see the records that the automated recording device created. That would seem to be a reasonable request.

Caron Broadcasting, Inc. licensee of station WKAT, in North Miami, Florida, apparently willfully and repeatedly violated Sections 73.1745(a) and 73.3526 of the Commission’s Rules by operating at times with power other than those specified in its license and failing to maintain and make available a complete public inspection file. Caron is liable for a forfeiture in the amount of eight thousand dollars ($8,000). We also admonish Caron for the failure of the station’s chief operator to review, sign and date the station logs on a weekly basis as required under Section 73.1870(c)(3) of the Rules.On January, 26, 2009, an agent from the Miami Office monitored WKAT’s transmissions from approximately 5:00 p.m. until 7:00 p.m. The agent made several field strength measurements of the station’s signal and observed no reduction in the transmissions’ field strength after sunset.On January, 27, 2009, an agent from the Miami Office monitored WKAT’s transmissions from approximately 5:25 p.m. until 6:45 p.m. The agent made several field strength measurements of WKAT’s signal and observed no reduction in the transmissions’ field strength after sunset. At 6:43 p.m., the agent made a field strength measurement of the station’s signal one block from the WKAT studio.

On February 5, 2009, at 11:01 a.m., an agent from the Miami Office made a field strength measurement of the station’s signal one block from WKAT’s main studio, which measured approximately the same level as the nighttime measurement that was made there on January 27, again indicating that WKAT was not reducing its power at night. The agent immediately conducted an inspection of WKAT’s main studio with the station’s general manager and designated chief operator. The chief operator stated that the station uses a remote phone monitoring system, which allows the caller to change from day mode (mode “2”) tonight mode (mode “1”). At 11:55 a.m., the chief operator called the transmitter using the remote monitoring system, which indicated that the daytime mode transmitter power was 4,758 watts. At the request of the agent, the chief operator switched the transmitter to nighttime mode, and the system indicated that the power was 316 watts. At 1:45 p.m., with the WKAT transmitter in nighttime mode, the agent made a field strength measurement near the WKAT studio which was much lower than the daytime mode measurement made earlier that day. This measurement confirmed that the station’s transmitter and transmitter remote control system were functioning properly.

Still on February 5, 2009, the agent inspected WKAT’s available daily transmitter logs, which showed that from December 4, 2008 until February 4, 2009, WKAT was not reducing power at night as required by its license. All the log entries made during the daytime and nighttime were in the range of approximately 4,600 to 4,900 watts, and indicated that the transmitter was in mode “2,” the day mode, at all times. The log entries for the early morning hours of February 5, 2009 indicated that WKAT was operating at nighttime power at that time. Neither the station manager nor the chief operator could explain why the power was not being reduced, or why or how the situation was corrected early that morning. The agent also found that none of the station logs were signed by the chief operator or by anyone else. There was apparently no verification of whether or not the station was operating with authorized power, and no initiation of any corrective action for the overpower condition that had been ongoing for several months. The agent also requested to inspect the station’s public inspection file and found that it did not contain the quarterly radio issues/programs lists for the 1st through 4th quarters of 2008. The station manager stated that he did not know where the issues/programs lists were, but that they may be in storage since WKAT moved its studio in August 2008.

They tracked that one down the old-fashioned way, multiple visits at sunset to take field strength meter readings. It seems like no one in this radio group knew anything about FCC requirements and rules. None of this is rocket science, really. These NAL’s are both over a year old. I wonder why it is taking the FCC so long to get through this process.

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.