S.2881 – FCC Commissioners’ Technical Resource Enhancement Act

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 whatever 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.

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 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 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…

fcclogowords

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.