Category: fcc

AM revitalization comments

I have been reading the comments regarding the FCC’s NPRM (13-249).  Clearly, many people are interested in keeping the AM broadcasting band both active and relevant.  Some of these suggestions have merit but are unlikely to be adopted by the FCC.  Others are viable and could alleviate at least a few of the technical shortcomings of the AM band.  The rest fall along expected positions.  Here is a brief rundown:

  • Clear Channel, iBiquity: Allow stations to transmit in all digital mode.  Likelihood: Possible.  The hybrid version of AM HD Radio has been a failure on several fronts; added interference to adjacent channels, self-interference, poor adoption, wonky CODECs, etc.  However, letting stations choose to broadcast in all digital AM HD Radio may decide the issue once and for all.  As long as the all-digital carriers fall within the current analog channels, this would be fine.  Actually, I would add that stations transmitting in all digital be allowed to choose DRM as well as HD Radio
  • REC Networks, MMTC: Move AM stations to former TV channels 5 and 6.  Likelihood: Unlikely.  It would be a neat solution, however, there are currently many full and low-power TV stations still using those frequencies.
  • Clear Channel, SBE, MMTC, Crawford, et al: Allow AM stations a special translator filing window.  Likelihood: Almost assured.  This has been broached by the FCC itself.  I would add that Class D and Class C stations be given priority.
  • SBE, du trial, Lundin and Rackely, MMTC et. al: Remove the “ratchet rule,” reduce antenna efficiency requirements and city of license contour requirements.  Likelihood: probable.  Over the years, the FCC’s rules and regulations designed to help AM broadcasting’s technical product have done the opposite in many cases.  This is especially true of the “ratchet rule.”
  • SBE, du Trial, Lundin and Rackely, MMTC: MDCL (Modulation Depended Carrier Level) Likelihood: Possible.  MDCL does not do much to improve AM signal quality, but it can save the station owner some money on the electricity bill.
  • Alabama Broadcaster’s Association, et al: Better FCC enforcement.  Likelihood: Not very.  This is another area where interference and AM noise problems can be fixed.  Given Ajit Pai’s desire for “non-regulatory” relief, stepped-up enforcement seems to be a non-starter.
  • Hatfield and Dawson: Eliminate substandard AM stations.  Likelihood: Not very.  Getting rid of substandard stations and letting the remaining AM stations enjoy a little breathing room is actually a big step in the right direction.  H&D notes that the FCC should petition congress for tax relief for those stations that choose to surrender their licenses.  Unfortunately, it does not appear likely that the FCC, congress, and the current station owners would go for it.
  • du Treil, Lundin, and Rackely: Do away with skywave protection for class A stations  Likelihood: Possible.  The argument goes; skywave listening represents a very small number of mostly hobbyists (AM DXers) as other, better methods for program distribution exist for serious listeners.  Sad but true.
  • du Treil, Lundin, and Rackely: No more new AM stations.  Likelihood: Possible.  There is a cogent argument to be made regarding the overcrowding of the AM band.  Stopping any further crowding is a good idea.
  • SBE, Cohen, Dippell, and Everist, et al: Tighten regulations on electrical noise emitters.  Likelihood: Unlikely.  The FCC does not have the mettle to tighten regulations against powerful manufacturing and technology lobbies.
  • iBiquity: Do not let anything get in the way of the HD Radio rollout.  Likelihood: Is it possible to get in the way of something that is standing still?

Talking amongst engineers and AM broadcasters, many of these ideas have merit.  The real question is, will any of this bring more listeners?

Pai says “No fighting!”

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

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

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

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

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

Now, SHUT UP AND GET BACK IN LINE

Stay sharp, do not be fooled

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

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

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

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

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

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

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

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

The FCC: Spectrum management in the public interest

Alternative title: Who will really benefit from all digital AM HD Radio™?

Remember when, at license renewal time, radio and TV stations played this announcement:

On (date of the last renewal grant), (station’s call letters) was granted a license by the Federal Communications Commission to serve the public interest as a public trustee until (license expiration date)…

Emphasis mine.

There seems to be a disassociation between those words and the actions of certain broadcasters who view their licenses as a matter of fact and have little regard for the public interest.  The FCC exacerbates the situation with the attitude that everything, including the entire radio frequency spectrum, is for sale to the highest bidder.  John Anderson (DIY Media) has a great article on how big business interests game federal regulators into doing what they want.  This happens in all sectors; banking, agriculture, energy, health care, media, military and so on.   There are many examples of shoddy regulators and big business gone wild over the last ten years to fully prove this theory.  If you don’t believe me, do a little research.  There is no reason to think that the FCC is different from any other federal regulatory agency.

The vast majority of mass media outlets in the US are owned by just six major corporations (see below).  Radio remains the only piece of the mass media system that has not been completely rolled up in consolidation.  Currently, there is a small number corporate radio owners who own a combined ~2,300 stations and one public broadcasting network that accounts for another ~900 stations. I include public radio here because the majority of those station’s upgrades were footed by the taxpayer though grants from the Corporation for Public Broadcasting. That leaves a majority of the approximately 8,500 radio stations that are still owned by a diversified collection of medium and small groups and individuals.

Forcing radio stations to adopt the proprietary, all digital HD Radio™ as the broadcasting standard would, in effect, drive many of those small owners and individuals out of business because of the exorbitant costs for equipment upgrades, antenna modifications, and licensing fees.  This would create a new wave of consolidation as smaller groups and single station owners sold out.  Any remaining small station owners will not have the legal wherewithal to fight against the coming waves of digital interference on both the AM (medium frequency) and FM (VHF) bands.

Therefore, the short answer to the question; who benefits from an all conversion to all digital HD Radio™ is iBquity and its investors, many of whom are found in the list of consolidated media corporations below.  Who looses? Just about everyone else; small and medium group owners, independent radio owners, listeners, communities of license, radio employees, advertisers etc. For those sitting on the fence, thinking “I’ll just do my job any everything will be just fine.”  Full implementation of HD Radio™ will destroy what is left of broadcasting in this country.  Radio is already on shaky ground as a result of product dilution, staff cuts, mediocre programing and competing media systems.  One more step backward, such as adopting a technically flawed digital system that works worse than its analog counterpart, and the remaining listeners may just say “screw this,” and abandon radio altogether.  When the last radio station is turned off, what do you think will happen to your job then?

At the big NAB Las Vegas confab, FCC commissioner Ajit Pai and to a lesser extent, Commissioner Rosenworcel, encouraged people to write or email them with their ideas on how to revitalize AM radio.  I suggest we take advantage of that invitation and tell them what HD Radio™ really is.  There is a shrinking window of opportunity to join the discourse and be heard, now is the time.

Let not any one pacify his conscience by the delusion that he can do no harm if he takes no part, and forms no opinion. Bad men need nothing more to compass their ends, than that good men should look on and do nothing. ~John Stuart Mill

What is at stake?  The future of diversified media and radio broadcasting in the US.

Sidebar: Mass Media Consolidation

Can the public trust a mass media that is owned mostly by six mega corporations to honestly and without bias report news, current events, investigate corruption, and be a government watch dog?  History says no.

Who owns the media?

Time Warner

  • Home Box Office (HBO)
  • Time Inc.
  • Turner Broadcasting System, Inc.
  • Warner Bros. Entertainment Inc.
  • CW Network (partial ownership)
  • TMZ
  • New Line Cinema
  • Time Warner Cable (spun off in 2009)
  • Cinemax
  • Cartoon Network
  • TBS
  • TNT
  • CNN
  • HLN
  • MapQuest
  • Moviefone
  • Castle Rock
  • Sports Illustrated
  • Fortune
  • Marie Claire
  • People Magazine

Walt Disney

  • ABC Television Network (8 stations owned, 200 affiliates)
  • Disney Publishing
  • ESPN Inc.
  • Disney Channel
  • Radio Disney (31 stations, 2 affiliates)
  • SOAPnet
  • A&E
  • Lifetime
  • Buena Vista Home Entertainment
  • Buena Vista Theatrical Productions
  • Buena Vista Records
  • Disney Records
  • Hollywood Records
  • Miramax Films
  • Touchstone Pictures
  • Walt Disney Pictures
  • Pixar Animation Studios
  • Buena Vista Games
  • Hyperion Books

Viacom

  • Paramount Pictures
  • Paramount Home Entertainment
  • Black Entertainment Television (BET)
  • Comedy Central
  • Country Music Television (CMT)
  • Logo
  • MTV
  • MTV Canada
  • MTV2
  • Nick Magazine
  • Nick at Nite
  • Nick Jr.
  • Nickelodeon
  • Noggin
  • Spike TV
  • The Movie Channel
  • TV Land
  • VH1

News Corporation

  • Dow Jones & Company, Inc.
  • Fox Television Stations (25 stations)
  • The New York Post
  • Fox Searchlight Pictures
  • Beliefnet
  • Fox Business Network
  • Fox Kids Europe
  • Fox News Channel
  • Fox News Radio
  • Fox Sports Net
  • Fox Television Network (175 affiliates)
  • FX
  • My Network TV
  • MySpace
  • News Limited News
  • Phoenix InfoNews Channel
  • Phoenix Movies Channel
  • Sky PerfecTV
  • Speed Channel
  • STAR TV India
  • STAR TV Taiwan
  • STAR World
  • Times Higher Education Supplement Magazine
  • Times Literary Supplement Magazine
  • Times of London
  • 20th Century Fox Home Entertainment
  • 20th Century Fox International
  • 20th Century Fox Studios
  • 20th Century Fox Television
  • BSkyB
  • DIRECTV
  • The Wall Street Journal
  • Fox Broadcasting Company
  • Fox Interactive Media
  • FOXTEL
  • HarperCollins Publishers
  • The National Geographic Channel
  • National Rugby League
  • News Interactive
  • News Outdoor
  • Radio Veronica
  • ReganBooks
  • Sky Italia
  • Sky Radio Denmark
  • Sky Radio Germany
  • Sky Radio Netherlands
  • STAR
  • Zondervan

CBS Corporation

  • CBS News
  • CBS Sports
  • CBS Television Network (16 stations owned, 200 affiliates)
  • CNET
  • Showtime
  • TV.com
  • CBS Radio Inc. (130 stations)
  • CBS Consumer Products
  • CBS Outdoor
  • CW Network (50% ownership)
  • Simon & Schuster (Pocket Books, Scribner)

NBC Universal

  • Bravo
  • CNBC
  • NBC News
  • MSNBC
  • NBC Sports
  • NBC Television Network (10 stations owned, 200 affiliates)
  • Oxygen
  • SciFi Magazine
  • Syfy (Sci Fi Channel)
  • Telemundo
  • USA Network
  • Weather Channel
  • Focus Features
  • NBC Universal Television Distribution
  • NBC Universal Television Studio
  • Paxson Communications (partial ownership)
  • Trio
  • Universal Parks & Resorts
  • Universal Pictures
  • Universal Studio Home Video

Large and medium group radio owners:

Bain Capital Partners, LLC Thomas H Lee Partners, LLC

  • Clear Channel Outdoor
  • Clear Channel Broadcasting (800 stations)
  • Premier Radio Networks
  • Radio Computer Services (RCS)

Cumulus Media (public)

  • Cumulus Broadcasting (550 stations)
  • Cumulus networks (formerly ABC Radio networks)
  • Broadcast Software International

Townsquare Media (220 stations)

Entercom (109 stations)

Salem Communications (97 stations)

Saga Communications (88 stations)

Univision (69 radio, 42 television stations)

Radio one (69 stations)

Family Broadcasting (63 stations)

Beasley Broadcast Group (47 stations)

Moody Radio (36 stations)