On June 19th, WKZE received a notice of violation from the FCC’s New York Field office. The crux of the issue seems to be interference being generated on 784.8 MHz (WKZE 8th harmonic) to a new Verizon Wireless installation located nearby:
47 C.F.R. §73.317(a): “FM broadcast stations employing transmitters authorized after January 1, 1960, must maintain the bandwidth occupied by their emissions in accordance with the specification detailed below. FM broadcast stations employing transmitters installed or type accepted before January 1, 1960, must achieve the highest degree of compliance with these specifications practicable with their existing equipment. In either case, should harmful interference to other authorized stations occur, the licensee shall correct the problem promptly or cease operation.” The eighth harmonic of Station WKZE-FM (784.8 MHz) was causing interference to the Verizon Wireless transmitter located approximately 500 feet away.
First off, we note that the WKZE transmitter is not allegedly causing interference to a Verizon Wireless transmitter, but rather to a Verizon Wireless receiver. That may be splitting hairs, however, since the FCC is quoting a technical rules violation, they can at least get the technical language right.
A brief examination of the rest of FCC part 73.317 is in order to find the specification cited in section (a). Section (d) states:
(d) Any emission appearing on a frequency removed from the carrier by more than 600 kHz must be attenuated at least 43 + 10 Log10 (Power, in watts) dB below the level of the unmodulated carrier, or 80 dB, whichever is the lesser attenuation.
Since 784.8 MHz – 98.1 MHz is greater than 600 KHz, this is the section that applies to the WKZE situation. Thus, the interfering signal must be greater than -80 dBc to trigger the Notice Of Violation (NOV) from the FCC. The station ERP is 1,800 watts or +62 dBm. Measurements were made with an Agilent N992A spectrum analyzer using an LPA-1000 log periodic antenna. At a 12-foot distance away from the WKZE transmitter cabinet, the signal on 784.8 MHz was found to be -94 dBc or 0.000063 watts. At the base of the Verizon Wireless tower, the measurement was -124 dBc, or 0.000000025 watt, which is barely perceptible above the -130 dBm noise floor. There does not appear to be any violation of 47 CFR 73.317. Rather, the issue seems to be Verizon Wireless’s deployment of the 700 MHz LTE band and the use of high-gain antennas coupled with high-gain preamplifiers on frequencies that are harmonically related to broadcast stations nearby. In this particular installation, the antenna has 16 dB of gain, minus a 4.5 dB of transmission line loss into a 21 dB preamplifier before the receiver. At the output of the Verizon preamplifier, the signal on 784.8 MHz was measured at -89 dBc, which is still in compliance.
By these measurements, clearly, WKZE is not in violation of any FCC regulation. It makes one wonder, does the FCC understand its own rules? Or, is this a matter of favoritism towards a huge corporation over a small independent radio broadcaster? Is it a matter of “broadband at the expense of all others?” There are several of these broadcast to 700 MHZ LTE interference cases pending throughout the country. This could set a dangerous precedent for broadcasters and other RF spectrum users as wireless giants like Verizon throw their weight around and eye even more spectrum to press into broadband service.
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)
Profile of a successful AM radio station, March 2013: WSBS, Great Barrington, Massachusetts
Great Barrington is either a large village or a medium-sized town with a population of approximately 7,100. There are many listenable FM and AM radio stations from Albany, NY, Pittsfield, Springfield, and Poughkeepsie, NY markets. There are also a few local stations; WBCR-LP, WMAQ (WAMC repeater), and W254AU (WFCR repeater). While the competition is not fierce, citizens have a variety of stations to choose from.
WSBS is a class D AM station on 860 KHz with 2,700 watts daytime power, 250 watts critical hours, and 3.9 watts night time power.
WSBS AM 860 KHz approximate daytime coverage area
This is the approximate daytime coverage area for WSBS AM. I could not find any good coverage maps online, so I made this one myself. When I am driving, I get the station reliably to Kingston, NY, however, indoor listening may be a different matter. With 3.9 watts ERP, nighttime coverage does not include much of the city of license.
They have a translator on 94.1 MHz, W231AK. This is an example of when an FM translator on an AM station is a benefit to the community of license. W231AK has recently been moved from the top of the roof of the Fairview Hospital to the WSBS AM tower. During this move, the ERP was increased from 35 watts to 250 watts and the highly directional antenna was replaced in favor of a 2-bay half wave spaced circularly polarized Shively 6812.
W231AK old service contourW231AK new service contour
Not only did the move increase the translator’s coverage area, it also reduced operating expenses for the radio station, as they no longer have to pay rent or TELCO charges.
WSBS 860 KHz Harris SX2.5 transmitter, courtesy of NECRAT
The main transmitter for the AM station is a Harris SX2.5 . It transmits from a 79-degree tower, the tower and antenna field are well-maintained.
WSBS 860 KHz, Great Barrington, MA tower base and ATU
The studio has a new Audioarts Air4 console, which we just finished installing last December.
The station has an AC music format, which is quite popular. As the FM translator’s coverage has been quite limited until recently and there have been issues with the telephone company circuit taking the translator off the air, the majority of listeners are tuned to the AM signal. There is a live morning show and afternoon show, the rest of the day is voice tracked with music on hard drive. They have frequent contests and give aways. They also do local sports, community events, news and things like live election night coverage. In short, the station serves its community and, as demonstrated by a recent Chamber Business event at the station’s studio, the community appreciates its radio station.
There is nothing magic here; no gimmicks, IBOC, or another technical wizardry. This facility is at best, technically average, albeit well maintained. There is an older Orban Optimod processor, an older AM transmitter, and the original, electrically short tower. The station also has a working emergency generator. The only new tech is the web stream, which all radio stations should have.
The station is successful because of its programming, period. People love local radio. Making connections with listeners imparts a shared sense of community. Being on the air with a local presence during storms, even when the power is out, is a big deal. When it comes to relevance within the community and local businesses; in 2013 all radio stations need to earn that.
Conclusion:
I do not suffer from technophobia; when digital radio was first proposed, I welcomed the idea. It was not until I began looking at the technical proposals and iBiquity’s proprietary system that I became concerned. After hearing the initial implementation of AM HD radio on WOR in NYC, I was not impressed with either it’s audio quality or the side band interference that the analog/digital hybrid AM HD system created. What is of even greater concern is the propensity for government regulatory agencies to rubber stamp technical proposals by lobbying associations without testing or even fact checking.
Digital modulation methods at medium frequencies present a unique challenge where the ratio of the signal bandwidth to available frequency spectrum becomes too great to be practical. This is exacerbated at the lower end of the band where side band symmetry is difficult to achieve at ±15 KHz required by the all digital and the analog/digital hybrid version of AM HD radio.
Clearly, AM radio needs a technical revamping. Can it be saved? Yes. Is it worth saving? Yes. Is a yet unproven proprietary digital modulation scheme the way to do it? No.
Can the AM broadcast service be revitalized and returned to relevancy? If so, how? The previous post demonstrated that AM radio service problems are multigenerational and multifaceted. There is no one solution that will make everything better. Pushing an all-digital solution will not solve electrical noise issues or overcrowding issues on the AM band. It will not address the paucity of the local, unique programming that is the bread and butter of successful AM operators. Because the issues that face AM operators cover many different areas of broadcasting, any proposed solution must address every aspect. Any proposal that simply addresses the poor fidelity, for example, will simply be another band-aid (no pun intended), placed on top of numerous others which have been previously ineffective.
The FCC is looking for deregulatory solutions to the AM problem. Deregulation and the FCC’s lasissez-faire attitude is exactly why the AM broadcast band is in the condition it is today. Relaxed technical standards have allowed the creeping crud to take over like Kudzu. Further deregulation will only exacerbate the problems.
In broad categories, AM radio’s problems are:
Noise and interference
Low fidelity
Lack of ratings
Low profitability
Electrical Noise on AM broadcast band
In order for any solution to be effective, this problem must be addressed first. Noise and interference are at the heart of the technical issues confronting the typical AM radio listener. These problems come from multiple sources, but the worst of which are electrical devices such as CFLs and other fluorescent lights, LED lamps, street lights, utility company wires, computers, computer monitors, TVs, power line communication, appliances, and other intentional emitters. The FCC has, within it current powers, the ability to address at least some of these noise generators. Devices like CFLs, LED lamps, computers, and others are regulated under Part 15 and 18 of the FCC rules. While there is little that can be done with fluorescent lights (they work using an internal electrical arc), other emission standards can be tightened and better, more specific warning labels can be implemented on the packaging.
Station-to-station interference on the AM broadcast band
Another aspect of this problem is mutual interference on the AM broadcast band. In short, too many stations are licensed to a small slice of the electromagnetic spectrum. The increasingly poor condition of many directional antenna systems ensures that there is a cacophony of interference at night. While this is a politically sticky situation, some tough love is needed to solve these problems. There are many underperforming AM stations on the air that are junkyards of last-ditch formats that have little or no hope of success. These stations are often technical disasters that pollute the spectrum with interfering signals. Compounding this issue is the transmission of IBOC at night. The current iteration of IBOC (HD radio) intentionally transmits on adjacent channels creating more problems than it solves.
Confronting any of these issues is almost certain to be a non-starter and that is a shame because real, meaningful steps can be taken here.
One scenario would be a one-time test, applied during the next license renewal cycle, that allows station owners to assess their operations. Those that do not pass the test would be able to surrender their license for a tax credit. This type of culling is not unprecedented, as the FRC did something very similar during the early days of broadcasting when the AM band became a free for all. The test should have three areas of consideration; technical operations, programming, and business profitability. Something like this would be a reasonable example of a re-licensing test:
Technical operations
Test
Points
Does the
license
2
Is antenna array being maintained, field mowed, trees cut, tower fences secure, signage posted, catwalks or access roadways maintained
1
Does station have a working backup transmitter
1
Does station have a working backup STL
1
Does station have a working emergency generator
1
Does station have a current transmitter maintenance log
1
Are NRSC measurements up to date
1
Are monitor points measured at least biannually
1
Minimum score to pass technical operations: 5 points
Programming
Test
Points
Does station originate local programing
1 point per average weekly hour
Does station have local news
1 point per average weekly quarter hour
Does station appear in market ratings survey
1 point per survey period (or 4 points for continuous survey markets)
Minimum score to pass programming test: 5 points
Business
Is the station profitable
¼ point for every profitable quarter during last license period
Minimum score to pass business test: 3.5 points
Minimum overall score for all three tests combined: 16 points
This is a fairly low bar to get over. I generally do not advocated more government regulations and regulatory burden. However, this is one case where relaxed regulations lead to the problems currently being encountered. Perhaps a one time re-regulation would be warranted in the public interest.
Audio quality and other technical improvements
There are several areas where new technology can be used to improve AM stations technical quality. There is a common misconception that AM broadcasting has low fidelity due to inferior bandwidth. Truth be told, AM broadcasting can pass 15-20 KHz audio. It is restricted to less than 10 KHz because of the aforementioned band congestion problems. Since the NAB and the FCC has made exceptions to the NRSC-1 requirement in order to transmit HD radio, perhaps other wide bandwidth uses can be considered. One possibility would be to allow transmission of 15 KHz audio during daytime hours, switching back to NRSC-1 standard after dark. This may not work on local (class C) channels but for regional and what remains of cleared channels, it may offer some improvement. Also, turning off IBOC hybrid analog/digital transmissions after dark should be examined regardless of whether an all digital solution is sought. Hybrid IBOC is a part of the night time noise problem and not a viable solution, particularly troublesome are class A skywave signals.
Also, much benefit could be derived from requiring that all AM stations sync their carriers to GPS. If all of the stations on the same channel are on exactly the same frequency, it will eliminate carrier squeals, growls and whines. This is something that can be done very easily and inexpensively, especially with newer transmitters.
Double sideband AM is wasteful, as both lower and upper sidebands contain the same information. Suppressing the lower sideband and transmitting just the carrier and upper sideband would free up quite a bid of bandwidth and reduce adjacent channel interference. Most simple diode detectors demodulate the upper sideband anyway.
A concerted effort must be made to restore all of the technically deficient antenna systems. Not only fixing out of tolerance DAs but also addressing bandwidth issues, general maintenance, ground systems, clearing away brush and undergrowth can all have noticeable positive effects on signal performance.
At the same time, better receivers are making their way into the market place. Receivers that have auto variable IF bandwidth based on signal strength could greatly improve audio quality. The auto bandwidth function could be overridden by user selected bandwidth, if desired. I know that wider IF bandwidths are in the current chipset because of IBOC and DRM, I do not know to what extent they can be adjusted, but it is something that receiver manufactures should consider.
None of these solutions are Earth shattering, nor would they require great sums of money to implement.
AM to FM Translators
The current thought process is that using FM translators for AM stations is a fantastically great development. For a class D AM station with little or no night time power, an FM translator is a good way to maintain service to the community. For class C or some class B AM stations where night time interference greatly degrades the station’s service area, an FM translator is a good way to maintain service to the community. Does a 50 KW blow torch really need a 250 watt (or less) FM translator to aide with reception in its city of license? No. Yet, this is how the AM to FM translator service will be rolled out, those that already have sound technical operations will be given FM authorizations. This does nothing to actually fix AM broadcasting technical issues, it is a well meaning measure that will be incorrectly applied by the broadcasters that need it least.
Programming
All of the technology and gadgets will not solve the problem of poor programming. This is an area where the FCC should not tread, however, broadcasting associations can assist their members with local programming issues. Broadcasters need to understand that good local programming that is unique will attract listeners, worthless junk will not.
