The lesser of two evils

If I had to pick between allowing HD RadioTM 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 RadioTM 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 RadioTM 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 RadioTM 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 RadioTM radio are:

  1. Inadequate building penetration at the current power level (1% of carrier power)
  2. Bandwidth that exceeds current channel assignments on both AM and FM frequencies.
  3. 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
  4. Complete lack of public awareness.
  5. 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.

Local Community Radio Act (HR 1147/S 592)

I sent off a letter to my Senators and Congressman this morning regarding HR 1147/S 592 AKA Local Community Radio Act.  Basically, I am against this.  Not that I don’t appreciate what it is trying to accomplish.  I believe the technical degradation of the FM band is a higher concern.  After all, if we turn the FM band into what the AM band has become, nobody will listen to the radio.

Radio is too important to ruin.  Here is what I wrote:

I strongly urge you NOT to support the bipartisan Local Community Radio Act (HR 1147/ S. 592) sponsored by Reps. Mike Doyle and Lee Terry and Sens. Maria Cantwell and John McCain.

In spite of what many have said, Low Power FM (LPFM) contributes to the technical degradation of the FM service.  By adding more and more signals covering every possible spot in the FM spectrum, the noise floor is raised causing many FM receivers to “picket fence” which is annoying to most listeners.

Radio has suffered enough degradation over the last few decades.  AM radio is now so fraught with interference, especially at night, most people do not even consider listening to it.  Packing the FM dial with thousands of low power operators will create the same problems and cause most people to abandon radio altogether.

I am a strong proponent of 1st amendment rights.  I believe the sponsors of this bill are well intentioned, however misinformed. I believe that the deregulation of commercial radio allowing one company to own 1,200 radio licenses has created most of the problems we see today.

Clear Channel, in particular, has removed almost all localism from radio, creating bland canned music channels.  Their modus operandi was to buy a group of radio stations in a market, combine the stations under one roof, get rid of most of the staff, and drop the advertising rates so other local stations could not compete.  Non-Clear Channel stations were then forced to make cuts in there advertising rates and or expenses to stay in business.

The answer is not to create a bigger mess.  Instead:

1.  Push the FCC to tighten ownership rules.  In some ways the horse is already out of the barn, but it would prevent another Clear Channel from forming in the future.
2.  If major radio groups go bankrupt and are broken up, allow it to happen, do not intervene.  This will allow real radio broadcasters to pick up the pieces and put something together.  Perhaps investigate supporting small radio owners by waiving FCC fees and limited tax breaks for a period of time.
3.  Push the FCC to continue with the localism hearings they were conducting.
4.  Push the FCC to update the EAS and make a workable Emergency Alert System in the US.

Radio is too important a resource to have it ruined.  Of all the media outlets, radio is the most robust.  During an emergency often times the utility grid is down.  Many radio stations have backup power generators and can provide vital information when the internet, phone system, cable TV network, cellphone system, e-mail, etc are down.

Radio can provide local government important mass access to their constituents during elections and at other important times.  Radio is free, there are no subscription fees, no service providers, etc.  Almost everyone owns a radio, most people own several.

Small savvy radio owners can make a go of it, provided the deck is not stacked against them.

Please DO NOT support the Local Community Radio Act. Thank you.

If you want to get involved, you can go to the Free Press website, there you will find a link to a “Take Action” page (not sure that link will work).  Again, I am not opposed to Free Press or even Free Radio.  Packing the FM spectrum with LPFM, translators and the like will only create reception problems.  This is just become another reason for people not to listen to radio.

EAS

Emergency warning siren station
Emergency warning siren station

EAS, or more properly, the Emergency Alert System, is a government-mandated system of encoders and decoders designed by the federal government to alert the public in case of war or other emergency.  It and its predecessor, EBS (Emergency Broadcast System) have never been activated by the federal government.  Both systems, however, are used extensively by local and state governments for things like weather alerts, amber alerts, etc.

Back in the mid-90s the FCC had a chance to redo the EBS and produce something that was a streamlined and effective tool for public warning.  Unfortunately, the EAS system is neither.  Rather, it is a cumbersome system of weekly and monthly tests scheduled around pre-conceived notions that how the system is tested every week will be how the system works in an emergency.  In practice, this is generally a good theory of system design, but it has failed miserably with EAS.  The reasons why are thus:

  • Most all emergencies are local or at most state-wide events.  To this day, very few state and or local government emergency managers would be able to activate EAS for their area.  The reason is there is minimal if any interface with the LP-1 EAS stations or station personnel.  Ignorance and apathy on behalf of both radio station personnel and government officials is the main culprit.
  • Most stations are un-maned for large portions of the day.  Even if government officials could/did call the station, chances are, nobody would be there.  If by chance, arrangements were made to contact station employees at home, they would have to interface with the EAS equipment remotely, which adds complexity to an already complex system.
  • EAS messages are still mainly relayed from radio station to radio station, the so-called daisy chain network that has been shown numerous times to be unreliable.
  • The system of SAME codes, FIPS identifiers is not necessarily bad, the application in this case leaves something to be desired.  The FCC had a chance to update EAS before the HDTV rollout.  One would assume that any improvements could have been built into the new TV sets that are now being sold, but again, that opportunity was missed.  For example, I suggested that each TV have a set-up screen option where the owner could input their zip code.  They could also choose what types of alerts they would want to know about and even base the alerts types on the time of day.  Live in a flood zone, the FFW (Flash Flood Warning) 24/7.  Live in tornado alley, TOR (Tornado Warning), etc.  The cable companies then pipe in the local NOAA all hazards radio station.  All the sudden there is a real national alert system in place using mostly non-broadcast wireless systems.  Add to that the ability to sign up for emergency e-mails and text messages for specific areas (many places are currently doing this) and there is multiple message paths.

The system as is not reliable and sooner or later that will be shown with a large-scale failure.  Recently, the FCC held a summit with the Department of Homeland Security.  The cliff notes version of this event is: Yes, the system can be made better.  Let’s keep throwing the same ideas at the wall and see if anything sticks this time.  Excuse me if I don’t do back flips, this is the same information that was discussed during the last “let’s revamp EAS” discussion back in 2005 (04-296).

In the meantime, the EAS continues to be a good fundraiser for the FCC enforcement bureau.  Which, you know, it is easier to go to a licensed radio station and bust them for not re-transmitting the RMT (Required Monthly Test) than it is to go out and bust some of the numerous pirate radio operators, some of whom are operating in the same city/metropolitan area as a field office.

The shame of it is, it could work without a great deal of cost, very well.

The FCC is studying the state of Journalism

The FCC has drafted a Notification of Inquiry (NOI) examining the state of media journalism in America. Why?  No harm can come from this, right?  Let us read a little further:

A major issue the report details is the possibility of “behavioral rules” for broadcasters, according to the official. Behavioral rules might include guidelines that broadcasts serve the public interest.

Bringing back Cold War-era guidelines mandating that broadcasters do “non-entertainment” programming is another idea being examined, according to the official.

From CNSNews.com

Doh! Now that most radio stations have fired their news departments, the government wants news.  Frankly, I think it is a dumb idea.  The hands of time can’t be turned back so there is no use trying.

There are radio stations out there that provide good local and national news, most NPR stations for example.  There are also a few commercial stations still doing it.  Those that can make money on it will and that is the way it should be.

I listen to the local NPR station’s (WAMC) program called “The Media Project.”  It is an interesting show where a Television news anchor, a local newspaper editor and the radio station president talk about media issues.  Often, it turns into a lament about how the internet news sources are cutting into their own audience because the internet is “free.”  The newspaper editor in particular often feels that he is shouldering the burden (by paying the reporter’s salaries) of gathering the news and the free-loading internet people who write blogs, like this one, merely leach off of the newspaper’s hard work.  And he has a point.

So charge for it.  I’d pay a $3-5 per month fee to have full online access to a good local paper.  I think many other people would too.  When they started giving away their content is when they got into trouble and that is their own fault.  This would be a good formula:

  1. Media outlets (newspapers, TV stations, Radio stations, Cable companies, etc) get together to come up with a policy for online content.
  2. A good example would be, limited free access to national stories and front page items and advertisements.  Charge a nominal subscription fee for locally generated content and full access.  Charge a higher fee for content without advertising (except classifieds).
  3. Create a website that is laid out like a newspaper.  Keep all the sections the same and make it very easy to navigate around in.

Some newspapers, like the New York Times, are already doing things like this.  The reality is that online media is here to stay.  Those legacy media outlets that want to survive are going to have to figure out a way to compete and make money online.