MMTC Radio Rescue, sort of like the Patriot Act – For Radio

I read with interest the MMTC’s (Minority Media Telecommunication Council) ideas for rescuing radio.  In the summary, they make the statement:

By granting this Radio Rescue Plan quickly, the FCC can provide lenders and investors with assurance that the federal government stands behind the survival and sustainability of this industry that is so vital to public service, public safety, minority entrepreneurship and democracy

Red flag.  Anytime some groups want to rush something through because of some perceived crisis, it should be closely examined for potential conflicts of interest.

It is fine to look into the rules and make changes as technology evolves, rushing some change through because the economy has gone south is not the best plan.  If radio is in such bad shape that it needs a rules relaxation to survive, that indicates there is something seriously wrong with the underlying structure.  No amount of rules changing is going to help that.

Anyway, they lay out some ideas, most of which have been batted about before and have had little of the intended affects.

  1. Re-purpose TV channel 5 and 6 to the FM broadcast band.  Allow AM station to migrate there with a priority given to relieve interference issues on the AM band.
  2. Night time AM signal contour rules, relax requirement to cover 80 percent of city of license at night.
  3. Modify or eliminate principle community coverage rules
  4. Replace minimum efficiency standards for AM antenna systems with “minimum radiation standards”
  5. Allow FM applicants to specify Class C, C0, C1, (etc) in zone I and IA.
  6. Delete non-viable FM allotments from the table of allotments.

1.  The first idea is to re-purpose TV channel 5 and 6 to the FM band.  This would allow more FM stations to exist and presumably many AM station to migrate to the FM band.  Sort of like the expanded AM band project in the 1990s where AM stations moved to the 1600-1700 khz range and then turned in their old licenses in the 540-1600 khz range to reduce interference.  Worked out well except for the last part, almost no AM station that moved into the expanded band has ever turned in it’s original license.  I doubt that they would in an AM to FM band migration.

Perhaps using this expanded FM band to move all of the NCE stations from the commercial channels and allow for LPFM’s to proliferate would be a good idea.

Then there is the problem of what to do with the various LPTV-6 stations that are still around.

I doubt the FCC will go for this because they can make too much money auctioning off the spectrum in one whole chunk to the highest bidder.

2.  Night time AM coverage rules.  The proposal is to allow a relaxing of the night time AM coverage rules over the city of license.   Currently required to cover 80 percent of the area or population except in the expanded band, where the requirement is 50 percent.  Making it all one uniform standard (50%) would make the most sense.  Not that it would make a lot of difference listener wise, still, it might ease the burden on some AM station that would otherwise be solvent.

3.  Modify or eliminate principle community coverage contours.  This idea  just seems like a way to satisfy more big radio consolidators and have more stations move out of their communities of license, which they are supposed to be serving.  This is the money statement:

MTCC believes that modification fo these rules benefit small, women, minority, and all broadcasting licesnses by providing them with additional flexibility for site location

How?  I still cannot fathom how this will benefit those groups mentioned above, seems like a generic statement with no merit.

The rim shot signals which are at least providing some type of radio programming to rural areas would cease to exist as they would all pick up and move toward population centers.  This is a bad idea.  The owners who bought rim shots should have known they were buying rim shots in the first place and not be expecting too much in the way of moving things around to accommodate their idea of what the FM broadcast band should be.

4.  Replace minimum efficiency standards with a minimum radiation standard for AM antenna systems.   The proposal states that when those standards were adopted, land was plentiful and electricity was not.  I would comment that neither land nor electricity is plentiful today.  Reducing this standard would open up potential AM station buyers to risk of investing in a bigger money pit than what AM radio currently is today.

In other words, it is a bad idea which would only cause potential owners to be saddled with huge electric bills and hasten the end of AM radio.  As an engineer, I know that with the right amount of capacitance and inductance, I can load up an AM transmitter to a chain link fence.  That doesn’t mean it is a good idea.

5.  Allow FM applicants to specify class C, C0, C1, C2, C3, (etc) in zone I and IA.  I presume they mean to allow a class B to specify class C2 and a class B1 to specify a class C3.  This might make the application process a little more uniform, but I doubt it would make much difference in the FM band.

Also, they seem to use the term “spectrum warehousing” often.  What does that mean?  They make an elusion to the difference between a 54 dBu and a 60 dBu contour.  Is that 6 dBu a “spectrum warehouse?” It is really nonsensical, sort of like “precious bodily fluids” in Dr. Strangelove.

6.  Non-viable FM allotments.  Sure, delete them or re-align them so that they might be usable to someone.  Makes sense.

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 has would like to see -10 dB referenced to 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 it’s 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 1940’s.  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. Proprietary nature of HD RadioTM‘s CODECs and licensing for second channels give Ibiquity too large a role 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 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 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 the 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.


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 it’s 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-90’s 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 official 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 ads complexity to an already complex system.
  • EAS messages are still mainly relayed from radio station to radio station, the so called daisy chain net work 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 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 “lets revamp EAS” discussion back in 2005 (04-296).

In the mean time, the EAS continues to be a good fund raiser 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.