LPFM – Page 4 – Engineering Radio

Low Power FM, House passes H.R. 1147

The House passed the “LOCAL COMMUNITY RADIO ACT OF 2009 ” (aka HR 1147) last night in one of the last legislative acts of 2009. This is the companion bill to S. 592, which is still in committee.

The need for LPFM stations is justified thusly:

In part due to consolidation of media ownership, there have been strong financial incentives for some companies to reduce local programming and rely instead on syndicated programming produced for hundreds of stations, though noncommercial educational radio stations, including FM translator stations, currently provide important local service, as do many commercial radio stations. A renewal of commitment to localism–local operations, local research, local management, locally originated programming, local artists, and local news and events–would bolster radio’s service to the public.
Local communities have sought to launch radio stations to meet their local needs. However, due in part to the scarce amount of spectrum available and the high cost of buying and running a large station, many local communities are unable to establish a radio station.
In 2003, the average cost to acquire a commercial radio station was more than $2,500,000.
In January 2000, the Federal Communications Commission authorized a new, affordable community radio service called `low-power FM’, or `LPFM’, to `enhance locally focused community-oriented radio broadcasting’.
Through the creation of LPFM, the Federal Communications Commission sought to `create opportunities for new voices on the airwaves and to allow local groups, including schools, churches, and other community-based organizations, to provide programming responsive to local community needs and interests’.
The Federal Communications Commission made clear that the creation of LPFM would not compromise the integrity of the FM radio band by stating, `We are committed to creating a low-power FM radio service only if it does not cause unacceptable interference to existing radio service.’.
Currently, FM translator stations can operate on the second- and third-adjacent channels to full-power radio stations, up to an effective radiated power of 250 watts, pursuant to part 74 of title 47, Code of Federal Regulations, using the very same transmitters that LPFM stations will use. The Federal Communications Commission based its LPFM rules on the actual performance of these translators, which already operate without undue interference to FM stations.
Small rural broadcasters were particularly concerned about a lengthy and costly LPFM interference complaint process. Therefore, in September 2000, the Federal Communications Commission created a process to address interference complaints regarding LPFM stations on an expedited basis.
In December 2000, Congress delayed the full implementation of LPFM until the Federal Communications Commission commissioned and reviewed an independent engineering study. This action was due to some broadcasters’ concerns that LPFM service would cause interference in the FM radio band.
The Federal Communications Commission granted licenses to over 800 LPFM stations despite the congressional action. These stations are currently on the air and are run by local government agencies, groups promoting arts and education to immigrant and indigenous populations, artists, schools, religious organizations, environmental groups, organizations promoting literacy, and many other civically oriented organizations.
After 2 years and the expenditure of $2,193,343 in taxpayer dollars, the independent engineering study commissioned by the Federal Communications Commission concluded that concerns about interference on third-adjacent channels were unwarranted.
The Federal Communications Commission issued a report to Congress on February 19, 2004, which stated that `Congress should readdress this issue and modify the statute to eliminate the third-adjacent channel distance separation requirement for LPFM stations.’
On November 27, 2007, the Federal Communications Commission again unanimously affirmed LPFM, stating in a news release about the adoption of the Low-Power FM Third Report and Order and Second Notice of Proposed Rulemaking that the Federal Communications Commission recommends `to Congress that it remove the requirement that LPFM stations protect full-power stations operating on third-adjacent channels’. Until the date of enactment of this Act, Congress had not acted upon that recommendation.
Minorities represent almost a third of the population of the United States. However, according to the Federal Communications Commission’s most recent Form 323 data on the race and gender of full-power, commercial broadcast licensees, minorities own only 7 percent of all local television and radio stations. Women represent more than half of the population but own only 6 percent of all local television and radio stations. LPFM stations, while not a solution to the overall inequalities in minority and female broadcast ownership, provide an additional opportunity for underrepresented communities to operate a station and offer local communities a greater diversity of viewpoints and culture.
LPFM stations have proven to be a vital source of information during local or national emergencies. Out of the few stations that were able to stay on the air during Hurricane Katrina, several were LPFM stations. In Bay St. Louis, Mississippi, low-power FM station WQRZ remained on the air during Hurricane Katrina and served as the Emergency Operations Center for Hancock County. After Hurricane Katrina, when thousands of evacuees temporarily housed at the Houston Astrodome were unable to hear over the loudspeakers information about the availability of food and ice, the location of Federal Emergency Management Agency representatives, and the whereabouts of missing loved ones, volunteers handed out thousands of transistor radios and established an LPFM station outside of the Astrodome to broadcast such information.

Similar to S. 592, the bill aims to:

Increase the number of LPFM stations by doing away with the 3rd adjacent protections.
Mitigate interference by creating a 1 year period during which a new LPFM station must broadcast “periodic announcements that alert listeners that interference that they may be experiencing could be the result of the operation of the new low-power FM station on a third-adjacent channel and shall instruct affected listeners to contact the low-power FM station to report any interference.” LPFM licensees are then tasked with solving interference complaints within a licensed full-power FM station’s protected contour.
Protect translator input signals.
Protect reading for the blind services.

I am not finding fault with any of the justifications, they are all true and make a good point about the decline of Radio in general as I have discussed in previous posts.

The potential increase of LPFM stations is in the thousands.

The proposed interference mitigation is a pipe dream. The FCC enforcement bureau is overworked as it is. We have had a pirate on one of our frequencies for years, every once in a while they drive out and bust the guy, only to have him return a week or two later. Somehow this group of overworked people will be able to process hundreds or thousands of interference complaints?

Unless there is increased funding for the FCC enforcement bureau, I am skeptical. There is no specific discussion on funding, only specifying that the cost should be below $139 million.

We live in interesting times.

S. 592: On your mark, get set…

Go!

The Senate seems to have it in its mind to release the LPFM genie from the bottle:

The Senate Commerce Committee unanimously approved a bill (Local Community Radio Act (S. 592)) today that would loosen regulations limiting low-power FM stations. It would abolish the third-adjacent minimum distance separation requirement except for stations that provide a radio reading service, as well as give FM translators and LPFMs equal access to spectrum. The House Commerce Committee has also cleared the bill.

The Local Community Radio Act (S. 592) official bill summary is:

3/12/2009–Introduced.Local Community Radio Act of 2009 – Repeals provisions in the Departments of Commerce, Justice, and State, the Judiciary, and Related Agencies Appropriations Act, 2001 that required the Federal Communications Commission (FCC) to:
(1) modify rules authorizing the operation of low-power FM radio stations to prescribe minimum distance separations for third-adjacent channels;
(2) prohibit applicants who have engaged in the unlicensed operation of any station from obtaining a low-power FM license; and
(3) conduct a program to test whether low-power FM radio stations will result in harmful interference to existing FM radio stations if minimum distance separations for third-adjacent channels are not required. Requires the FCC to modify its rules to eliminate third-adjacent minimum distance separation requirements between specified stations. Requires the FCC to retain rules that provide third-adjacent channel protection for full-power noncommercial FM stations that broadcast radio reading services via a subcarrier frequency from potential low-power FM station interference. Requires the FCC, when licensing FM translator stations, to ensure that:
(1) licenses are available to both FM translator stations and low-power FM stations; and
(2) such decisions are made based on the needs of the local community.

I would add to that list; Must be on the air at least 50% of the time and no more than 50% of that time is automated. Why not? If this is supposed to spur local (community radio) what would be the point of a whole bunch of low-power automated stations? Just more clutter in the FM band.

About community radio

Because of this post, I have received some e-mails asking why I am against community radio. I am not. In fact, I support community radio. I think that community radio done well is a wonderful tool in our democracy, giving a voice to those that are watching the government. It also promotes other locals’ interests, events, music, etc. I would like to see more failing stations bought by community broadcasters and turned into something that is a public trust and responsive to the local population.

What I was trying to get at in the previous post was that overcrowding the FM band with more and more small signals will degrade it. There are no ifs, and, or buts, removing third adjacent protections on the FM band will increase the noise floor. This will lead to more interference on the average FM radio, which will lead to more people getting fed up and tuning out.

Here is why: You cannot change the laws of physics. FM transmitters have output filters that attenuate sideband energy, that is to say, energy transmitted on 1st, 2nd, and 3rd adjacent channels. A 50,000-watt FM station on 100.3 MHz will have sideband energy on 100.1, 99.9, and 99.7 MHz as well as 100.5, 100.7, and 100.9 MHz. Due to the limitations of the components used to construct those filters, they can only be designed with the accuracy of the components used. In other words, most electrical components have a tolerance given in percent, for example, +/- 10%. That means that the value of the component will change, usually because of heating. Therefore, output filters cannot be constructed to limit emissions to only the main channel and say one adjacent channel, they would drift off frequency.

Also, creating a brick wall filter that cuts everything off at the second adjacent channel will cause distortion of the RF signal on the main channel. With analog AM and FM transmitters, it cannot be done. Digital transmissions are another story, but that is not what we are talking about here.

That is an engineer’s point of view.

One other thing about adding hundreds more LP FM signals. There should be something that stipulates most (say >50%) of the programming be locally originated. Recorded for later playback is fine. Having thousands of LP stations broadcasting the same syndicated shows or running voice-tracked automation 24/7 would be a recreation of the AM band as it currently exists. If you want to listen to that, then it already exists, help yourself. I, on the other hand, would like to avoid the AMization of the FM band.

That is all.

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.