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FCC Comment Sought on HD Radio Power Increase

Here is something to think about. HD radio on FM in its current implementation has already done significant damage to the coverage area of existing stations on adjacent channels. My personal example is the loss of coverage for WQXR 96.3 N.Y. in Monmouth County New Jersey due to interference from HD WRAT 95.9.
I am a broadcast engineer for a group of radio stations who listened to WQXR on my way to work. When WRAT added their HD signal, my automobile reception of WQXR became unlistenable. I am within the published service contour of WQXR yet I am a listener that WQXR lost due to interference. Now think about what would happen if this interfering HD station be allowed to raise the injection level of the HD. It would push the interference deeper into the service contour of WQXR. That means more listeners lost.
 
Eng.Mike did proclaim:

Here is something to think about. HD radio on FM in its current implementation has already done significant damage to the coverage area of existing stations on adjacent channels. My personal example is the loss of coverage for WQXR 96.3 N.Y. in Monmouth County New Jersey due to interference from HD WRAT 95.9.
I am a broadcast engineer for a group of radio stations who listened to WQXR on my way to work. When WRAT added their HD signal, my automobile reception of WQXR became unlistenable. I am within the published service contour of WQXR yet I am a listener that WQXR lost due to interference. Now think about what would happen if this interfering HD station be allowed to raise the injection level of the HD. It would push the interference deeper into the service contour of WQXR. That means more listeners lost.

Thank you for posting in this topic Eng.Mike! For the last year or so I have been asking for the radio engineering types in the trenches (the folks who do the actual hands-on work) to do more posting in this thread but realize if their opinions differ from their employers' support of HD radio technology then they are effectively muzzled. Thank you for speaking out about your own experiences.
 
Carmine5 said:
Time to sharpen up those talking points. We have until 10/28 to make it known how we feel about the 10 db power increase.

http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-08-2340A1.pdf

http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-08-2340A1.txt

C5

Yeah - right - they never did send me the form. I think they ignored people, put off sending the forms, made the comment period short - so that they could SILENCE any dissenting opinion. Another rubber stamp for iBiquity, and it will re-make the FM band in the image of AM.
 
Yeah - right - they never did send me the form. I think they ignored people, put off sending the forms, made the comment period short - so that they could SILENCE any dissenting opinion. Another rubber stamp for iBiquity, and it will re-make the FM band in the image of AM.

Didn't need a form...
Wrote it in Word
converted to a PDF
attached it to the online ECFS cover page just like attaching any CDBS filing

Only only took an hour of my time from start to filed.
 
rbrucecarter5 said:
Carmine5 said:
Time to sharpen up those talking points. We have until 10/28 to make it known how we feel about the 10 db power increase.

http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-08-2340A1.pdf

http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-08-2340A1.txt

C5

Yeah - right - they never did send me the form. I think they ignored people, put off sending the forms, made the comment period short - so that they could SILENCE any dissenting opinion. Another rubber stamp for iBiquity, and it will re-make the FM band in the image of AM.

I'm sorry. I typed in 10/28 when it should be 11/28. Still, a month is not as much time for comments as the FCC has allotted for other petitions.

Obviously, they want to fast track a decision on this matter. And given their recent favorable response for using unlicensed devices in white spaces, I think it's safe to assume that the Commission will approve the power increase.

C5
 
Prometheus Radio Project has made their comments to the FCC on the power increase available for reading.

http://prometheusradio.org/media/DAB_power_increase.pdf

One point of interest is the impact the increase would have on translators:

"..none of the parties’ testing has considered the impact of digital signals on low power stations...it is likely that a 100 watt LPFM station (or translator) will be located on one of the adjacent channels to a large Class C station which is broadcasting with as much as 100,000 watts analog...based on iBiquity’s test results from short spaced and super power B stations, there will likely be many circumstances where the relative field strengths of LPFMs (and translators) within their small coverage areas will be overwhelmed by the digital signal."

So even if commercial broadcasters and the NPR have little sympathy for LPFM's, the power increase could have a detrimental effect on their own translators. Oops!

C5
 
Carmine5 said:
rbrucecarter5 said:
Yeah - right - they never did send me the form. I think they ignored people, put off sending the forms, made the comment period short - so that they could SILENCE any dissenting opinion.
... a month is not as much time for comments as the FCC has allotted for other petitions. Obviously, they want to fast track a decision on this matter. And given their recent favorable response for using unlicensed devices in white spaces, I think it's safe to assume that the Commission will approve the power increase.

Please let me try to disabuse you of several misconceptions.

First, the comment period is still open. The deadline for comments, which should have concerned points raised in the Notice, was December 5. The deadline for reply comments, which should be responsive to what was said in the comments, is January 12, 2009. You can add your reasoned agreement or disagreement.

Second, comments are not a public opinion poll. If all you want to say is that you agree or disagree with something, you're free to do so but it will have very little weight. Comments (and reply comments) are primarily a means to gather information so that the agency has a basis for a good decision. You contribute the most value by providing facts (authenticated, please) and logic.

Third, no "form" is required. You submit comments via the web to the Electronic Comment Filing System (ECFS). The ECFS has a dual purpose: it collects comments from the public, and it allows you to read comments already filed. In fact, the ECFS contains the history of items on the rulemaking docket -- not only comments, but notices, motions, ex parte presentations, and decisions as well.

There are two ways to file comments in the ECFS. The simpler method, used primarily by people who just want to give an opinion, is ECFS Express, at http://fjallfoss.fcc.gov/ecfs/Upload/. The ways the pros do it is to create a document using their normal word processor, and upload it. ECFS (http://www.fcc.gov/cgb/ecfs/) will accept filings in the following formats: MS Word 6.0 and higher, MS Excel 4.0 and higher, Word Perfect 5.1 and higher, ASCII Text, and Adobe Acrobat Portable Document Format (PDF). For more information, please refer to the online User Manual at http://www.fcc.gov/cgb/ecfs/ecfsmanual.html. (I personally recommend converting to PDF to avoid font problems, to make the document readable by the most people, and to ensure that you aren't uploaded deleted text that Word files may keep around.) The link to upload is http://fjallfoss.fcc.gov/prod/ecfs/upload_v2.cgi.

Since we are in the reply comment phase now for the power increase proposal, you should be responsive to the comments already filed. To see what they are, go to http://fjallfoss.fcc.gov/prod/ecfs/comsrch_v2.cgi, enter 99-325 in Box 1, and click on "Retrieve Document List." Since the documents are in reverse chronological order, the ones appearing first concern the most recent matter, the power increase proposal. (You don't have to go back further than October 2008.) (If you want to see how reply comments respond to comments, look at Proceeding 08-172, which just closed for reply comments. This was the one about possibly mandating IBOC and SDARS features on the same receivers.)

Finally, if you read the comments, you'll see that the center of gravity is against approving a blanket 10 db increase in subcarrier power. Several leading comments refer to ongoing negotiations that would lead to a subsequent, more parameterized proposal. (Your reply comments may include your own analysis of the consensus of the comments.)

- Jonathan
 
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