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FCC Commissioner's Comments on AM

I possted this reply there as well:

Yep...good comments. But keep in mind that Commissioner Pai is only one of five Commissioners, and he represents the minority.

For most of the past 12 years, Commissioner Michael Copps was in a similar position, before retiring earlier this year. He spent most of his time at the FCC giving speeches like this one, saying a lot of things that people outside the Commission agreed with. Copps' problem was getting his fellow Commisioners to agree. He was unable to get proposals passed, even when his party became the majority. Why? Because it required the ability to get others on the commission to agree.

I don't know Commissioner Pai. I see he's from Buffalo. He sounds like a well-minded person. He's only been at the Commision for four months. Time will tell if he's able to get something done.
 
Interesting what people are saying about AM. Commissioner Pai may be on to something, and it's heartening to know he's not writing off AM (and by all appearances, neither are his colleagues on the Commission.)

Actualy, it can still be kept alive and well if it has the programming people want to listen to. (From personal experience--I work for a regional AM signal that's the main NPR affiliate for the region that does well in the Arbitrons in total audience and 35-64 demos, regularly among the top ten in a 30+ station market and higher-rated than any of its FM counterparts statewide.)

What do we need to do? In addition to programming spoken-word content intelligently, we push for the best possible technical standards we can. Forget IBOC, which works well only with the broader spectrum footprint of an FM signal. Instead, let AM stations once again transmit 50-15,000 hZ audio, allow them to at least double their power to cut through the growing amount of electrical noise generated by everything from lighting to computers, use skywave-reducing antennas to cut interference, AND police the band to make sure people actually live within their license parameters. (Too many these days are either staying on day power after dark, staying on the air past licensed signoff time, or going through the fiction of a momentary carrier cut at sunset and going right back to day pattern/power rather than doing a true pattern/power change.)

The power hike will be the most controversial but I think we'd all trade slight additional interference in fringe areas outside our markets, for a better and stronger signal within our target area.
 
- If we *can* develop an anti-skywave antenna design that provides enough attenuation to be worthwhile, that would be a huge breakthrough for AM. It won't help *every* station (for example, 1590 there in the Rochester area must provide *groundwave* protection to at least one station) but it would be a big deal for most.

I'm just not really convinced it's possible. For WXXI-AM, for example, you'd need at least 27dB of skywave suppression to eliminate the need to go directional at night. It is very possible that an effective anti-skywave design may be significantly *larger* than a traditional antenna, causing NIMBY problems. (on the other hand, it might allow a directional station to reduce the number of towers required)

- It would be interesting to see the unexpected side-effects of an across-the-board power increase. What would happen if the FCC sent every AM station a new license authorizing 4x the power on their old license? I suspect fewer than 25% of stations would implement the increase. Many simply couldn't afford the bigger transmitter. Others wouldn't see enough of a return on investment to make it worthwhile. (factor in new antenna-tuning networks and, probably most important, higher utility bills)

But of course, those stations that didn't implement the increase would suffer quite a bit of new interference.

The power increase could have the unexpected benefit of forcing marginal stations out of business, eliminating their contribution to the overall interference background. It would also allow remaining stations to let out their patterns.

- IMHO improved enforcement of sunset signoffs & pattern changes would largely have the same effect: not as much about reducing interference as about driving marginal stations off the air & removing their contribution to interference & coverage limits.

- I'm not that worried about IBOC. It seems to be dying on its own. The full-digital mode tests will return some interesting data but few markets have enough viable AM signals to make a full-digital operation practical.

- The Commission should find a way to hold filing windows more often. (IMHO there should be a filing window for each broadcast service at least once a year, and all applications filed during that window should be processed before the next window opens) When new frequencies open due to stations going dark elsewhere, existing stations shouldn't have to wait 3-4-5 years for the opportunity to file a major change.

The thousands of pending FM translator applications need to be processed promptly. I don't think they should receive any priority over LPFM, but I do think they deserve a prompt decision. Of course, many of these translators can end up relaying AM stations.

Maybe there should be a path to convert these to commercial LPFMs? Maybe if the AM station has a clean record with the FCC and has operated for at least 50 years, it may shut down its AM transmitter & operate only the translator?

- I think we need to be more aggressive about cancelling idle licenses. A station that doesn't operate at least the minimum schedule in the rules for at least 26 weeks a year should lose its license. A station that doesn't operate at least 26 weeks at full authorized facilities should see its license permanently modified for the reduced facilities. If the reduced facilities are below the station's class minimum, it should be reduced in class -- and if those facilities are not licensable (for example, a 50-watt AM daytimer) the license should be cancelled. No more bringing the station back up for a week once a year to retain the license, and no more using 150 watts into a 50-foot longwire for a year.

Apply these requirements to *all* services. It won't cancel nearly as many FM licenses or translators as it cancels AMs, but it will cancel *some*, and that will be spectrum available to reduce the load on 540-1700.

- I don't think there's anything wrong with developing an "RDS" function for AM (to the degree it's technically feasible) nor with developing a means for providing "alternate frequency" information.

Nobody is going to go along with a mandate though.

- As long as we have too many stations too close together, increasing the audio bandwidth, either of stations or of receivers, is going to be counter-productive.
 
w9wi said:
- The Commission should find a way to hold filing windows more often.

The problem with that is the Commission doesn't have enough staff. That's why they lengthened the term for license renewal. Too many licenses, and too few staff. They have tried any excuse they can come up with to increase staff and budget, and Congress says no every time.
 
TheBigA said:
w9wi said:
- The Commission should find a way to hold filing windows more often.

The problem with that is the Commission doesn't have enough staff. That's why they lengthened the term for license renewal. Too many licenses, and too few staff. They have tried any excuse they can come up with to increase staff and budget, and Congress says no every time.

With a larger staff, we'd be looking at substantially higher fees for any of the interactions with the FCC. Most of what was implemented (minor changes, auctions, 73.215, etc..) was to allow the system to be streamlined as much as possible.
 
I don't know Commissioner Pai. I see he's from Buffalo. He sounds like a well-minded person. He's only been at the Commision for four months. Time will tell if he's able to get something done.

Buffalo? http://www.fcc.gov/leadership/ajit-pai Something tells me we're not in Kansas anymore.

All this talk about bringing back AM with 15k response, 4x power increases (stations like WECK go to 4kw, stations like WGR goes to 20kw) and bigger sticks to reduce skywave interference. Sure. To pay for this, owners need only walk to the back yard and pick a bushel full of tens and twenties off the money tree. It borders on delusional.
 
Bob1370 said:
Actualy, it can still be kept alive and well if it has the programming people want to listen to. (From personal experience--I work for a regional AM signal that's the main NPR affiliate for the region that does well in the Arbitrons in total audience and 35-64 demos, regularly among the top ten in a 30+ station market and higher-rated than any of its FM counterparts statewide.)

Bob, I'm not sure where you're getting your data to support your claim that WXXI-AM is rated higher than your FM public radio counterparts in New York. I just ran the Spring 2012 report from the Radio Research Consortium, which tallies Arbitron numbers for subscribing public radio stations. The report shows FM stations in Albany, Oswego-Syracuse and Binghamton have higher shares than WXXI-AM. Your average quarter hour numbers are on par with Albany and higher than Binghamton and Syracuse. But of course, Rochester has a bigger population than these other communities. This is not meant to diminish WXXI-AM's strength in the Rochester. But to proclaim statewide supremacy is simply not true.
 
w9wi said:
- If we *can* develop an anti-skywave antenna design that provides enough attenuation to be worthwhile, that would be a huge breakthrough for AM. It won't help *every* station (for example, 1590 there in the Rochester area must provide *groundwave* protection to at least one station) but it would be a big deal for most.

I'm just not really convinced it's possible. For WXXI-AM, for example, you'd need at least 27dB of skywave suppression to eliminate the need to go directional at night. It is very possible that an effective anti-skywave design may be significantly *larger* than a traditional antenna, causing NIMBY problems. (on the other hand, it might allow a directional station to reduce the number of towers required)

- It would be interesting to see the unexpected side-effects of an across-the-board power increase. What would happen if the FCC sent every AM station a new license authorizing 4x the power on their old license? I suspect fewer than 25% of stations would implement the increase. Many simply couldn't afford the bigger transmitter. Others wouldn't see enough of a return on investment to make it worthwhile. (factor in new antenna-tuning networks and, probably most important, higher utility bills)

But of course, those stations that didn't implement the increase would suffer quite a bit of new interference.

The power increase could have the unexpected benefit of forcing marginal stations out of business, eliminating their contribution to the overall interference background. It would also allow remaining stations to let out their patterns.

- IMHO improved enforcement of sunset signoffs & pattern changes would largely have the same effect: not as much about reducing interference as about driving marginal stations off the air & removing their contribution to interference & coverage limits.

- I'm not that worried about IBOC. It seems to be dying on its own. The full-digital mode tests will return some interesting data but few markets have enough viable AM signals to make a full-digital operation practical.

- The Commission should find a way to hold filing windows more often. (IMHO there should be a filing window for each broadcast service at least once a year, and all applications filed during that window should be processed before the next window opens) When new frequencies open due to stations going dark elsewhere, existing stations shouldn't have to wait 3-4-5 years for the opportunity to file a major change.

The thousands of pending FM translator applications need to be processed promptly. I don't think they should receive any priority over LPFM, but I do think they deserve a prompt decision. Of course, many of these translators can end up relaying AM stations.

Maybe there should be a path to convert these to commercial LPFMs? Maybe if the AM station has a clean record with the FCC and has operated for at least 50 years, it may shut down its AM transmitter & operate only the translator?

- I think we need to be more aggressive about cancelling idle licenses. A station that doesn't operate at least the minimum schedule in the rules for at least 26 weeks a year should lose its license. A station that doesn't operate at least 26 weeks at full authorized facilities should see its license permanently modified for the reduced facilities. If the reduced facilities are below the station's class minimum, it should be reduced in class -- and if those facilities are not licensable (for example, a 50-watt AM daytimer) the license should be cancelled. No more bringing the station back up for a week once a year to retain the license, and no more using 150 watts into a 50-foot longwire for a year.

Apply these requirements to *all* services. It won't cancel nearly as many FM licenses or translators as it cancels AMs, but it will cancel *some*, and that will be spectrum available to reduce the load on 540-1700.

I feel that those AM stations with 'compromised' night time service patterns (i. e. formerly class II-C and II-S) who get an FM translator should be given an incentive for the following: in lieu of shutting down AM operations entirely, be reduced to daytime service only. I say it's time to re-clear the clear channels.

I completely agree with cancelling idle licenses! Either use it or lose it! I also feel that there should be no simulcasting of AM stations whose service patterns overlap more than 50%.

Forgive my digressions, but in Baltimore, Family Stations, Inc. operates two AM stations. One is a (using old-school terms) Class II-D (@ 750), the other a Class II-S (@860). Sometimes when scanning the dial, I'll hear the former simulcast the latter. When they're not doing that I'll hear broadcasts in CHINESE! It would make more sense for 750 to broadcast the previous night's programming on 860, but that's not the case. IMNSHO that is a total waste of a station! While I realize that facility is insignificant in Baltimore, I'm sure there are others who could make better use of that facility!
 
klutch00 said:
I'm sure there are others who could make better use of that facility!

The FCC doesn't make those kinds of judgements. They have received complaints and petitions to deny using that point of view, and all the ones I know of have been denied.
 
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