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FCC to consider ongoing operation of existing FM6/Franken FMs, Expanded FM Band and Elimination of Reserved Band Protection Requirements

Protected contour at 63 dBu is going the wrong way... most of the rest of the world uses 54 dBu as the standard. We use 60 dBu.
I have ran many models in the past to migrate AM stations to FM. The problem is that no matter what model you do, you can't move them all. There's simply not enough room in the band. This includes both models that keep the full-service TV 5 and 6 (as what REC is going to be proposing) or displacing the 23 or so remaining Ch 5 and 6 stations (with ABC/Disney owning a full-service 6 in a top 10 market, this will be non-starter.

The consensus is that a forced migration should not be a part of the equation. Instead, a different approach to open spectrum for new NCE stations, requiring localism in the first window series and using an allotment system for the first window only to assure that channels are fairly distributed, without the 1st/2nd NCE priority nonsense which has shut out many local groups in the past 2 windows (since the first filing window series would be allotments, all applications would have the same community of license and fair distribution is satisfied through the allotments). After the first filing window series, this band will return to status quo in the legacy band.

But for now, putting in a new band for new local groups, representing our demographics that have substantially changed since the last time there was an NCE opportunity in a major urban or suburban area will bring new opportunities and give people, who want to hear the programming an incentive to purchase a radio. NPR was very correct to suggest NCE stations in this band instead of the forced migration of AMs to this band.
So these stations will not stream? I can't imagine, with thousands of audio sources on the phone everyone carries, anything interesting enough for most people to decide to carry their phone and a Walkman
 
So these stations will not stream? I can't imagine, with thousands of audio sources on the phone everyone carries, anything interesting enough for most people to decide to carry their phone and a Walkman
Those who make the comments like "no one listens to the radio because everyone is using the phones" are usually privilged to not understand that there are many demographics that do not have that privilege. Even with Obamaphones, the data is limited, not enough to regularly listen to streaming stations.

Commercial stations have a commercial incentive to stream. In the NCE sector, if you dig past NPR affilliates and the megachurches, you will find a lot of stations that are not streaming, especially in the LPFM sector. Proably due to the licensing.

There are many that still get their earfull from radio. In Arizona, if you are doing foster care, one of the requirements they have is to own a portable radio with batteries in the event of an emergency. The app on the cellphone will not cut it. Anyone who has been through a natural disaster knows, the phones/cellphones will not always be there.

Since the last time that new stations could be offered in many major cities, there have been substantial demographic shifts and many of those groups are underrepresented on the radio. If a band expansion makes these groups more visible and allows them to have a lifeline, then it's worth it. Going NCE in the expanded band is the right solution.
 
I used 63 dBu on one model to squeeze as many AM to FM station conversions as possible into 2 MHz. With 4 MHz, there would be many more possibilities, spacing and power.

Few Class B stations get de facto protection to 54 dBu anyway, because of grandfathered short spacing and super power, and all the squeeze ins and translators with super HAAT that don't de facto protect Class As and B1s.

I don't think this whole band expansion will fly by just addressing more NCE-FMs and LPFMs, and ignoring AM migration. I'm sure there will be an enormous number of comments though in any NPRM.

Don't get me wrong, I've always thought that expanding the band is the only way to address many concerns. There's so many people pushing and pulling in so many directions, and so many agendas.
 
I used 63 dBu on one model to squeeze as many AM to FM station conversions as possible into 2 MHz. With 4 MHz, there would be many more possibilities, spacing and power.

Few Class B stations get de facto protection to 54 dBu anyway, because of grandfathered short spacing and super power, and all the squeeze ins and translators with super HAAT that don't de facto protect Class As and B1s.

I don't think this whole band expansion will fly by just addressing more NCE-FMs and LPFMs, and ignoring AM migration. I'm sure there will be an enormous number of comments though in any NPRM.

Don't get me wrong, I've always thought that expanding the band is the only way to address many concerns. There's so many people pushing and pulling in so many directions, and so many agendas.
The proposal has provisions for AM translators in the spectrum for those who want to voluntarily go there to run translators. Translators, like LPFM stations there will have to protect the LPTVs that will not be displaced under the plan. We are only proposing full-service (primary) operation on only one "Band" (our reference to each TV channel.. 76.1~81.9 is in Band 5 and 82.1~87.9 is in Band 6). This way, we are not going to displace all of the LPTV stations (only about half of them). If the AM broadcasters want to primary in the band, they need to speak up and so far, they are not interested. They may come eventually and likely, it could eventually result in a displacement of even the primary TV stations (which we are not displacing). When REC releases our full plan to the public, either later this week or next week, it will hopefully explain this better.

Bottom line is that we went into this plan with the following objectives:
  • Use existing mass produced and proven technology (analog FM).
  • Protect all primary TV stations on Channels 5 and 6. (protection rules to address "co-channel" interference protection)
  • No forced migration of stations or listeners. (all new services)
  • A focus on noncommercial service. (full-service will be NCE only on a block of channels within the band)
  • A focus on localism. (first filing window series for local applicants, national applicants allowed in later windows)
  • Avoiding unnecessary displacement of secondary TV services (hence keeping full-service in one band in one place).
  • Preventing the overall loss of the FM6 services (commercial allotment at 87.7 set aside in 13 markets)
  • Technical rules already tried and tested. (use existing analog to digital standards for TV protections)
  • Open the door for new and creative uses for the FM spectrum. (we have a couple of ideas that will be announced)
Also, with this plan, FM translators operating in the expanded spectrum are expected to fully comply with the Local Community Radio Act, specifically section 5 which speaks to translators and LPFMs being "equal in status" and licenses for translators and LPFMs being issued based on "community need".
 
I always envisioned something like the AM Expanded Band for AM to FM migration. Allow a certain number of years to simulcast and then choose one or the other.

Which brings up a question. Did any AM station opt to return to 540-1600 kHz at the end of the simulcast period? The issue is similar, as there were few radios that went up to 1700 kHz. Many already went to about 1660 though. I have a table radio from the late 1930s that covered the "Police Band", 1610 to 1720 kHz, recalling George Carlin's skit about "Wonder WINO, 1750 on the dial". :)
 
I always envisioned something like the AM Expanded Band for AM to FM migration. Allow a certain number of years to simulcast and then choose one or the other.

Which brings up a question. Did any AM station opt to return to 540-1600 kHz at the end of the simulcast period? The issue is similar, as there were few radios that went up to 1700 kHz. Many already went to about 1660 though. I have a table radio from the late 1930s that covered the "Police Band", 1610 to 1720 kHz, recalling George Carlin's skit about "Wonder WINO, 1750 on the dial". :)
A couple of them managed to keep both frequencies, I guess we could count South Bend, where 1620 eventually went off the air while the original 1580 remained. The idea of the X-band was to move a select few stations there and shut off the original frequency.
 
I always envisioned something like the AM Expanded Band for AM to FM migration. Allow a certain number of years to simulcast and then choose one or the other.

Which brings up a question. Did any AM station opt to return to 540-1600 kHz at the end of the simulcast period? The issue is similar, as there were few radios that went up to 1700 kHz. Many already went to about 1660 though. I have a table radio from the late 1930s that covered the "Police Band", 1610 to 1720 kHz, recalling George Carlin's skit about "Wonder WINO, 1750 on the dial". :)
The FCC never followed through on enforcing the completion of the migration. This issue was brought up a few years ago as one of Pai's wishlist items in the AM Revitalization proceedings, but nothing has been heard from it since. That same NPRM also suggested a filing window for new extended band AM stations.
 
The FCC never followed through on enforcing the completion of the migration. This issue was brought up a few years ago as one of Pai's wishlist items in the AM Revitalization proceedings, but nothing has been heard from it since.
And I suspect the reason is that simply nobody cared. That would be the case with the expanded band, AM stereo requirements in the expanded band, and the fact that end of the band never amounted to much. Why go through the process of holding stations accountable for requirements that are irrelevant?
 
1657762897222.png

1970 distance separation requirements in miles for Class A to Class A, for 0 kHz, 200 kHz, 400 kHz, and 600 kHz separations. 5 miles for the 10.6/10.8 separation.

I would hope that proposals would allow mainly contour overlap restrictions to be used for allotments, like 88-92 MHz NCE-FM rules continue to use. But for allotment models, to maximize the number of possible allotments with limited expanded band frequencies, a 3 kW/100 meter two dimensional packing model should be used. The service area from this exceeds the vast majority of 250 watt translators, even the super HAAT translators.

It seems a little late in the game to propose that new expanded band frequencies have 54 dBu protection rather than 60 dBu (1 mV/M), originally the protected contour for ALL classes of FM stations in the United States. Only Class B protection was changed to 54 dBu in the early 1960s, and much later 57 dBu for the new Class B1. Even then, the protection was esoteric, known mostly to engineering consultants and FCC engineers. It was lost in the details of the distance separation requirements, which were a hodge podge of inconsistent government/industry compromise results, which were rounded UP to the next 5 mile increment. Using the FCC FM Propagation utility at FCC.gov, the secrets of the actual distance providing 60 dBu protection for Class A to Class A 3 kW facilities are revealed. It's actually 100 km/62 miles for 0 kHz, 61 km/38 miles for 200 kHz separations. Newer rule makings are more logical and consistent with protected and interfering contours, but remnants like this remain. There are other remnants, despite all the changes.

The NPRM Comments are likely to push in every direction. It will likely be a rocky ride.
 

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Let's not forget how various government agencies are trying to push.....er, encourage....people to buy and drive EVs. Whether that's wise is hotly contested by both sides. But it's relevant here because my understanding is that EVs do not (and will not) come with AM radio because the operation of the vehicle renders all but the strongest signal unusable. And the car is the number one place where radio is consumed.

So, there's that to consider.
 
Let's not forget how various government agencies are trying to push.....er, encourage....people to buy and drive EVs. Whether that's wise is hotly contested by both sides. But it's relevant here because my understanding is that EVs do not (and will not) come with AM radio because the operation of the vehicle renders all but the strongest signal unusable. And the car is the number one place where radio is consumed.
Most of the EVs that do not have AM are European, and that is because the AM band is essentially "gone" over there. Many nations have no AM stations, and others just have some that are running "until the equipment stops working".

The major US car manufacturers have AM in their EVs.
 
View attachment 3286

1970 distance separation requirements in miles for Class A to Class A, for 0 kHz, 200 kHz, 400 kHz, and 600 kHz separations. 5 miles for the 10.6/10.8 separation.

I would hope that proposals would allow mainly contour overlap restrictions to be used for allotments, like 88-92 MHz NCE-FM rules continue to use. But for allotment models, to maximize the number of possible allotments with limited expanded band frequencies, a 3 kW/100 meter two dimensional packing model should be used. The service area from this exceeds the vast majority of 250 watt translators, even the super HAAT translators.

It seems a little late in the game to propose that new expanded band frequencies have 54 dBu protection rather than 60 dBu (1 mV/M), originally the protected contour for ALL classes of FM stations in the United States. Only Class B protection was changed to 54 dBu in the early 1960s, and much later 57 dBu for the new Class B1. Even then, the protection was esoteric, known mostly to engineering consultants and FCC engineers. It was lost in the details of the distance separation requirements, which were a hodge podge of inconsistent government/industry compromise results, which were rounded UP to the next 5 mile increment. Using the FCC FM Propagation utility at FCC.gov, the secrets of the actual distance providing 60 dBu protection for Class A to Class A 3 kW facilities are revealed. It's actually 100 km/62 miles for 0 kHz, 61 km/38 miles for 200 kHz separations. Newer rule makings are more logical and consistent with protected and interfering contours, but remnants like this remain. There are other remnants, despite all the changes.

The NPRM Comments are likely to push in every direction. It will likely be a rocky ride.
The REC plan is allotments only to get a baseline group of stations in the first window series without causing MX chaos (MXs would only be between applications for the same allotment, similar to 2010).. Once the first window series is over, it goes to 73.509 contours just like 88.1~91.9.

60 dBu works well in the reserved band. No need to drop down to 54 for fair distribution purposes.. We will handle fair distrubtion in the first window through the allotments. Also, this means no zones... everything is zone 2. Classes A, C3 and C2. (No C1, C0, C, B1 or B).
 
Most of the EVs that do not have AM are European, and that is because the AM band is essentially "gone" over there. Many nations have no AM stations, and others just have some that are running "until the equipment stops working".

The major US car manufacturers have AM in their EVs.
I believe that Tesla is another. And yes, aside from the UK, AM is essentially empty in northern Europe. I was there last month and you can clearly pick up numerous AM signals from the UK in places like Amsterdam, Brussels and metro Paris because there isn't anything on the band in those countries. But even those are relics, as every one of them (and many are music formats) has a DAB feed that's receivable over much of the nation. AM merely fills in the gaps.
 

All the more reason why AM to FM migration has to be addressed in any Expanded Band proposal. The haphazard way that AM stations are forfeiting their licenses, or making them a small shadow of what they were, low power nondirectional Day and Night, Class D, and selling their land, or compromising their facilities in order to diplex. There are quite a number of 50000 watt stations with just a 250 watt translator, and the stations are pretending that they are FM STATIONS, promoting the FM frequency, and rarely even mentioning the AM frequency. Even 250 watt translators with super HAAT approaching 300 meters are BARELY even the equivalent of a 3000 watt Class A facility, but with a lot more interference, and causing a lot of DE FACTO interference to stations in nearby markets. Many others are simulcasting with "rimshot" Class A facilities, and a few simulcasting Class B facilities 30 or 40 miles away which don't even cover the AM coverage area that well.

There are far too many AM stations just to lose those thousands of audio services without replacement. Most other countries have addressed this, but the FCC's and NAB's obsessive adherence to distance based allotments rather than contour overlap, First Local Service adherence which often precludes stations from serving a greater population, and "rural initiatives", which also could have been addressed years ago with right sized, right ERP/HAAT DA contour based stations, before all the allotments were made in the middle of nowhere where they fit, but with very little population served.
 
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All the more reason why AM to FM migration has to be addressed in any Expanded Band proposal. The haphazard way that AM stations are forfeiting their licenses, or making them a small shadow of what they were, low power nondirectional Day and Night, Class D, and selling their land, or compromising their facilities in order to diplex. There are quite a number of 50000 watt stations with just a 250 watt translator, and the stations are pretending that they are FM STATIONS, promoting the FM frequency, and rarely even mentioning the AM frequency. Even 250 watt translators with super HAAT approaching 300 meters are BARELY even the equivalent of a 3000 watt Class A facility, but with a lot more interference, and causing a lot of interference to stations in nearby markets. Many others are simulcasting with "rimshot" Class A facilities, a few with Class B facilities 30 or 40 miles away which don't even cover the AM coverage area that well.

There are far too many AM stations just to lose those thousands of audio services without replacement.
AM/FM common owners can transition their AMs to HD Radio, which does have a higher penetration right now than WIDE-FM receivers.
 
AM/FM common owners can transition their AMs to HD Radio, which does have a higher penetration right now than WIDE-FM receivers.
FM HD radio is not the answer. With all the limited coverage area and digital artifacts such as sibilance, it just doesn't cut it. How many people are using the FM HD-2 simulcasts of AM stations? Are they showing up much in the ratings?

Like I said, I agree with the FM Expanded Band IN PRINCIPLE, but we've already jammed hundreds of 100-1000 watt stations into the existing NCE band and 100 watt LPFMs into the non reserved band, and I think AM station replacement needs to be a priority in any expanded band.
 
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