FCC violated 47 CFR 73.207, 73.211 and 73.215 in approving HD-FM

[radioskeptic]

Another thread on this board, “FCC violated 47 CFR Section 73.44(b) in approving HD-AM,” dealt with the FCC’s failure to follow its own rules when it approved Ibiquity’s digital system for the AM band. But let’s look at the problems with the FM version of “HD.”.

“The minimum ERP for Class A stations is 0.1 kW,” according to 47 CFR 73.211. The “HD Radio” ad campaign is fond of calling HD-2 signals “the stations between the stations,” but that term would be better applied to the the primary Ibiquity signals, which are on side channels that are actually half of each first-adjacent channel. It’s important to emphasize here that these signals are NOT an integral part of the “host” analog FM signal.

Each of the side channels is 23 dB below the level of the analog signal. The side channels may or may not share the same antenna. They frequently can NOT share the same transmitter finals, because many Class C finals can’t faithfully pass the amplitude variations that result from adding those unrelated side signals to the constant-amplitude analog FM signal.

In short, by most conventional definitions they should be considered two additional, albeit much lower-powered, stations, even when they’re multiplexed on the same antenna.

And at 250 watts (23 dB below 50 kw), each Ibiquity side channel on a full-powered Class B FM station clearly meets the definition of a Class A station. (73.211 also says, “Class A stations may have an ERP less than 100 watts provided that the reference distance … equals or exceeds 6 kilometers,” so the same power adjustment for height applies to the digital side channels.)

Most New York Class B stations have Class B first-adjacents in Philadelphia. Consequently, each of those NY stations has one of its side channels effectively acting as a Class A co-channel for a Class B in Philadelphia, and vice versa.

The distance by air – or “as the crow flies,” if you prefer – from the Roxborough section of Philadelphia (home of the “antenna farm”) to the Empire State Building in New York is a bit short of the 89-mile requirement in the FCC’s short-space table (73.215) – and far short of the 111-mile requirement in the regular spacing table (73.207) – for Class A and B co-channel pairs.

How could the FCC let this debacle happen?

(For reference, you can find anything in Title 47 of the Code of Federal Regulations, or "47 CFR" for short, at this link: http://www.fcc.gov/mb/audio/bickel/amfmrule.html, either as text or as a PDF.)

 

[R.F. Burns]

Another thread on this board, “FCC violated 47 CFR Section 73.44(b) in approving HD-AM,” dealt with the FCC’s failure to follow its own rules when it approved Ibiquity’s digital system for the AM band. But let’s look at the problems with the FM version of “HD.”.

“The minimum ERP for Class A stations is 0.1 kW,” according to 47 CFR 73.211. The “HD Radio” ad campaign is fond of calling HD-2 signals “the stations between the stations,” but that term would be better applied to the the primary Ibiquity signals, which are on side channels that are actually half of each first-adjacent channel. It’s important to emphasize here that these signals are NOT an integral part of the “host” analog FM signal.

Each of the side channels is 23 dB below the level of the analog signal. The side channels may or may not share the same antenna. They frequently can NOT share the same transmitter finals, because many Class C finals can’t faithfully pass the amplitude variations that result from adding those unrelated side signals to the constant-amplitude analog FM signal.

In short, by most conventional definitions they should be considered two additional, albeit much lower-powered, stations, even when they’re multiplexed on the same antenna.

And at 250 watts (23 dB below 50 kw), each Ibiquity side channel on a full-powered Class B FM station clearly meets the definition of a Class A station. (73.211 also says, “Class A stations may have an ERP less than 100 watts provided that the reference distance … equals or exceeds 6 kilometers,” so the same power adjustment for height applies to the digital side channels.)

Most New York Class B stations have Class B first-adjacents in Philadelphia. Consequently, each of those NY stations has one of its side channels effectively acting as a Class A co-channel for a Class B in Philadelphia, and vice versa.

The distance by air – or “as the crow flies,” if you prefer – from the Roxborough section of Philadelphia (home of the “antenna farm”) to the Empire State Building in New York is a bit short of the 89-mile requirement in the FCC’s short-space table (73.215) – and far short of the 111-mile requirement in the regular spacing table (73.207) – for Class A and B co-channel pairs.

How could the FCC let this debacle happen?

(For reference, you can find anything in Title 47 of the Code of Federal Regulations, or "47 CFR" for short, at this link: http://www.fcc.gov/mb/audio/bickel/amfmrule.html, either as text or as a PDF.)

My goodness and you know about the two 101.1's? One in Philly and one in NY, how have they been able to survive all these years? We're do you live that you recieve 101.1 & 101.3? Say what you will. I live north of Manhattan and get a full quieting signal on WKXW 101.5. That's between 2 IBOC stations on 101.1 & 101.9. I must have a magical setup to receive that with no interference. I'm not makning this up, which some have chosen to ignore, because it doesn't fit their preconceived notions. I guess what will have to happen is that these stations making claims of interference will have to go out and take field readings to prove their statements. So far all I see are theoretical comments but no provable proof. The one station that filed a complaint was found to be completely wrong.

 

[radioskeptic]

Yes, R.F., of course I know that WCBS-FM in NYC and WBEB in Philly are both on 101.1 and that it hasn't hurt B101's bottom line at all, because it virtually owns the 25-54 female demo in Philly. The station is probably the most successful stand-alone in the industry. (Yes, David Eduardo, I understand that stations make money based on ratings in their own markets, and that a handful of listeners in Trenton and points north make no substantial difference in a Philly staton's rate card! That doesn't mean that signal coverage doesn't matter to listeners, though, and that's what industry insiders like you don't seem to understand. You see, at one time selling time was viewed as a means to an end, and that end was serving the public "interest, convenience and necessity." Today, maximizing profits for investors is the the only apparent purpose of broadcasting, and of virtually everything else. End of soapbox speech. I won't get too far afield here.)

But I also know that when you drive up the NJ Turnpike, B101's is the first Philly Class B you lose, and that's due to co-channel interference from 'CBS-FM.

Of course, B101 -- originally WDVR -- was established in 1963 as a short-spaced drop-in. It would never be allowed as a new assignment today, and neither would the short-spaced co-channel pairs on 100.3 in Newark, NJ and Media, PA and on 99.5 in NYC and Wilmington, DE.

CBS probably could have blocked the Philly co-channel allotment if they had cared enough to try, but in those days the biggies didn't realize how important FM would become within a decade, and how dominant within two!

Remember, CBS was one of the leaders of the successful campaign to have FM kicked out of its pre-war band and moved to the present 88-108 band. And in 1963, CBS still didn't get it, even if I did at the age of 15.

What CBS, ABC, DuMont, Cowles and other did to FM in 1945 -- knowingly making false statements to the FCC on technical issues, etc. -- was unethical, and reprehensible, if not technically illegal. And be it noted that the new FCC chairman at the time, Paul Porter, had previously worked as corporate counsel for CBS!

What those companies did in suppressing a superior technology that they did not control for apparently anti-comptetive reasons SHOULD be criminal, as should what the backers of Ibiquity are doing today when they keep desperately promoting an inferior technology in which they DO own an interest for equally anti-competitive reasons!

(NBC was originally on record in favor of moving the FM band, but parent RCA switched sides, probably thinking that moving FM would set a precedent for moving all broadcast TV to UHF -- which might have been a good thing, because there wasn't enough room in the 12 VHF channels for a truly national, and competitive, TV service. And there weren't nearly as many pre-war TV sets as pre-war FM radios in the hands of the public, and virtually all pre-war TV stations were owned by huge corporations that could absorb the cost of the change, not by small radio broadcasters who couldn't find a place in the AM band, but believed in FM.)

By the way, R.F., can I assume that you don't oppose actual new relatively low-powered (analog) Class A drop-ins that violate the current rules on the same terms as those digital side channels?

 

[mgpt6]

Since IBOC has been on the scene if you wanted to listen to a distant FM station which has a local FM station on an adjcent channel, you cant anymore.Now you hear the digital hash form the local stations IBOC signal.

 

[radioskeptic]

My point exactly, mgpt6!

There are plenty of Class B first-adjacent pairs that just barely make the mileage requirement for Class B first-adjacents, but fall short of the mileage requirement for Class A-Class B co-channel pairs. (I cited the NY-Phillly pairs as a convenient example of a whole cluster of them.)

And at 250 watts ERP, or the height-adjusted equivalent, the digital side channels of the Ibiquity FM system should qualify as new Class A signals as defined in 47 CFR 73.211. Why? Because they are, in fact, separate signals, even when they share same transmitter finals as well as the the same antenna. That's because they are NOT generated as part of the analog FM signal (unlike FMeXtra digital signals, which are SCA signals that modulate the frequency of the analog FM signal -- and which stay within the analog signal channel to boot!).

Perhaps the most remarkable thing about this is the fact that the big broadcast groups who fought hard against LPFM (and had my support for that fight, because I foresaw that small independent religious broadcasters, most of whom spew far more poisonous right-wing hate nonsense than genuine religious material, would be the real winners) are now pushing a system that will cause far more interference than the 100-watt, 30-meter LPFM's ever could!

Of course, it's not so remarkable when you consider that they all own a piece of Ibiquity, and will profit, if only marginally, from the licensing fees that many small, independent broadcasters can't afford. How anti-competitive can you get?

But then, if you're a real radio oligopolist, what's not to like?

 

[SUPERCASTER]

Since IBOC has been on the scene if you wanted to listen to a distant FM station which has a local FM station on an adjcent channel, you cant anymore.Now you hear the digital hash form the local stations IBOC signal.

According to iBiquity, HD Radio cartel, promoters, and their official "playbook" there is no HD digital hash on adjacent FM channels and (anyway) is impossible to hear on an FM radio. They claim anyone who hears FM adjacent channel HD hash has a broken radio. :
HD supporters never let truth stand in the way of an opportunity to peddle their favorite destructive product.

 

[R.F. Burns]

Since IBOC has been on the scene if you wanted to listen to a distant FM station which has a local FM station on an adjcent channel, you cant anymore.Now you hear the digital hash form the local stations IBOC signal.

According to iBiquity, HD Radio cartel, promoters, and their official "playbook" there is no HD digital hash on adjacent FM channels and (anyway) is impossible to hear on an FM radio. They claim anyone who hears FM adjacent channel HD hash has a broken radio. :
HD supporters never let truth stand in the way of an opportunity to peddle their favorite destructive product.

Prove your point. Show us where that statement is made and then post a demo proving your point.

 

[Tom Wells]

Since IBOC has been on the scene if you wanted to listen to a distant FM station which has a local FM station on an adjcent channel, you cant anymore.Now you hear the digital hash form the local stations IBOC signal.

According to iBiquity, HD Radio cartel, promoters, and their official "playbook" there is no HD digital hash on adjacent FM channels and (anyway) is impossible to hear on an FM radio. They claim anyone who hears FM adjacent channel HD hash has a broken radio. :
HD supporters never let truth stand in the way of an opportunity to peddle their favorite destructive product.

Prove your point. Show us where that statement is made and then post a demo proving your point.

Mr Burns, you have never addressed the previous demos where I removed the hiss that "wasn't there".

I would make a demo showing the noise, small but present, in all FM stereo with IBOC, but I suspect the few people would
listen criically enough to hear its presence.

Do you take this opportunity today to comment on the previous demo, that we might consider your present request worthwhile?

Remember, the recording from your car radio? Where I stripped off a goodly layer of hiss?
By what I heard last week, of all the big IBOC NY AMs, WABC sure does a good job of still having crispness.

 

[mgpt6]

I can give two examples. I live near Brockton, Mass. In my car which has an OEM Chrylser tuner, I could pick up WMVY 92.7 FM which was a Class A from Mathas Vineyard ,Mass. When WBOS 92.9 FM Boston, Class C went IBOC , I could no longer get WMVY on my car radio near my home. Another more recent example is I would also listen to WXRV 92.5 a Class C FM from Haverhill, Mass. Several months ago, WPRO -FM 92.3 a Class C from Providence went IBOC. Before I could get WXRV all the way home, now I lose WXRV to WPRO's IBOC hash at the Avon/ Brockton, Mass. townline.

 

[R.F. Burns]

Since IBOC has been on the scene if you wanted to listen to a distant FM station which has a local FM station on an adjcent channel, you cant anymore.Now you hear the digital hash form the local stations IBOC signal.

According to iBiquity, HD Radio cartel, promoters, and their official "playbook" there is no HD digital hash on adjacent FM channels and (anyway) is impossible to hear on an FM radio. They claim anyone who hears FM adjacent channel HD hash has a broken radio. :
HD supporters never let truth stand in the way of an opportunity to peddle their favorite destructive product.

Prove your point. Show us where that statement is made and then post a demo proving your point.

Mr Burns, you have never addressed the previous demos where I removed the hiss that "wasn't there".

I would make a demo showing the noise, small but present, in all FM stereo with IBOC, but I suspect the few people would
listen criically enough to hear its presence.

Do you take this opportunity today to comment on the previous demo, that we might consider your present request worthwhile?

Remember, the recording from your car radio? Where I stripped off a goodly layer of hiss?
By what I heard last week, of all the big IBOC NY AMs, WABC sure does a good job of still having crispness.

To the best of my knowledge WABC restricts their audio to the Lodi transmitter site to 7.5 Khz. In the winter when they turned off their IBOC generator after dark you could really hear that the audio was resticted. They do a music show on Saturday evenings and their audio is obviously restricted. Actually, WCBS since the reintroduction of their IBOC exciter sounds great. I know what they sound like both on the air and off the air, and the audio is about the same quality for both. WOR which has a new transmitter facility also sounds very good, IMO. As to your demo, what I will do is make a NY demo using my Sony Walkman, which I can plug directly into the computer's sound card and let you make your observations again. The car demo was recorded on a TCM 5000 cassette machine with no noise reduction and standard ferric tape and the fact that I used a microphone which allowed outside noise to enter into the demo. Let's see how this works for you. By the way, what noise reduction plug in are you using? I use a directX noise reduction plug in with Sound Forge 6E as my editing program and an Audigy sound card. Also how many DB of reduction did you use in your adjustments to my demo?

 

[Tom Wells]

To the best of my knowledge WABC restricts their audio to the Lodi transmitter site to 7.5 Khz. In the winter when they turned off their IBOC generator after dark you could really hear that the audio was resticted. They do a music show on Saturday evenings and their audio is obviously restricted. Actually, WCBS since the reintroduction of their IBOC exciter sounds great. I know what they sound like both on the air and off the air, and the audio is about the same quality for both. WOR which has a new transmitter facility also sounds very good, IMO. As to your demo, what I will do is make a NY demo using my Sony Walkman, which I can plug directly into the computer's sound card and let you make your observations again. The car demo was recorded on a TCM 5000 cassette machine with no noise reduction and standard ferric tape and the fact that I used a microphone which allowed outside noise to enter into the demo. Let's see how this works for you. By the way, what noise reduction plug in are you using? I use a directX noise reduction plug in with Sound Forge 6E as my editing program and an Audigy sound card. Also how many DB of reduction did you use in your adjustments to my demo?

Using the factory 2007 Taurus AM/FM with cassette!?, the audio balance seemed best on WABC.
WFAN, WOR and WCBS have "head colds". They seem too thick between 150 and 800 hz, like old jukeboxes.

All my processing is done in old analog standalone equipment to CD, then back to files through Nero software.
When I processed the audio, I first applied DNR, a National Semiconductor product.
This varies the upper passband limit as it senses "meaningful dynamics" in audio modulation, and is variable.
This is useful from cleaning the lightest, almost imperceptible hiss, as well as the heavy hash on a worn 78 RPM.
This works well when the incoming signal is "hot", not as well if incoming levels are low.
Following this is a 15 band eq, then a variable expander both by MXR.

I then record to a Denon CDR 2020 (?) or some such. The CD then gets Nero'd in the laptop, but no nero plug-in processing.

If the walkman goes straight to the sound card input, I agree there should be no opportunity for hiss.
But I also understand the impedances between in/out may not be ideal for this combo.
You might need to pad the output.
I think you are suggesting that these in the demo will be AM analogs, center tuned on a PLL radio.

If you include WRKL, please state where it was recorded.
I'd like to suggest something like Hudson pkwy, about 130th st, or equivalent distance. This shouldn't be too bad,
as it is on the west side.

Please also include a reference recording of WINS or other for full analog comparison, with same radio and tuning.

 

[R.F. Burns]

To the best of my knowledge WABC restricts their audio to the Lodi transmitter site to 7.5 Khz. In the winter when they turned off their IBOC generator after dark you could really hear that the audio was resticted. They do a music show on Saturday evenings and their audio is obviously restricted. Actually, WCBS since the reintroduction of their IBOC exciter sounds great. I know what they sound like both on the air and off the air, and the audio is about the same quality for both. WOR which has a new transmitter facility also sounds very good, IMO. As to your demo, what I will do is make a NY demo using my Sony Walkman, which I can plug directly into the computer's sound card and let you make your observations again. The car demo was recorded on a TCM 5000 cassette machine with no noise reduction and standard ferric tape and the fact that I used a microphone which allowed outside noise to enter into the demo. Let's see how this works for you. By the way, what noise reduction plug in are you using? I use a directX noise reduction plug in with Sound Forge 6E as my editing program and an Audigy sound card. Also how many DB of reduction did you use in your adjustments to my demo?

Using the factory 2007 Taurus AM/FM with cassette!?, the audio balance seemed best on WABC.
WFAN, WOR and WCBS have "head colds". They seem too thick between 150 and 800 hz, like old jukeboxes.

All my processing is done in old analog standalone equipment to CD, then back to files through Nero software.
When I processed the audio, I first applied DNR, a National Semiconductor product.
This varies the upper passband limit as it senses "meaningful dynamics" in audio modulation, and is variable.
This is useful from cleaning the lightest, almost imperceptible hiss, as well as the heavy hash on a worn 78 RPM.
This works well when the incoming signal is "hot", not as well if incoming levels are low.
Following this is a 15 band eq, then a variable expander both by MXR.

I then record to a Denon CDR 2020 (?) or some such. The CD then gets Nero'd in the laptop, but no nero plug-in processing.

If the walkman goes straight to the sound card input, I agree there should be no opportunity for hiss.
But I also understand the impedances between in/out may not be ideal for this combo.
You might need to pad the output.
I think you are suggesting that these in the demo will be AM analogs, center tuned on a PLL radio.

If you include WRKL, please state where it was recorded.
I'd like to suggest something like Hudson pkwy, about 130th st, or equivalent distance. This shouldn't be too bad,
as it is on the west side.

Please also include a reference recording of WINS or other for full analog comparison, with same radio and tuning.

I'll record WRKL for you but can't do it at 130 street. I drive it every day and it's outside of WRKL's protected contour and it's noisy at best. I'll provide a recording south of the station but inside it's protected contour, OK?

 

[R.F. Burns]

To the best of my knowledge WABC restricts their audio to the Lodi transmitter site to 7.5 Khz. In the winter when they turned off their IBOC generator after dark you could really hear that the audio was resticted. They do a music show on Saturday evenings and their audio is obviously restricted. Actually, WCBS since the reintroduction of their IBOC exciter sounds great. I know what they sound like both on the air and off the air, and the audio is about the same quality for both. WOR which has a new transmitter facility also sounds very good, IMO. As to your demo, what I will do is make a NY demo using my Sony Walkman, which I can plug directly into the computer's sound card and let you make your observations again. The car demo was recorded on a TCM 5000 cassette machine with no noise reduction and standard ferric tape and the fact that I used a microphone which allowed outside noise to enter into the demo. Let's see how this works for you. By the way, what noise reduction plug in are you using? I use a directX noise reduction plug in with Sound Forge 6E as my editing program and an Audigy sound card. Also how many DB of reduction did you use in your adjustments to my demo?

Using the factory 2007 Taurus AM/FM with cassette!?, the audio balance seemed best on WABC.
WFAN, WOR and WCBS have "head colds". They seem too thick between 150 and 800 hz, like old jukeboxes.

All my processing is done in old analog standalone equipment to CD, then back to files through Nero software.
When I processed the audio, I first applied DNR, a National Semiconductor product.
This varies the upper passband limit as it senses "meaningful dynamics" in audio modulation, and is variable.
This is useful from cleaning the lightest, almost imperceptible hiss, as well as the heavy hash on a worn 78 RPM.
This works well when the incoming signal is "hot", not as well if incoming levels are low.
Following this is a 15 band eq, then a variable expander both by MXR.

I then record to a Denon CDR 2020 (?) or some such. The CD then gets Nero'd in the laptop, but no nero plug-in processing.

If the walkman goes straight to the sound card input, I agree there should be no opportunity for hiss.
But I also understand the impedances between in/out may not be ideal for this combo.
You might need to pad the output.
I think you are suggesting that these in the demo will be AM analogs, center tuned on a PLL radio.

If you include WRKL, please state where it was recorded.
I'd like to suggest something like Hudson pkwy, about 130th st, or equivalent distance. This shouldn't be too bad,
as it is on the west side.

Please also include a reference recording of WINS or other for full analog comparison, with same radio and tuning.

I'll record WRKL for you but can't do it at 130 street. I drive it every day and it's outside of WRKL's protected contour and it's noisy at best. I'll provide a recording south of the station but inside it's protected contour, OK?

OK, you'll have to overlook the slight video leakage from my computer which AM radios are prone to in my recording. Listen to WFAN 00-25, WABC 26-52, WCBS 54-1:13 & WRKL 1:14 - 2:00 recorded from my walkman;

http://download.yousendit.com/1FF9F178719AB6A5


I live about 12 miles or so from the WRKL transmiter site which is within it's protected contour. Tell me where you hear WCBS under their audio.