FCC violated 47 CFR Section 73.44(b) in approving HD-AM

[R.F. Burns]

What's the difference if a stations is blocked by the qrm of lower power stations sharing a frequency or the sound of digita IBOC. Noise is noise. I've ben told that tests were done prior to IBOCs arrival on the scene and they found only12 to 15 stations nationally where a problem might occur. With my IBOS radios and DSP I can listen to first adjacents while a IBOC station is operating on an adjacent channel.

The difference is that lower power stations do NOT share frequencies with clear channels, at least not inside the 50/50 skywave contour. Allocations outside that contour use directional antennas so that they don't spew co-channel into the protected skywave service area. However, lower power stations or even other 50kW clear channel stations do sit inside the 50/50 contours of clear stations on adjacent channels. IB(A)C intentionally puts constant hash into those adjacent channels especially within +/- 5 kHz of the adjacent station's carrier (+/- 10-15 kHz offset from the IBOC station's carrier). How are you able to hear stations adjacent to a local IBOC? The "close" sideband of the desired signal gets stepped on by the analog or by the secondary digital subcarriers, and the "far" sideband, usually the clean one, gets the primary IBOC subcarrier noise. Are you saying that if a station running IBOC has a strength of, say, 30-50 mV/m at my location, and I am trying to pick up a 1.2 mV/m skywave signal that I will still be able to hear it if I tune to the right sideband?

Just curious, what were those 12 to 15 problem stations?

IBOC operates within the law as it is written. Facts are facts.

Within the letter of the law, yes. Within the spirit of the law, no. Those who wrote the law never expected the mask to be used as a hash mask, only as a splatter mask. In my experience hash is much worse than splatter. Sadly, the spirit of the law means nothing. IBOC does fit inside a mask that was never intended to be used for digital and is legal.

This is a business not a hobby. The so called spirit of the law is defined by those who are willing to make the law say what's best for them. The letter is what matters. I am not able to tell you which stations might have problems. I wasn't privey to that detail only the rough number. You drew the conclusion that the mask was never intended for the needs of IBOC. The commission and many engineers disagree with you. You can come up with any name yoiu wish for IBOC, it's legal and the FCC has given it its stamp of approval and I don't mean just the comissioners. FCC field techs have agreed that IBOC follows the law and operates legaly. You might not like it but the anti IBOC people are fighting a losing battle because the law is not on their side.

 

[awj223]

This is a business not a hobby. The so called spirit of the law is defined by those who are willing to make the law say what's best for them. The letter is what matters. I am not able to tell you which stations might have problems. I wasn't privey to that detail only the rough number. You drew the conclusion that the mask was never intended for the needs of IBOC. The commission and many engineers disagree with you. You can come up with any name yoiu wish for IBOC, it's legal and the FCC has given it its stamp of approval and I don't mean just the comissioners. FCC field techs have agreed that IBOC follows the law and operates legaly. You might not like it but the anti IBOC people are fighting a losing battle because the law is not on their side.

Yes, DXing is a hobby. The FCC could care less about it and so could I. However, listening to stations in the secondary service area isn't a hobby. This is intended service according to the way allocations were made.

You still haven't answered the other questions. So what are the 12-15 stations nationally that were found have problems?? Can you hear a 1-2 mV/m skywave underneath a 30 mV/m IBOC adjacent with the primary sidebands 25-30 dB below? You claim you can hear adjacent channels to IBOC stations with a selective enough receiver.

 

[R.F. Burns]

This is a business not a hobby. The so called spirit of the law is defined by those who are willing to make the law say what's best for them. The letter is what matters. I am not able to tell you which stations might have problems. I wasn't privey to that detail only the rough number. You drew the conclusion that the mask was never intended for the needs of IBOC. The commission and many engineers disagree with you. You can come up with any name yoiu wish for IBOC, it's legal and the FCC has given it its stamp of approval and I don't mean just the comissioners. FCC field techs have agreed that IBOC follows the law and operates legaly. You might not like it but the anti IBOC people are fighting a losing battle because the law is not on their side.

Yes, DXing is a hobby. The FCC could care less about it and so could I. However, listening to stations in the secondary service area isn't a hobby. This is intended service according to the way allocations were made.

You still haven't answered the other questions. So what are the 12-15 stations nationally that were found have problems?? Can you hear a 1-2 mV/m skywave underneath a 30 mV/m IBOC adjacent with the primary sidebands 25-30 dB below? You claim you can hear adjacent channels to IBOC stations with a selective enough receiver.

Did you read what I wrote? I told you I was not privey to the call signs of those stations. Is that too difficult to understand? I live in NYC where we have more 50 KW 1A's than any place in America. First adjacents have always been near impossible catches here. certainly not enjoyable enough to listen to. As for claims I recorded WLW while WOR had their IBOC exciter on using my HD Receptor. I posted the audio quite some time ago. I have posted audio demonstartions all along proving my points. I'm not making this stuff up here. Read WCBS's response to the claim that they interfere with WRKL.

http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6518919218



Skywave signals are not within the protected contour of radio stations. In other words no one will guarantee that you can listen to WCBS in Ohio even if you have always been able to. That's the law. The FCC itself says that a properly operating IBOC station falls within the legal operating parameters of the rules. Don't like it? Work on having the law changed. The arguments I'm reading are like the arguments made by WRKL when they say even though WCBS (for example) is operating legally all these people with faulty radios willl suffer. There's absolutely no logic to that argument and it reminds me of the spirit of the law being as important as the letter of the law argument. No insult intended but laws are laws and IBOC operates within the letter of the law.

 

[PhilJSmith67]

IBOC operates within a horribly bastardized interpretation of the letter of the law. Even the abbreviation "I.B.O.C." had to be created to misguide the masses that this is a system that operates "on channel."

 

[Tom Wells]

The letter of the law somewhere states how many non-linear splatter "events" are permitted within a 10-minute period.

It is outside of the "spirit" of the law to state that there is only one event, and it lasts the whole 10 minutes.

It is also outside the spirit of the law to do a spectrum analyzer cumulative sweep for 1.5 seconds, when the
stated measurement cycle is 10 minutes.

Has ibiquity any idea why the FCC thought a limited number of "splatter" events per unit of time was a good operating standard?
Why wasn't continuous splatter considered good operating practice?
But now it's OK...?

By the same logic, all rules intended to prevent RF interference should be dropped.
Those with problems receiving would have to get better radios with noise blanking and DSP.


The sad part of this issue is that stations ADD this interference intentionally.
It would be bad enough if they only interfered with neighbors, but they degrade their own analog signal with muffled audio and hiss.

 

[vsa]

The letter of the law somewhere states how many  non-linear splatter "events" are permitted within a 10-minute period.

It is outside of the "spirit" of the law to state that there is only one event, and it lasts the whole 10 minutes.

It is also outside the spirit of the law to do a spectrum analyzer cumulative sweep for 1.5 seconds, when the
stated measurement cycle is 10 minutes.

Has ibiquity any idea why the FCC thought a limited number of "splatter" events per unit of time was a good operating standard?
Why wasn't continuous splatter considered good operating practice?
But  now it's OK...?

By the same logic, all rules intended to prevent RF interference should be dropped.
Those with problems receiving would have to get better radios with noise blanking and DSP.


The sad part of this issue is that stations ADD this interference intentionally.
It would be bad enough if they only interfered with neighbors, but they degrade their own analog signal with muffled audio and hiss.

Tom,

Your statement is so important that it bears repeating. It goes to the very point of this whole thread. Some so-called radio engineers here have sold their souls to iBiquity and their investors. Their messages reak of it and their attitudes reveal a plethora of arrogance. They don't give a rat's posterior about the radio broadcasting business or their smaller business neighbors. They care only about their greedy little selves. Almost every word they write here proves it!

Once again, as you stated:

"The letter of the law somewhere states how many  non-linear splatter "events" are permitted within a 10-minute period.

It is outside of the "spirit" of the law to state that there is only one event, and it lasts the whole 10 minutes.

It is also outside the spirit of the law to do a spectrum analyzer cumulative sweep for 1.5 seconds, when the stated measurement cycle is 10 minutes."


 

 

[R.F. Burns]

The letter of the law somewhere states how many non-linear splatter "events" are permitted within a 10-minute period.

It is outside of the "spirit" of the law to state that there is only one event, and it lasts the whole 10 minutes.

It is also outside the spirit of the law to do a spectrum analyzer cumulative sweep for 1.5 seconds, when the
stated measurement cycle is 10 minutes.

Has ibiquity any idea why the FCC thought a limited number of "splatter" events per unit of time was a good operating standard?
Why wasn't continuous splatter considered good operating practice?
But now it's OK...?

By the same logic, all rules intended to prevent RF interference should be dropped.
Those with problems receiving would have to get better radios with noise blanking and DSP.


The sad part of this issue is that stations ADD this interference intentionally.
It would be bad enough if they only interfered with neighbors, but they degrade their own analog signal with muffled audio and hiss.

Tom,

Your statement is so important that it bears repeating. It goes to the very point of this whole thread. Some so-called radio engineers here have sold their souls to iBiquity and their investors. Their messages reak of it and their attitudes reveal a plethora of arrogance. They don't give a rat's posterior about the radio broadcasting business or their smaller business neighbors. They care only about their greedy little selves. Almost every word they write here proves it!

Once again, as you stated:

"The letter of the law somewhere states how many non-linear splatter "events" are permitted within a 10-minute period.

It is outside of the "spirit" of the law to state that there is only one event, and it lasts the whole 10 minutes.

It is also outside the spirit of the law to do a spectrum analyzer cumulative sweep for 1.5 seconds, when the stated measurement cycle is 10 minutes."

And these smaller companies CARE about broadcasting. Baloney!! They care about their bottom line and whether IBOC is an answer or not isn't the point. What matters is the law. The FCC (including field engineers) has declared that IBOC is fully legal. What is so hard to understand?

 

[awj223]

And these smaller companies CARE about broadcasting. Baloney!! They care about their bottom line and whether IBOC is an answer or not isn't the point. What matters is the law. The FCC (including field engineers) has declared that IBOC is fully legal. What is so hard to understand?

Gimme a break. Those people would find a way declare it legal for me to wipe out everything within a quarter mile with 50 kilowatts of ultra wideband if the money was coming from the right places.

Our court system needs to hit these guys with a cluestick. Remember the whole TV broadcast flag brouhaha? How in the h*ll does that serve the public interest? Yet, the FCC declared it legal and in a ruling set a July 2006 deadline for all new hardware to recognize it, before the courts threw out that ruling and scolded the FCC for overstepping its authority.

 

[R.F. Burns]

And these smaller companies CARE about broadcasting. Baloney!! They care about their bottom line and whether IBOC is an answer or not isn't the point. What matters is the law. The FCC (including field engineers) has declared that IBOC is fully legal. What is so hard to understand?

Gimme a break. Those people would find a way declare it legal for me to wipe out everything within a quarter mile with 50 kilowatts of ultra wideband if the money was coming from the right places.

Our court system needs to hit these guys with a cluestick. Remember the whole TV broadcast flag brouhaha? How in the h*ll does that serve the public interest? Yet, the FCC declared it legal and in a ruling set a July 2006 deadline for all new hardware to recognize it, before the courts threw out that ruling and scolded the FCC for overstepping its authority.

Not gonna happen in this case. You feel your signal is being interfered with in areas where you are license to cover? File with the FCC. If not, then you have nothing to complain about. In the case of WRKL they had nothing to complain about. They receive no interference from WCBS or any other radio station. Bring on the suits but proof will be what matters, not allegations.

 

[awj223]

Not gonna happen in this case. You feel your signal is being interfered with in areas where you are license to cover? File with the FCC. If not, then you have nothing to complain about. In the case of WRKL they had nothing to complain about. They receive no interference from WCBS or any other radio station. Bring on the suits but proof will be what matters, not allegations.

Why do you keep mentioning WRKL? I'm not talking about WRKL; in fact, I think their case is a fraud and have said so. I also said that they should either tell their listeners to get better radios or sell out.

Here's where I see problems with IBOC:
http://www.hallikainen.com/FccRules/2007/73/44/

Sec. 73.44 AM transmission system emission limitations.
(a) The emissions of stations in the AM service shall be attenuated in
accordance with the requirements specified in paragraph (b) of this section.
Emissions shall be measured using a properly operated and suitable
swept-frequency RF spectrum analyzer using a peak hold duration of 10
minutes, no video filtering, and a 300 Hz resolution bandwidth, except that
a wider resolution bandwidth may be employed above 11.5 kHz to detect
transient emissions. Alternatively, other specialized receivers or monitors
with appropriate characteristics may be used to determine compliance with
the provisions of this section, provided that any disputes over measurement
accuracy are resolved in favor of measurements obtained by using a
calibrated spectrum analyzer adjusted as set forth above.

(b) Emissions 10.2 kHz to 20 kHz removed from the carrier must be attenuated
at least 25 dB below the unmodulated carrier level, emissions 20 kHz to 30
kHz removed from the carrier must be attenuated at least 35 dB below the
unmodulated carrier level, emissions 30 kHz to 60 kHz removed from the
carrier must be attenuated at least [5 + 1 dB/kHz] below the unmodulated
carrier level, and emissions between 60 kHz and 75 kHz of the carrier
frequency must be attenuated at least 65 dB below the unmodulated carrier
level. Emissions removed by more than 75 kHz must be attenuated at least 43
+ 10 Log (Power in watts) or 80 dB below the unmodulated carrier level,
whichever is the lesser attenuation, except for transmitters having power
less than 158 watts, where the attenuation must be at least 65 dB below
carrier level.

I am not yet convinced that people are using the correct measurements, although -25 dBc is a dirty signal indeed for something that stretches two channels away, and it is legal.

http://www.hallikainen.com/FccRules/2007/73/182/

Sec. 73.182 Engineering standards of allocation.
(1) Class A stations operate on clear channels with powers no less than 10kW
nor greater than 50 kW. These stations are designed to render primary and
secondary service over an extended area, with their primary services areas
protected from objectionable interference from other stations on the same
and adjacent channels. Their secondary service areas are protected from
objectionable interference from co-channel stations. For purposes of
protection, Class A stations may be divided into two groups, those located
in any of the contiguous 48 States and those located in Alaska in accordance
with Sec. 73.25.

(i) The mainland U.S. Class A stations are those assigned to the channels
allocated by Sec. 73.25. The power of these stations shall be 50 kW. The Class A
stations in this group are afforded protection as follows:

(A) Daytime. To the 0.1 mV/m groundwave contour from stations on the same
channel, and to the 0.5 mV/m groundwave contour from stations on adjacent
channels.

(B) Nighttime. To the 0.5 mV/m-50% skywave contour from stations on the same
channels.

Skywave is only protected from cochannel. Interfering IBOC stations would be adjacent channels, and this interference would be legal. Fair enough. I still think there will be issues, however. Let's take an example from the California market just because I'm most familiar with it:
http://radio-locator.com/cgi-bin/pat?call=KNBR&service=AM&status=L&hours=U
KNBR 680, Class A, 50 kW from Belmont, CA, COL San Francisco. Red line is the 2.5 mV/m contour. The 5 mV/m contour is just inside this line, and almost certainly encompasses Santa Rosa, Sacramento, Merced, and probably just makes it to the Salinas/Monterey area. What do we have sitting inside this contour? Let's take a look:
http://radio-locator.com/cgi-bin/pat?call=KMBX&service=AM&status=L&hours=D
KMBX 700, Soledad, a 2.5 kW, class B station. The transmitter is outside KNBR's 5 mV/m contour, but it shoots a strong directional signal into KNBR's protected service area in the Salinas/Monterey/Carmel area. If you've ever heard what IBOC does to stations two channels away, you know that it does cause objectionable interference in the form of a high squealing noise. 3rd adjacents are ok (which is why I think WRKL's case is a fraud) but here we're talking about a 2nd adjacent. So what happens if KMBX turns on the hash machine? I think once again, Sec 73.44 tells the story:

http://www.hallikainen.com/FccRules/2007/73/44/

Sec. 73.44 AM transmission system emission limitations.
(c) Should harmful interference be caused to the reception of other
broadcast or non-broadcast stations by out of band emissions, the licensee
may be directed to achieve a greater degree of attentuation than specified
in paragraphs (a) and (b) of this section.

There may also be issues with KNCO 830 in Grass Valley, which has a primary service area overlapping with that of KGO 810's northeast of Sacramento.
http://radio-locator.com/cgi-bin/pat?call=KGO&service=AM&status=L&hours=D
http://radio-locator.com/cgi-bin/pat?call=KNCO&service=AM&status=L&hours=D

If we had to make the rules over again, I would restrict each station to 9 kHz, designate 2 kHz per channel as guard space, and require attenuation of at least 50 dB 11 kHz away from the center. With full digital and modern coding techniques, that wouldn't sound too bad.

But in the real world, AM stations are legally allowed to be very wideband (I don't know what the people who allocated channels of 10 kHz spacing and allowed stations to spew so much spectral energy outside +/- 5 kHz from the carrier were thinking) but even so I still think there will be issues.

 

[R.F. Burns]

Not gonna happen in this case. You feel your signal is being interfered with in areas where you are license to cover? File with the FCC. If not, then you have nothing to complain about. In the case of WRKL they had nothing to complain about. They receive no interference from WCBS or any other radio station. Bring on the suits but proof will be what matters, not allegations.

Why do you keep mentioning WRKL? I'm not talking about WRKL; in fact, I think their case is a fraud and have said so. I also said that they should either tell their listeners to get better radios or sell out.

Here's where I see problems with IBOC:
http://www.hallikainen.com/FccRules/2007/73/44/

Sec. 73.44 AM transmission system emission limitations.
(a) The emissions of stations in the AM service shall be attenuated in
accordance with the requirements specified in paragraph (b) of this section.
Emissions shall be measured using a properly operated and suitable
swept-frequency RF spectrum analyzer using a peak hold duration of 10
minutes, no video filtering, and a 300 Hz resolution bandwidth, except that
a wider resolution bandwidth may be employed above 11.5 kHz to detect
transient emissions. Alternatively, other specialized receivers or monitors
with appropriate characteristics may be used to determine compliance with
the provisions of this section, provided that any disputes over measurement
accuracy are resolved in favor of measurements obtained by using a
calibrated spectrum analyzer adjusted as set forth above.

(b) Emissions 10.2 kHz to 20 kHz removed from the carrier must be attenuated
at least 25 dB below the unmodulated carrier level, emissions 20 kHz to 30
kHz removed from the carrier must be attenuated at least 35 dB below the
unmodulated carrier level, emissions 30 kHz to 60 kHz removed from the
carrier must be attenuated at least [5 + 1 dB/kHz] below the unmodulated
carrier level, and emissions between 60 kHz and 75 kHz of the carrier
frequency must be attenuated at least 65 dB below the unmodulated carrier
level. Emissions removed by more than 75 kHz must be attenuated at least 43
+ 10 Log (Power in watts) or 80 dB below the unmodulated carrier level,
whichever is the lesser attenuation, except for transmitters having power
less than 158 watts, where the attenuation must be at least 65 dB below
carrier level.

I am not yet convinced that people are using the correct measurements, although -25 dBc is a dirty signal indeed for something that stretches two channels away, and it is legal.

http://www.hallikainen.com/FccRules/2007/73/182/

Sec. 73.182 Engineering standards of allocation.
(1) Class A stations operate on clear channels with powers no less than 10kW
nor greater than 50 kW. These stations are designed to render primary and
secondary service over an extended area, with their primary services areas
protected from objectionable interference from other stations on the same
and adjacent channels. Their secondary service areas are protected from
objectionable interference from co-channel stations. For purposes of
protection, Class A stations may be divided into two groups, those located
in any of the contiguous 48 States and those located in Alaska in accordance
with Sec. 73.25.

(i) The mainland U.S. Class A stations are those assigned to the channels
allocated by Sec. 73.25. The power of these stations shall be 50 kW. The Class A
stations in this group are afforded protection as follows:

(A) Daytime. To the 0.1 mV/m groundwave contour from stations on the same
channel, and to the 0.5 mV/m groundwave contour from stations on adjacent
channels.

(B) Nighttime. To the 0.5 mV/m-50% skywave contour from stations on the same
channels.

Skywave is only protected from cochannel. Interfering IBOC stations would be adjacent channels, and this interference would be legal. Fair enough. I still think there will be issues, however. Let's take an example from the California market just because I'm most familiar with it:
http://radio-locator.com/cgi-bin/pat?call=KNBR&service=AM&status=L&hours=U
KNBR 680, Class A, 50 kW from Belmont, CA, COL San Francisco. Red line is the 2.5 mV/m contour. The 5 mV/m contour is just inside this line, and almost certainly encompasses Santa Rosa, Sacramento, Merced, and probably just makes it to the Salinas/Monterey area. What do we have sitting inside this contour? Let's take a look:
http://radio-locator.com/cgi-bin/pat?call=KMBX&service=AM&status=L&hours=D
KMBX 700, Soledad, a 2.5 kW, class B station. The transmitter is outside KNBR's 5 mV/m contour, but it shoots a strong directional signal into KNBR's protected service area in the Salinas/Monterey/Carmel area. If you've ever heard what IBOC does to stations two channels away, you know that it does cause objectionable interference in the form of a high squealing noise. 3rd adjacents are ok (which is why I think WRKL's case is a fraud) but here we're talking about a 2nd adjacent. So what happens if KMBX turns on the hash machine? I think once again, Sec 73.44 tells the story:

http://www.hallikainen.com/FccRules/2007/73/44/

Sec. 73.44 AM transmission system emission limitations.
(c) Should harmful interference be caused to the reception of other
broadcast or non-broadcast stations by out of band emissions, the licensee
may be directed to achieve a greater degree of attentuation than specified
in paragraphs (a) and (b) of this section.

There may also be issues with KNCO 830 in Grass Valley, which has a primary service area overlapping with that of KGO 810's northeast of Sacramento.
http://radio-locator.com/cgi-bin/pat?call=KGO&service=AM&status=L&hours=D
http://radio-locator.com/cgi-bin/pat?call=KNCO&service=AM&status=L&hours=D

If we had to make the rules over again, I would restrict each station to 9 kHz, designate 2 kHz per channel as guard space, and require attenuation of at least 50 dB 11 kHz away from the center. With full digital and modern coding techniques, that wouldn't sound too bad.

But in the real world, AM stations are legally allowed to be very wideband (I don't know what the people who allocated channels of 10 kHz spacing and allowed stations to spew so much spectral energy outside +/- 5 kHz from the carrier were thinking) but even so I still think there will be issues.

I bring up WRKL because it's local to NYC where I live and they are the only filing so far. You think you havew a case I say go for it. All I can tell you is that the NY field office found that WOR is operating with a perfectly legal signal.