Here come the complaints...

[dumber than a box of hair]

WRKL, 910 kHz in New City NY, an ethnic-format station which claims a 0.5 mV/m daytime IF contour covering most of New York City, is claiming IBOC interference from WCBS on 880 kHz.

WRKL's filings against WCBS:

http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6518808409
http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6518912523
http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6518913456

WCBS's reply to WRKL:

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

 

[Mike Walker]

Well WCBS shouldn't produce ANY interference (HD or no) thirty kilohertz away from their assigned frequency. If they do, they should correct it.

 

[vsa]

Mike, see:

http://www.radio-info.com/smf/index.php/topic,68267.0.html

 

[IBOCRocks]

Mike, see:

http://www.radio-info.com/smf/index.php/topic,68267.0.html

What does that have to do with this thread? Mike's right...if there is an issue, it has to do with this particular installation. Whether or not the good Mr. Kahn has filed suit really has nothing to do with it. Just because he filed it doesn't make him right.

 

[vsa]

Mike, see:

http://www.radio-info.com/smf/index.php/topic,68267.0.html

What does that have to do with this thread? Mike's right...if there is an issue, it has to do with this particular installation. Whether or not the good Mr. Kahn has filed suit really has nothing to do with it. Just because he filed it doesn't make him right.

It has EVERYTHING to do with this thread! You didn't read what Mr. Kahn wrote to the FCC.

Don't blame the engineers at WCBS. They are among the best in the business. Put the blame exactly where it belongs - on the 47 CFR Section 73.44(b) violating technology created by iBiquity.

 

[IBOCRocks]

Mike, see:

http://www.radio-info.com/smf/index.php/topic,68267.0.html

What does that have to do with this thread? Mike's right...if there is an issue, it has to do with this particular installation. Whether or not the good Mr. Kahn has filed suit really has nothing to do with it. Just because he filed it doesn't make him right.

It has EVERYTHING to do with this thread! You didn't read what Mr. Kahn wrote to the FCC.

Don't blame the engineers at WCBS. They are among the best in the business. Put the blame exactly where it belongs - on the 47 CFR Section 73.44(b) violating technology created by iBiquity.

Again, it has to do with the interpretation by Mr. Kahn. Goes back to "just because someone says it, it doesn't make it true."

 

[vsa]

Mike, see:

http://www.radio-info.com/smf/index.php/topic,68267.0.html

What does that have to do with this thread? Mike's right...if there is an issue, it has to do with this particular installation. Whether or not the good Mr. Kahn has filed suit really has nothing to do with it. Just because he filed it doesn't make him right.

It has EVERYTHING to do with this thread! You didn't read what Mr. Kahn wrote to the FCC.

Don't blame the engineers at WCBS. They are among the best in the business. Put the blame exactly where it belongs - on the 47 CFR Section 73.44(b) violating technology created by iBiquity.

Again, it has to do with the interpretation by Mr. Kahn. Goes back to "just because someone says it, it doesn't make it true."

47 CFR Section 73.44(b) and (a) are very clear. Federal law says it, so it is true. If the law was adhered to, there would be no interference caused by iBiquity's technology being operated by WCBS.

 

[R.F. Burns]

Mike, see:

http://www.radio-info.com/smf/index.php/topic,68267.0.html

What does that have to do with this thread? Mike's right...if there is an issue, it has to do with this particular installation. Whether or not the good Mr. Kahn has filed suit really has nothing to do with it. Just because he filed it doesn't make him right.

It has EVERYTHING to do with this thread! You didn't read what Mr. Kahn wrote to the FCC.

Don't blame the engineers at WCBS. They are among the best in the business. Put the blame exactly where it belongs - on the 47 CFR Section 73.44(b) violating technology created by iBiquity.

Again, it has to do with the interpretation by Mr. Kahn. Goes back to "just because someone says it, it doesn't make it true."

47 CFR Section 73.44(b) and (a) are very clear. Federal law says it, so it is true. If the law was adhered to, there would be no interference caused by iBiquity's technology being operated by WCBS.

I wonder who made this complaint against WCBS and who are they interfering with? I hope it isn't their neighbor to the north because if push come to shove it can be pointed out that due to short spacing their towers their tuning is so cirtical that every time it rains their pattern goes out of spec and the phaser needs to be retuned. I wonder what their monitor points look like? Are they spot on or just close enough.

 

[vsa]

Mike, see:

http://www.radio-info.com/smf/index.php/topic,68267.0.html

What does that have to do with this thread? Mike's right...if there is an issue, it has to do with this particular installation. Whether or not the good Mr. Kahn has filed suit really has nothing to do with it. Just because he filed it doesn't make him right.

It has EVERYTHING to do with this thread! You didn't read what Mr. Kahn wrote to the FCC.

Don't blame the engineers at WCBS. They are among the best in the business. Put the blame exactly where it belongs - on the 47 CFR Section 73.44(b) violating technology created by iBiquity.

Again, it has to do with the interpretation by Mr. Kahn. Goes back to "just because someone says it, it doesn't make it true."

47 CFR Section 73.44(b) and (a) are very clear. Federal law says it, so it is true. If the law was adhered to, there would be no interference caused by iBiquity's technology being operated by WCBS.

I wonder who made this complaint against WCBS and who are they interfering with? I hope it isn't their neighbor to the north because if push come to shove it can be pointed out that due to short spacing their towers their tuning is so cirtical that every time it rains their pattern goes out of spec and the phaser needs to be retuned. I wonder what their monitor points look like? Are they spot on or just close enough.

Please read the first message in this thread, posted by Mr. Hair. Then read the (a) portion of Sec 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."

If you read WCBS's response to the initial complaint by WRKL, their documetation states that the required "peak hold duration of 10 minutes" measurements were only swept at a rate of approximately 1.5 seconds. Why? Because if they were done according to the LAW, they would have clearly revealed why WCBS's hash was interfering with WRKL.

This is commonly known as a "smoking gun".

 

[clouseau]

Don't blame the engineers at WCBS. They are among the best in the business. ...

You know, I would agree with you, but did you look at the spectrum scan in the complaint? They need some work on this one.

Their 2nd and even 3rd adjacent emissions are high. I understand they are WCBS, but it looks high to me. Compare it to WFAN.

Clouseau

BTW is it just me? This looks like a very good report by an engineering firm. But they use Radio-Locator.com maps?

Weird...

 

[R.F. Burns]

Mike, see:

http://www.radio-info.com/smf/index.php/topic,68267.0.html

What does that have to do with this thread? Mike's right...if there is an issue, it has to do with this particular installation. Whether or not the good Mr. Kahn has filed suit really has nothing to do with it. Just because he filed it doesn't make him right.

It has EVERYTHING to do with this thread! You didn't read what Mr. Kahn wrote to the FCC.

Don't blame the engineers at WCBS. They are among the best in the business. Put the blame exactly where it belongs - on the 47 CFR Section 73.44(b) violating technology created by iBiquity.

Again, it has to do with the interpretation by Mr. Kahn. Goes back to "just because someone says it, it doesn't make it true."

47 CFR Section 73.44(b) and (a) are very clear. Federal law says it, so it is true. If the law was adhered to, there would be no interference caused by iBiquity's technology being operated by WCBS.

I wonder who made this complaint against WCBS and who are they interfering with? I hope it isn't their neighbor to the north because if push come to shove it can be pointed out that due to short spacing their towers their tuning is so cirtical that every time it rains their pattern goes out of spec and the phaser needs to be retuned. I wonder what their monitor points look like? Are they spot on or just close enough.

Please read the first message in this thread, posted by Mr. Hair. Then read the (a) portion of Sec 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."

If you read WCBS's response to the initial complaint by WRKL, their documetation states that the required "peak hold duration of 10 minutes" measurements were only swept at a rate of approximately 1.5 seconds. Why? Because if they were done according to the LAW, they would have clearly revealed why WCBS's hash was interfering with WRKL.

This is commonly known as a "smoking gun".

WRKL, interesting case and they are CBS's neighbors to the north and they can not keep their pattern within spec. I've been out on field readings for them. Their Kintronics phaser has to be constantly retuned. Oh and they bought a station located 30 to 40 miles from the area they were trying to reach in Brooklyn. Funny though I have no problem with WRKL anywhere within their protected contour. Of course when you're trying to reach an audience with your .1 Mv signal outside of their protected countour it'll make this very interesting.

 

[Tom Wells]

Another smoking gun is clearly evident besides the 1.5 sec dwell time.

Take a look at the noise floor for frequencies the whole swept span, and see how the whole noise floor comes up with IBOC,
not only within the disputed range, but even to the full scanned width shown.

I don't care how you slice it, this degree of splatter is the hallmark of trying to make radio "do" square waves.
You can try all you want, and the only way to keep modulation products where you really want them in "ether"
is to use sine waves. All non-linearities begin the process of splatter, so exemplified by digital AM's example.

After a few years into radio, a long, long, time ago, we learned that non-linearity was BAD.
Most of us were sold on that idea. Now to be told that it is not only OK to make this WORST sort of emission flaw, but it is OK
to run this way 100% of the time is incredible.

You can see how classic RF engineers are horrified to see offensive pollution repackaged as a desirable product.

 

[vsa]

R.F. Burns opined: "WRKL, interesting case and they are CBS's neighbors to the north and they can not keep their pattern within spec. I've been out on field readings for them. Their Kintronics phaser has to be constantly retuned. Oh and they bought a station located 30 to 40 miles from the area they were trying to reach in Brooklyn.  Funny though I have no problem with WRKL anywhere within their protected contour. Of course when you're trying to reach an audience with your .1 Mv signal outside of their protected countour it'll make this very interesting."

It's a common tactic that when the evidence is against you, you try to make the complaining radio station out to be a "suspect" kind of operator. They are not after an audience inside their .1 contour. They would like their former audience and advertisers inside the .5 contour to be able to hear the station once again without the hash.

Tom makes an excellent point about the noise floor. The HD-R-AM hash is ADDITIVE to the existing noise floor.

 

[R.F. Burns]

R.F. Burns opined: "WRKL, interesting case and they are CBS's neighbors to the north and they can not keep their pattern within spec. I've been out on field readings for them. Their Kintronics phaser has to be constantly retuned. Oh and they bought a station located 30 to 40 miles from the area they were trying to reach in Brooklyn. Funny though I have no problem with WRKL anywhere within their protected contour. Of course when you're trying to reach an audience with your .1 Mv signal outside of their protected countour it'll make this very interesting."

It's a common tactic that when the evidence is against you, you try to make the complaining radio station out to be a "suspect" kind of operator. They are not after an audience inside their .1 contour. They would like their former audience and advertisers inside the .5 contour to be able to hear the station once again without the hash.

Tom makes an excellent point about the noise floor. The HD-R-AM hash is ADDITIVE to the existing noise floor.

WRONG. You see in this case I have access to inside information and even worked at the station in the 70's. They don't want to serve an audience inside their .5 Mv contour. The station is 24/7 Polish language and there may be 50 Polish speaking people in Rockland county. Certainly not enough to support a full time radio station. They themselves hold gatherings in central Jeresy because there aren't enough listeners in Rockland County to support them. They also bought WLIM in an attempt to service the Polish speaking community in Brooklyn. That didn't work either (poor ground coductivity on sandy LI and 10 KW on 1580 goes nowhere in this part of the country and so now WLIM is Spanish language. By the way, there WRKL license renewal app, applied for in 2006, has not been granted. There's at least one individual who has filed against them. The other Rockland station WRCR which applied for renewal around the same time as RKL has already received their renewal. This is truly a case of a station trying to service a community far outside of their protected contour. Polnet, the owners have a rim shot in the Chicago area but they didn't realize when they bought WRKL that for numerous, such as the high level of RF competition and noise as well as the poor ground conductivity would make their NY dreams a tougher job to accomplish. I once asked them why they didn't buy a station such as WJDM (1530 in Elizabeth NJ with a very large Polish speaking population) instead of RKL where their audience is not located and they told me that they couldn't afford to by WJDM. They were sold a bill of goods and it's coming back to haunt them.

 

[Tom Wells]

I compare the preceding 880-910 example as argued, to the much tighter 890-910 situation I have researched.

The quality of signal and radio in each instance will determine each listener's ability to receive adjacents.

I am able, on better radios, to listen to WGTO at 90 miles despite WLS IBOC 45 miles to my south,
with luck of my location and loop antennas.
These are 50 times different in power. Even one medium quality radio could do this.

The present example in NYC is not even 2nd adjacent. They are third adjacent, and people are complaining.
This proves the point already made by so many that the manufacturers have put out massively wide-tuning radios
because it's cheap and sounds great even on AM. These radios really ARE 40 khz wide.
I've seen them. I've tuned them.

No one except radio people would ever know how to use tunable loops, so most listeners with some noise, poorly-positioned radios, weak
signals, and cheap radios are gonna be out of luck.

They'll just have to....wait until HD becomes devalued enough for someone to put on a brokered polish format.
Or until the FCC stops the newly developed interference on AM.

 

[4dude]

Well WCBS shouldn't produce ANY interference (HD or no) thirty kilohertz away from their assigned frequency. If they do, they should correct it.

Your right,they normally wouldnt produce interference 30khz away....

BUT THEY ARE RUNNING GARBAGE.....Its thier own fault though,NO ONE FORCED THEM TO GO IBOC!! (The FCC isnt making stations go it .. Thats what is so confusing to me,why are all these stations doing this????)

 

[PhilJSmith67]

If you think there are complaints now, just wait a month or so when the nighttime flamethrowers start throwing sparks all over the dial. The existing noise floor and IBOC hash is most definitely additive, and when many analog signals on AM are each competing with two IBOC sidebands from opposing first-adjacents, it will be, well... "Interesting." That situation is assuming the best case scenario, which is using a narrowband receiver with sub-10kHz bandwidth. As for HD Radio reception, I wonder how well my Sangean HDR-1 will lock any locals with all the first-adjacent signals booming in from around the country.

 

[vsa]

R.F. Burns wrote: "...I have access to inside information and even worked at the station in the 70's. They don't want to serve an audience inside their .5 Mv contour."

The complaint filed with the FCC was based on interference received within their .5 mv/m contour. That's the issue.

 

[semoochie]

The 25mv/m city-grade contour is deemed to be interference free. I thought THAT was the protected contour as opposed to 0.5mv/m, which in many cases, extends to the 25mv/m contour of a first adjacent.

 

[vsa]

The 25mv/m city-grade contour is deemed to be interference free. I thought THAT was the protected contour as opposed to 0.5mv/m, which in many cases, extends to the 25mv/m contour of a first adjacent.

Let's be precise. According to federal law, this is what counts, depending on frequency separation.

Code of Federal Regulations - Title 47, Volume 4
Sec. 73.44 AM transmission system emission limitations.

(a) The emissions...shall be measured using a properly operated and
suitable swept-frequency RF spectrum analyzer using a peak hold duration
of 10 minutes...
(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.