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KATY files HD interference petition
- Thread starter TheBigA
- Start date
If nothing else this brings up an interesting question about grandfathered FMs. Should that extra power be granted to new technologies such as HD? I don't think it should. Any overlaid tech like the HD sidebands should play by the existing rules because they weren't around like the analog signal before the rules were finalized.
Knowing how the FCC has (in)acted on previous HD complaints, I expect this to go nowhere.
Knowing how the FCC has (in)acted on previous HD complaints, I expect this to go nowhere.
Very well-documented exhibits by Elliott Klein, KATY's consulting engineer. If you missed the link to the full petition (103 pages), its:
http://www.rbr.com/files.php?force&file=pdfs/KATY-FM-InterferencePet-052010.pdf
It will be interesting to watch how CBS responds. Apparently, the petitioner anticipates that the FCC (and the CBS lawyers) may cite the old WKLX precedent in an attempt to disqualify all of the mobile recordings -- which, in this day and age, would make absolutely no sense. I mean -- isn't radio supposed to be the primary "vehicle" to reach people on the go? But knowing how the Commission has taken the easy way out in RITOIE cases, KATY may have a difficult time with this; I wish Willie Davis the best. The least they could do is refund his regulatory fees.
Another counter argument that wouldn't surprise me is the questionable claim that KATY's signal in the affected areas was already unusable prior to KRTH's adoption of HD because of severe first-adjacent analog-to-analog interference. Fact is, today's FM receivers (especially those in vehicles) have much better selectivity than was typical in the 1940s when the adjacent channel protection ratios were defined. But the big problem with IBOC, as we all know, is that the digital signal is not actually "on channel", so there's no way to eliminate the interference with improved IF filtering. The only practical solution (as KATY points out) is a reduction in ERP towards the interference area. Will CBS agree to this and install a directional digital antenna, or instead spend more money fighting with KATY?
http://www.rbr.com/files.php?force&file=pdfs/KATY-FM-InterferencePet-052010.pdf
It will be interesting to watch how CBS responds. Apparently, the petitioner anticipates that the FCC (and the CBS lawyers) may cite the old WKLX precedent in an attempt to disqualify all of the mobile recordings -- which, in this day and age, would make absolutely no sense. I mean -- isn't radio supposed to be the primary "vehicle" to reach people on the go? But knowing how the Commission has taken the easy way out in RITOIE cases, KATY may have a difficult time with this; I wish Willie Davis the best. The least they could do is refund his regulatory fees.
Another counter argument that wouldn't surprise me is the questionable claim that KATY's signal in the affected areas was already unusable prior to KRTH's adoption of HD because of severe first-adjacent analog-to-analog interference. Fact is, today's FM receivers (especially those in vehicles) have much better selectivity than was typical in the 1940s when the adjacent channel protection ratios were defined. But the big problem with IBOC, as we all know, is that the digital signal is not actually "on channel", so there's no way to eliminate the interference with improved IF filtering. The only practical solution (as KATY points out) is a reduction in ERP towards the interference area. Will CBS agree to this and install a directional digital antenna, or instead spend more money fighting with KATY?
According to Inside Radio WAMU has just been issued an experimental license to increase its digital power from 170-watts to 680-watts. It will be interesting to see what kind of havoc that causes.
But, hey, in iBiquity-land it's all blue skies. According to Bob Struble in his latest column, HD Radio sales "have skyrocketed."
http://www.ibiquity.com/about_us/bobs_column_thoughts_on_radios_digital_future
Don't worry, be happy.
c5
But, hey, in iBiquity-land it's all blue skies. According to Bob Struble in his latest column, HD Radio sales "have skyrocketed."
http://www.ibiquity.com/about_us/bobs_column_thoughts_on_radios_digital_future
Don't worry, be happy.
c5
TheBigA said:
We've been told what the drill is for the digital power increase. Unless the FCC receives complaints from the public (six, is it?) from within the station's protected contour the Commish will do nothing.
It wouldn't surprise me to see them apply this same standard to long standing IBOC interference complaints.
Actually, BigA, as noted recently by Barry McLarnon in RW, the FCC's response to our complaint was far LESS than "condescending." The response was to ignore it completely. In fact, two separate complaints, over a hundred pages of findings, and four CD-Rs documenting nine weeks of interference at 43 different locations within the protected contours of all three WYSL directional patterns. Sworn statements from two respected consulting engineers. Ignored.
I wish KATY luck.
Far more serious potentially for HD are the Petitions for Reconsideration just filed. As we all know, the FCC staff can ignore the interference complaints in typical kiss-up-to-iBiquity fashion, but PFR's are another matter entirely, subject to appeal all the way to the DC Circuit Court. I wouldn't want to have to defend HD Radio in light of the exhaustive public record of interference, assuming the Petitioners have decent lawyers.
Tick.....tock......tick.....tock....
I wish KATY luck.
Far more serious potentially for HD are the Petitions for Reconsideration just filed. As we all know, the FCC staff can ignore the interference complaints in typical kiss-up-to-iBiquity fashion, but PFR's are another matter entirely, subject to appeal all the way to the DC Circuit Court. I wouldn't want to have to defend HD Radio in light of the exhaustive public record of interference, assuming the Petitioners have decent lawyers.
Tick.....tock......tick.....tock....
Nice move, Zach - now you've fed iBiquity's talking point! 
You've singlehandedly given them a chance to bray: "HD radio sales up 100%!"
Not to be an I-told-you-so, but.....I have long predicted that HD would eventually spark litigation when the stakes got high enough. Willie Davis is not a small-market AM operator (such as CBS dismissively portrays WYSL) but has resources and a multimillion dollar operation. He's not going to go away quietly when CBS pushes back. He'll complain. He'll wait for an administrative response.
And when it doesn't come - because the FCC won't take action, for all the reasons we've discussed here - he'll sue. And THAT will mark the end of HD Radio.
Which will be a good thing. We've been putting up with this repellent naked emperor long enough.
You've singlehandedly given them a chance to bray: "HD radio sales up 100%!" Not to be an I-told-you-so, but.....I have long predicted that HD would eventually spark litigation when the stakes got high enough. Willie Davis is not a small-market AM operator (such as CBS dismissively portrays WYSL) but has resources and a multimillion dollar operation. He's not going to go away quietly when CBS pushes back. He'll complain. He'll wait for an administrative response.
And when it doesn't come - because the FCC won't take action, for all the reasons we've discussed here - he'll sue. And THAT will mark the end of HD Radio.
Which will be a good thing. We've been putting up with this repellent naked emperor long enough.
Savage said:Nice move, Zach - now you've fed iBiquity's talking point!
Not to be an I-told-you-so, but.....I have long predicted that HD would eventually spark litigation when the stakes got high enough. Willie Davis is not a small-market AM operator (such as CBS dismissively portrays WYSL) but has resources and a multimillion dollar operation. He's not going to go away quietly when CBS pushes back. He'll complain. He'll wait for an administrative response.
And when it doesn't come - because the FCC won't take action, for all the reasons we've discussed here - he'll sue. And THAT will mark the end of HD Radio.
Which will be a good thing. We've been putting up with this repellent naked emperor long enough.
If the FCC listens to Willie Davis and tells the giant CBS to cut their power, wont others follow the lead of Davis? Fee-fi-fo-fum, I smell the blood...
(I watched a lot of Bills losses, though..... )
I'm with BigA. They won't do diddly squat. They use their HD Defense Stratagems of Choice - sophistry, parsing of the rules ("the meaning of 'is'"), tortured logic and Hollywood Engineering. (I imagine the few remaining and responsible engineers on the FCC staff, bound and gagged in some back room on 12th Street.)
The objective is to discourage all complainants. It will be up to the DC Circuit Court to swat this nonsense down. Which will amount to administration of the coup de grace for a technical system already overwhelmingly rejected by the public and broadcasters. It's already over for HD; it's just NPR, iBiquity and big group operators who refuse to read the memo.
)I'm with BigA. They won't do diddly squat. They use their HD Defense Stratagems of Choice - sophistry, parsing of the rules ("the meaning of 'is'"), tortured logic and Hollywood Engineering. (I imagine the few remaining and responsible engineers on the FCC staff, bound and gagged in some back room on 12th Street.)
The objective is to discourage all complainants. It will be up to the DC Circuit Court to swat this nonsense down. Which will amount to administration of the coup de grace for a technical system already overwhelmingly rejected by the public and broadcasters. It's already over for HD; it's just NPR, iBiquity and big group operators who refuse to read the memo.
Savage said:
I expect we will also see spectrum analyzer shots proving that KRTH "meets the mask", and the CBS lawyers will question why KATY has a legitimate case if the upper digital sideband is "in full compliance" with the rules. Then the FCC will send the Enforcement Bureau up to Mt Wilson, take some more shots, and agree there's nothing wrong -- never minding the fact that KATY is now unlistenable over a large part of the 60 dBu service area.
Meanwhile, isn't it comforting to know the Los Angeles EB office is working hard to shut down Part 15 hobbyists who put a long ground wire on their 100 mW transmitters, because that's a REAL PROBLEM:
http://www.fcc.gov/eb/FieldNotices/2003/DOC-269883A1.html
http://www.fcc.gov/eb/FieldNotices/2003/DOC-295836A1.html
Well, if you'll indulge me a metaphor, I think we all will sleep better knowing that: while the enforcement authorities are busy rationalizing and explaining away all the murderers and rapists rampaging through the streets, jaywalkers and unlicensed kiddie lemonade stands are dealt swift and decisive "justice."
The insanity of stubbornly defending the indefensible and irrelevant (I'm referring to HD Radio here) is emblematic of the upside-down world of Washington these days. Everywhere you look, government is out of control, in denial and acting contrary to the interests of the general public.
This board is about HD Radio. Our regulatory and enforcement issues represent a microscopic tip of a football-field sized iceberg when it comes to government in general.
The insanity of stubbornly defending the indefensible and irrelevant (I'm referring to HD Radio here) is emblematic of the upside-down world of Washington these days. Everywhere you look, government is out of control, in denial and acting contrary to the interests of the general public.
This board is about HD Radio. Our regulatory and enforcement issues represent a microscopic tip of a football-field sized iceberg when it comes to government in general.
While we're at it, all you miscreants out there....
As we listen to CBS and other Big Group Radio stations make a travesty out of the frequency allocation system of broadcast radio, obliterating popular and widely-listened-to radio stations with adjacent-channel obnoxious Soviet-jammer-style hiss - which their ambulance-chaser attorneys and captive consulting engineers insist doesn't exist - the FCC is sternly warning everyone that the use of wireless microphones in the 700 mHz range must cease by June 12. Violations will be met with fines.
The FCC isn't interested in keeping broadcast radio listenable. They're too busy herding your pastor and choir into paddy wagons outside your church for using nasty verboten microphones.
As Yakov Smirnoff used to say: "Whadda country!!!"
As we listen to CBS and other Big Group Radio stations make a travesty out of the frequency allocation system of broadcast radio, obliterating popular and widely-listened-to radio stations with adjacent-channel obnoxious Soviet-jammer-style hiss - which their ambulance-chaser attorneys and captive consulting engineers insist doesn't exist - the FCC is sternly warning everyone that the use of wireless microphones in the 700 mHz range must cease by June 12. Violations will be met with fines.
The FCC isn't interested in keeping broadcast radio listenable. They're too busy herding your pastor and choir into paddy wagons outside your church for using nasty verboten microphones.
As Yakov Smirnoff used to say: "Whadda country!!!"
Play Freebird said:
I'm sorry ... what "mask" is that? The one in § 73.317 of the Commission’s rules?
http://frwebgate.access.gpo.gov/cgi-bin/get-cfr.cgi?TITLE=47&PART=73&SECTION=317&TYPE=PDF
You've just poked one of my pet peeves. IBOC as commercialized has never fit this mask -- they gave up on this goal in the mid-1990's. The myth today is perpetuated by some graphical slight-of-hand, comparing power numbers (dBc, from § 73.317) with power spectral density numbers (dBc/kHz). It's an "apples and oranges" comparison, pure and simple.
The details are in: http://fjallfoss.fcc.gov/ecfs/document/view?id=7020408278
If the Joint Parties and iBiquity had drawn their graphs with units of dBc/Hz rather than dBc/kHz, maybe they could have convinced the Commission to allow them 30 dBc more digital power.
- Jonathan
I certainly hope the FCC (or better yet, CBS) addresses the problem, as KATY certainly should not have to deal with such interference.
With that said, I think this is a pretty exceptional situation (based on what I've heard from people who know more than I do). As a grandfathered "superpower" Class B station, the separation requirements for KRTH's adjacents weren't nearly sufficient for a station of its caliper. Since KRTH was allowed to run 1% of its grandfathered power level on their IBOC adjacents, rather than 1% of the maximum Class B power level that the spacing standards were based on, such interference is not surprising.
Not to say that there aren't regular stations that are experience a degradation of their signal by IBOC, but I doubt that this sort of situation is typical.
With that said, I think this is a pretty exceptional situation (based on what I've heard from people who know more than I do). As a grandfathered "superpower" Class B station, the separation requirements for KRTH's adjacents weren't nearly sufficient for a station of its caliper. Since KRTH was allowed to run 1% of its grandfathered power level on their IBOC adjacents, rather than 1% of the maximum Class B power level that the spacing standards were based on, such interference is not surprising.
Not to say that there aren't regular stations that are experience a degradation of their signal by IBOC, but I doubt that this sort of situation is typical.
jhardis said:
The old mask, as defined in § 73.317, was effectively replaced when the FCC adopted the NRSC-5 standard, which includes a new mask (and measurement technique) that was crafted to contain the FM IBOC emission. What's interesting, though, is that the new mask provides only 1.4 dB of headroom for the digital carriers at the -20 dBc power level. So, the 6 dB (or 10 dB) power increase does not fit in this mask, and, in essence, the FCC is breaking its own rules in permitting the increase.
In other words, business as usual.
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