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KATY files HD interference petition

Interesting email from Elliot Klein who, as we know, was instrumental in filing the KATY complaint against KRTH.

According to Mr. Klein:

“Our main reason for filing this complaint was to get CBS to come to the table. The solution, at least for KATY, is for KRTH to install a directional antenna on its IBOC operation with a deep null toward KATY. This would not hurt the IBOC coverage in the LA metro or the ARB LA metro for that matter."

Mr. Klein is no fan of IBOC. But as a way of legally challenging iBiquity, he made this observation:

"There are also some other issues that the U.S. Department of Justice should look into such as the licensing fee structure and the right of iBiquity to audit the books of stations it licenses the technology to. iBuquity is a consortium of large broadcast companies and I wonder if it’s even legal for an enterprise structured in that manner to have access to its competitors ‘books."

You can read his entire email here: http://www.laradio.com/

c5
 
Carmine5 said:
iBuquity is a consortium of large broadcast companies and I wonder if it’s even legal for an enterprise structured in that manner to have access to its competitors ‘books."
Click to expand...

That isn't correct. The large companies own shares of stock, but that doesn't give them access to competitor's books. I own stock in a lot of companies, and my access is limited to voting for board members and approving the accounting firm.
 
No, iBiquity has access to its clients'/licensees' books for auditing purposes, not its investor companies directly. That's how iBiquity enforces the revenue-sharing contract provisions having to do with subchannels.

Elliot validly points out, however, that this structure likely poses a moral risk situation. If Clear Channel or Greater Media suggest to iBiquity that the investment capital will get shut down if they "don't share financial data," what's a little Baghdad Bob Struble to do? "Just make sure I'm out of the building when the investors come. I don't want to know anything about it."

Datza nice liddle digital cumpony you got dere, Bobby. I'd bet dat plate-glass winda cost a TON. You should have sum insurance onnit. Just leave the computer booded up with de financials, okay?? Benny and I'll be back Tuezday. You go home and Dink Aboud Id, Okay, Bobbyboyy?
 
From what I can see, the "investment capitol," such as it was from the broadcasters, has already shut down. I haven't seen any announements of any new investments in this project, and iBiquity has already begun going to outside investors for their capitol. You can bet they'd tout it if they got a check from someone.
 
Play Freebird said:
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?
Click to expand...

Hi,

I'm the author of the KATY-FM pleading. Yes, in writing the pleading, I did anticipate the argument that mobile interference is not cognizable, due to the dynamic nature of received signal strength in the mobile environment. Although I generally prefer not to address arguments in anticipation that they might be raised, in this case, I felt it was better to address the issue head-on. I do believe that the Forus case that I cited in the pleading is helpful, as it does show that the FCC policy not to consider complaints of mobile interference is not all encompassing.

As to whether the affected interference area was already being obliterated by interference caused by KRTH's analog signal, there is a very simple and straightforward way to determine this. Let's do some A/B tests, turning KRTH-HD on and off, and we'll all be able to see and hear what happens.

I have read the rest of this thread as it has developed so far, and I appreciate the words of support for All Pro. You might consider filing comments in support of the Petition with the FCC. Posts to this message board are all well and good, but filings with the FCC are even better.

The Exhibit C that was part of the filing package comprised an optical disc (CD-R) and a table listing the audio tracks on the CD-R. The list included the time, date, and place associated with each recording.

If you are interested in a version of Exhibit C that contains embedded .mp3-file versions of the same recordings, please contact me.... kd4vs at comcast.net. In the embedded-audio version, one can trigger playback of the recordings by clicking within the box containing the given track number.

I generated these mp3s to reduce the file sizes, so as to prevent the .pdf version of the embedded-audio Exhibit C from growing so large that I would be unable to send it through The Tubes.

I employed 128 kilobaud sampling in the conversion process. The .mp3 copies sound much like the .wav originals. However, I used the .wav originals to make the CDs in the original, extra copies, and service copy of the filing package,so that neither CBS nor the FCC staff could question the accuracy of the recordings presented. If I had used converted .mp3 files, someone might question whether the converted versions are sufficiently faithful to the originals.

I do have some feel for the technical issues involved in this case. I received a Bachelor's degree in Electrical Engineering before attending law school, and I was involved in college radio while pursuing my undergraduate degree. I've been a ham since I was a kid, and I love the smell of hot rosin flux in the morning....

With best regards,

John Joseph McVeigh
Butler, Maryland
 
Further with regard to my last message, to avoid any ex parte issues, if anyone desires to file Comments pro (or con) with respect to the pleading that I have filed on All Pro's behalf, they should serve copies of what they file on me, and on CBS.
I consent in advance to service by email and email attachment.

JJM
 
As a follow up to this discussion, there are some observations on the KATY complaint found on the Radio World website.

http://www.rwonline.com/article/101240

Most damaging is this comment from an anonymous engineer:

"The people that signed on KATY elected to receive interference from KRTH, and [KATY] causes quite a bit of interference to KRTH because they used the Class B spacing rules as opposed to protecting it as it exists. By doing this, they volunteered to receive interference. Had they protected KRTH as it was licensed, the station would not exist is it is today (or may not exist at all)."

So with that reasoning it would seem unlikely that either CBS or the FCC would be motivated to resolve the matter.

One might be inclined to suggest that KATY gear up with HD Radio and throw a little IBOC interference KRTH's way except that IBOC also causes self-interference which is something KATY cannot afford to have happen.

c5
 
Carmine5 said:
Most damaging is this comment from an anonymous engineer:

"The people that signed on KATY elected to receive interference from KRTH, and [KATY] causes quite a bit of interference to KRTH because they used the Class B spacing rules as opposed to protecting it as it exists. By doing this, they volunteered to receive interference. Had they protected KRTH as it was licensed, the station would not exist is it is today (or may not exist at all)."
Click to expand...

This commenter fails to mention that FM receiver selectivity has improved over the years, so the actual first-adjacent interference from KRTH to KATY (and vice versa) is not as severe as it would have been 20 years ago when KATY signed on. With these advancements in receiver performance (particularly in car radios) the ability to listen to KATY (or KRTH) in the predicted mutual interference zones has also improved, allowing both stations the opportunity to increase listenership. But since KRTH began transmitting a hybrid digital signal at 101.3, the new interference to KATY is suddenly on the same channel -- and, therefore, cannot corrected in the receiver.

Those of you who follow the land-mobile industry are probably familiar with the "refarming" order that has been handed down by the FCC. If not, this document explains the basics:

http://andersonrepeaterclub.org/pdf/narrowbanding 030109.pdf

Basically, the FCC will require existing LMR licensees to reduce occupied bandwidth (at considerable expense) to make more efficient use of the spectrum and reduce interference to neighboring users. It's the improved performance of receivers which makes all of this feasible.

Meanwhile, in the AM and FM broadcast services, the FCC has taken just the opposite approach by authorizing an increase in occupied bandwidth for hybrid IBOC stations -- which reduces the quality of service on adjacent channels. Now, does this make any sense?
 
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