I hear a constant litany [usually from the “HD”-enthusiasts here] begging for a workable alternative solution when the flames roar over AM band issues. A few have “stepped-up” and presented their suggestions for digital band creation and AM rearrangement. The contributions have been interesting and with commendable merit; but in many cases, their start at point-A never reached a comprehensive conclusion at point-Z. So let’s take a stab at a really-sweeping “Band Plan” – the broadcast-equivalent of “Nation-Building” if you will. I’ll toss-in the “first draft” and take the “incoming fire” – and I can confidently-predict that explosive ordinance is headed my way!
As for any constructive attempt at band-planning; we need to first agree that the FM status quo will suffice for the reasonable future. IBOC will remain and “fight for its right to party”. Please have NO illusions that any TV-5 or 6 turf is headed for a digital-FM radio stick in the future – that spectrum is too-valuable in political eyes, and the government has handed corporate radio more than its fair share of food stamps! The “pols” are simply more-interested fuel prices, border-crashing, and over-heated Polar Bears! On the other hand, the AM band represents a valuable national resource; is in dire-need of resuscitation; and is deserving of a second chance in life.
[1] As for any *new band*: Let’s pursue the do-able and think 26 MHz in digital aac+ [for receiver synergy with IBOC]—a so-called “local-service digital D-26 band”. [2] While the FCC is giving up all those additional coffee-breaks, they can summarily-DISMISS ALL 14,000+ FM translator apps [they’re cancelable secondary services anyway] and continue the “freeze” on their non-productive future. [3] Create a NEW PRIMARY FM-assignment class [possibly call it “TA” for “Transferred Allocation”] with varied maximum ERP guided by Section 73.215 contour-protection rules... Think: “translator/LPFM hybrid and AM catch-basin”. [4] Grant “primary” status to FULL-FACILITY LP-100 FM stations—designating them as a “must relocate” by all future full-power and “TA” station apps AFTER a reasonable window to allow for the establishment of required Class TA facilities. Now, I think we have more-than-addressed the “local radio” concerns with the prior initiatives!
There is no-better candidate for an all-digital augmentation than the current AM band; but I’d question within the contemporary climate whether practicality could survive the brutal politics. Given the historical priorities of the FCC; the coverage capability of analog AM; and a heightened domestic threat – I can’t imagine the Regulators permitting a full-scale antiquation of the analog receiver base. [5] I’d suggest approval of a voluntary “proceed at YOUR own risk” provision on a station-by-station basis for one consciously-selecting a digital-only mode aimed at capable tuners; and I’d call for a digital AM receiver “type acceptance” that mandated that mode be included with hybrid-digital capability.
A technical game of Hop-Scotch or Shuffle-Board on the AM band ISN’T going to cut it... The “herd” HAS TO BE THINNED!!! This is NOT a matter of “MAYBE”—“MUST” is a more-appropriate term! No doubt this will require the proverbial “dangling carrot”—a band-bait ‘n switch if you will... And NOT at the peoples’ expense of additional corporate radio welfare and entitlement. The first challenge [related to radio] for the incoming FCC is to slam the brakes on that eight-year gravy-train; and progress beyond the mere visitation of genuine RE-REGULATION. As a political Libertarian, I can’t believe I felt it necessary to utter those dirty words – but corporate radio has worn-out its deregulatory welcome mat.
[6] To creatively-force the surrender of deficient AM facilities [in large and small markets alike], The Commission must first re-write with total retroactivity—the ownership rules that promoted this promiscuity in the first place – THEN display the carrot which becomes damn-attractive in the absence of ANY way around the *new* rules via so-called *Grandfathering*.
Continue to operate in as many locales as you can finagle-the-finances; but in ANY market where there is a “second voice” – the *new* cap is 4:2/2. If you're CCU [or their ilk] and own 8:4/4, 7:4/3, 7:3/4, 6:4/2, 6:3/3, and so-on down to within a silly station of the carved-in-stone limit of 4:2/2 – you call the media broker and sell – SELL – SELL! Here’s where things get “creative” and the carrot comes into play: If Mr. Blackburn gets you down to 6:4/2 or 5:3/2; and you’re really sentimental about the FM loss and disfavor the AM baggage; then TURN OFF and SURRENDER the license for those AM animals—put them humanely to rest – and earn a “credit” to maintain a third or fourth FM! [7] Any remaining AM is eligible for a local-digital D-26 simulcast allocation. NO “TA” will be granted to a large-market AM/FM multi-station cluster [I doubt one would fit within those circumstances anyway].
Sha-zaam! ...You’re almost back to a “cluster” again! ONLY the AM “bottom-feeders” are missing... I doubt the licenses of WABC, WCBS, WOR, WLS, WBBM, WGN, WLW, WSM, WSB, WBT, and hundreds of other capable compadres are headed back to The Commission ANYtime soon! BTW, NO smarmy AM station sales to the usual suspects who always seem to surface when “scraps” appear on the landscape [reference the AM expanded band]. YOU MUST TURN THEM OFF to enjoy the additional FM credit! Remember, the mission here is “herd-thinning”—not “herd-hiding”!
[8] Large market STAND-ALONE AM stations may seek an FM Class TA service [where possible] and local-digital D-26 allocation to SIMULCAST the AM. The “TA” cannot “travel” if that station is purchased by the operator of an in-market FM station. Stations licensed at under 250-watts at night may only operate within their specified daylight hours or a minimum of 6AM-7PM if a “TA” is granted.
Now that the big guys are in toe – let’s shift to the exurban, medium, and small markets where the AMs tend to be “Blue-Light Special” candidates anyway... The same rules above apply. [9] You may exercise the option to carve out an additional chunk of coverage IN THE FM BAND as a “TA” despite your FM circumstances. Scenario #1: You have a 5:3/2 count and wish to silence both AM stations – saving the third FM from divestiture and gaining an additional “TA” for a total of FIVE FMs. Scenario #2: You have a 4:2/2 count and wish to silence one lame AM station – gaining a “TA” and thus a third FM for a count of 4:3/1. [10] Any remaining AM facility and Class TA FM may seek a local-digital D-26 allocation for simulcast. [11] Standalone AM rules are the same as those detailed for large markets above.
Now imagine all the feeble major-market high-band 5kws; smaller-market 500-watt-day/37-watt-night typically-simulcast pea-shooters on the former Class 3s, Draconian-DA interference-machines, day-timers nearly-everywhere, and even “graveyards” that will be going bye-bye! Once cleared, the AM band could be sanely-reassessed.
[12] In the event that an AM station operates in a market with NO FM service licensed TO that community; this station qualifies for Class TA FM and D-26 local-digital service without surrendering its current AM for a predetermined period. There will be NO simulcast requirement for these additional facilities. Stations licensed at under 250-watts at night may only operate within their specified daylight hours or a minimum of 6AM-7PM if they are granted a “TA”.
[13] The C-QUAM AM-stereo system will remain the standard. Why is it that any proposal regarding AM-stereo seems to draw the unlucky number :'(
[14] FMeXtra, CAM-D, and any-other compliant transmission service will retain de facto authorization, but its implementation will remain the responsibility of those utilizing its operation [within the rules] and ELECTIVE to those designing and marketing capable receivers.
[15] The Commission WILL CODIFY minimum feature and performance standards after determining an appropriate receiver-class and retail price points regarding ALL-band reception [including D-26]; digital capability [iBiquity IBOC hybrid digital/full-digital on AM/FM if elected and digital D-26]; analog FM-stereo; NRSC AM bandwidth mask; C-QUAM AM-stereo; and possibly variable-bandwidth A-Max. Whether Sony or CTX; the FCC must mandate minimum receiver requirements. Less face fact: The U.S. is their most cherished market; so are they [in reality] prepared to surrender it by their failure to comply. If radios are fast-achieving integrated and DSP platforms; programming these “chips” into compliance shouldn’t be a daunting or expensive proposition.
If you believe that the AM band suffers from terminal disability due to over-population; and you believe that ownership limits are too high to regard the public interest – then the preceding paragraphs are a proposition worthy of debate. The “herd” can ONLY be effectively-thinned by directive [plus the carrot[/i] as a compensatory lure]. You cannot expect the former without the latter. Those few enjoying the current status quo will certainly bluster; but isn't this fair, effective, and within the realm of the public interest? ...YES, YES and YES! Are there holes? Is it ripe for nit-picking? ...YOU BET! But at least we can begin the dissection here... And that’s more productive than an AM-band autopsy!
As for any constructive attempt at band-planning; we need to first agree that the FM status quo will suffice for the reasonable future. IBOC will remain and “fight for its right to party”. Please have NO illusions that any TV-5 or 6 turf is headed for a digital-FM radio stick in the future – that spectrum is too-valuable in political eyes, and the government has handed corporate radio more than its fair share of food stamps! The “pols” are simply more-interested fuel prices, border-crashing, and over-heated Polar Bears! On the other hand, the AM band represents a valuable national resource; is in dire-need of resuscitation; and is deserving of a second chance in life.
[1] As for any *new band*: Let’s pursue the do-able and think 26 MHz in digital aac+ [for receiver synergy with IBOC]—a so-called “local-service digital D-26 band”. [2] While the FCC is giving up all those additional coffee-breaks, they can summarily-DISMISS ALL 14,000+ FM translator apps [they’re cancelable secondary services anyway] and continue the “freeze” on their non-productive future. [3] Create a NEW PRIMARY FM-assignment class [possibly call it “TA” for “Transferred Allocation”] with varied maximum ERP guided by Section 73.215 contour-protection rules... Think: “translator/LPFM hybrid and AM catch-basin”. [4] Grant “primary” status to FULL-FACILITY LP-100 FM stations—designating them as a “must relocate” by all future full-power and “TA” station apps AFTER a reasonable window to allow for the establishment of required Class TA facilities. Now, I think we have more-than-addressed the “local radio” concerns with the prior initiatives!
There is no-better candidate for an all-digital augmentation than the current AM band; but I’d question within the contemporary climate whether practicality could survive the brutal politics. Given the historical priorities of the FCC; the coverage capability of analog AM; and a heightened domestic threat – I can’t imagine the Regulators permitting a full-scale antiquation of the analog receiver base. [5] I’d suggest approval of a voluntary “proceed at YOUR own risk” provision on a station-by-station basis for one consciously-selecting a digital-only mode aimed at capable tuners; and I’d call for a digital AM receiver “type acceptance” that mandated that mode be included with hybrid-digital capability.
A technical game of Hop-Scotch or Shuffle-Board on the AM band ISN’T going to cut it... The “herd” HAS TO BE THINNED!!! This is NOT a matter of “MAYBE”—“MUST” is a more-appropriate term! No doubt this will require the proverbial “dangling carrot”—a band-bait ‘n switch if you will... And NOT at the peoples’ expense of additional corporate radio welfare and entitlement. The first challenge [related to radio] for the incoming FCC is to slam the brakes on that eight-year gravy-train; and progress beyond the mere visitation of genuine RE-REGULATION. As a political Libertarian, I can’t believe I felt it necessary to utter those dirty words – but corporate radio has worn-out its deregulatory welcome mat.
[6] To creatively-force the surrender of deficient AM facilities [in large and small markets alike], The Commission must first re-write with total retroactivity—the ownership rules that promoted this promiscuity in the first place – THEN display the carrot which becomes damn-attractive in the absence of ANY way around the *new* rules via so-called *Grandfathering*.
Continue to operate in as many locales as you can finagle-the-finances; but in ANY market where there is a “second voice” – the *new* cap is 4:2/2. If you're CCU [or their ilk] and own 8:4/4, 7:4/3, 7:3/4, 6:4/2, 6:3/3, and so-on down to within a silly station of the carved-in-stone limit of 4:2/2 – you call the media broker and sell – SELL – SELL! Here’s where things get “creative” and the carrot comes into play: If Mr. Blackburn gets you down to 6:4/2 or 5:3/2; and you’re really sentimental about the FM loss and disfavor the AM baggage; then TURN OFF and SURRENDER the license for those AM animals—put them humanely to rest – and earn a “credit” to maintain a third or fourth FM! [7] Any remaining AM is eligible for a local-digital D-26 simulcast allocation. NO “TA” will be granted to a large-market AM/FM multi-station cluster [I doubt one would fit within those circumstances anyway].
Sha-zaam! ...You’re almost back to a “cluster” again! ONLY the AM “bottom-feeders” are missing... I doubt the licenses of WABC, WCBS, WOR, WLS, WBBM, WGN, WLW, WSM, WSB, WBT, and hundreds of other capable compadres are headed back to The Commission ANYtime soon! BTW, NO smarmy AM station sales to the usual suspects who always seem to surface when “scraps” appear on the landscape [reference the AM expanded band]. YOU MUST TURN THEM OFF to enjoy the additional FM credit! Remember, the mission here is “herd-thinning”—not “herd-hiding”!
[8] Large market STAND-ALONE AM stations may seek an FM Class TA service [where possible] and local-digital D-26 allocation to SIMULCAST the AM. The “TA” cannot “travel” if that station is purchased by the operator of an in-market FM station. Stations licensed at under 250-watts at night may only operate within their specified daylight hours or a minimum of 6AM-7PM if a “TA” is granted.
Now that the big guys are in toe – let’s shift to the exurban, medium, and small markets where the AMs tend to be “Blue-Light Special” candidates anyway... The same rules above apply. [9] You may exercise the option to carve out an additional chunk of coverage IN THE FM BAND as a “TA” despite your FM circumstances. Scenario #1: You have a 5:3/2 count and wish to silence both AM stations – saving the third FM from divestiture and gaining an additional “TA” for a total of FIVE FMs. Scenario #2: You have a 4:2/2 count and wish to silence one lame AM station – gaining a “TA” and thus a third FM for a count of 4:3/1. [10] Any remaining AM facility and Class TA FM may seek a local-digital D-26 allocation for simulcast. [11] Standalone AM rules are the same as those detailed for large markets above.
Now imagine all the feeble major-market high-band 5kws; smaller-market 500-watt-day/37-watt-night typically-simulcast pea-shooters on the former Class 3s, Draconian-DA interference-machines, day-timers nearly-everywhere, and even “graveyards” that will be going bye-bye! Once cleared, the AM band could be sanely-reassessed.
[12] In the event that an AM station operates in a market with NO FM service licensed TO that community; this station qualifies for Class TA FM and D-26 local-digital service without surrendering its current AM for a predetermined period. There will be NO simulcast requirement for these additional facilities. Stations licensed at under 250-watts at night may only operate within their specified daylight hours or a minimum of 6AM-7PM if they are granted a “TA”.
[13] The C-QUAM AM-stereo system will remain the standard. Why is it that any proposal regarding AM-stereo seems to draw the unlucky number :'(
[14] FMeXtra, CAM-D, and any-other compliant transmission service will retain de facto authorization, but its implementation will remain the responsibility of those utilizing its operation [within the rules] and ELECTIVE to those designing and marketing capable receivers.
[15] The Commission WILL CODIFY minimum feature and performance standards after determining an appropriate receiver-class and retail price points regarding ALL-band reception [including D-26]; digital capability [iBiquity IBOC hybrid digital/full-digital on AM/FM if elected and digital D-26]; analog FM-stereo; NRSC AM bandwidth mask; C-QUAM AM-stereo; and possibly variable-bandwidth A-Max. Whether Sony or CTX; the FCC must mandate minimum receiver requirements. Less face fact: The U.S. is their most cherished market; so are they [in reality] prepared to surrender it by their failure to comply. If radios are fast-achieving integrated and DSP platforms; programming these “chips” into compliance shouldn’t be a daunting or expensive proposition.
If you believe that the AM band suffers from terminal disability due to over-population; and you believe that ownership limits are too high to regard the public interest – then the preceding paragraphs are a proposition worthy of debate. The “herd” can ONLY be effectively-thinned by directive [plus the carrot[/i] as a compensatory lure]. You cannot expect the former without the latter. Those few enjoying the current status quo will certainly bluster; but isn't this fair, effective, and within the realm of the public interest? ...YES, YES and YES! Are there holes? Is it ripe for nit-picking? ...YOU BET! But at least we can begin the dissection here... And that’s more productive than an AM-band autopsy!
