LPAM revised FCC proposal

[SUPERCASTER]

Dear Mr. Schellhardt,As an experienced broadcaster, and having over 45 years experience with broadcast systems in general and low power AM and FM systems in particular, (Radio Systems, LPB, etc.) I make the following observations and recommendations.Specifying a certified TIS transmitter is an extremely bad idea in my opinion for several reasons.1- Equipment certification is an expensive, time consuming process that adds substantially to the cost of transmitting equipment, limits free market competition among equipment suppliers, and delays the introduction of innovations and improvements.2- TIS transmitters have a mandatory audio filter that limits their usefulness to telephone quality voice transmission. Broadcasters and NAB lobbyists had this provision inserted into the TIS rules. Music sounds absolutely TERRIBLE when transmitted on a TIS certified transmitter. That was the intent of the broadcasters and NAB to limit competition and distinguish the TIS transmissions from any confusion with those of a licensed broadcasting station.3- I recommend VERIFICATION by competent, experienced technical person(s) who are responsible for the overall installed transmitting facility, (by periodic inspection, testing, and verification) rather then certification of any individual equipment. This is similar to the rules used by the campus limited educational low power AM stations. This will probably be required by the NAB lobbyists and FCC anyway. There is no need to add TIS certification of transmitting equipment. It is just another expensive layer of bureaucracy.The rule mandating this severe audio filter is in 47CFR90.242 section 8"Each transmitter in a Travelers Information Station shall be equipped with an audio low-pass filter. Such filter shall be installed between the modulation limiter and the modulated stage. At audio frequencies between 3 kHz and 20 kHz this filter shall have an attenuation greater than the attenuation at 1 kHz by at least:60 log<INF>10</INF> (f/3) decibels.where ``f'' is the audio frequency in kHz. At audio frequencies above 20 kHz, the attenuation shall be at least 50 decibels greater than the attenuation at 1 kHz."It sounds innocuous, but is quite severe, and makes music sound like an Edison tin foil recording.I also question the need and wisdom of the 3 "protection policies" listed as (a) (b) and (c).The FCC and NAB will undoubtedly come up with their own long list of additional restrictions, perhaps severely limiting or destroying the usefulness and practicality of the whole LPAM proposal.

 

[dbdigital]

It's too bad that the committee who put this petition together didn't consult with more experts on this issue or solicit concerns from others on the LPAM proposal in general.I'm not sure what happens at this point but, hopefully, the FCC will allow for another round of comments.db