"Naysayers" Propose Workable Solution to AM IBOC Debacle

[Chuck]

My initial response is - I like the plan. However in fairness, you can't speed read it once and formulate an intelligent opinion. I also could live without relocating LPFM. How about "LPFM can migrate" or if they decline then they lose protection (Which they don't have now) and live where they are.
<snip>
I hope a groundswell of radio people support this and get it passed. I give it a Single digit chance of passage at best.

Clouseau

I find myself agreeing with the good Inspector. Forcing anyone to move seems counter productive. Would you want to be the first to be forced to a frequency that not many people can receive? I wouldn't, but over time, a voluntary move might be a really good thing.

I'm not saying this just because I'm an LPFM advocate. I just don't think it is right to take away whatever has been granted, be it AM, FM, huge conglomerate or Mom & Pop Broadcaster. Opening new opportunities is a good thing. Forcing people to do something that may harm them is quite another story.

That said, I hope a lot of people get behind the basics of this proposal. The details can be worked out, but all in all, it is a logical way to fix many problems.

 

[TheBigA]

That said, I hope a lot of people get behind the basics of this proposal. The details can be worked out, but all in all, it is a logical way to fix many problems.

Just out of curiosity, when was the last time logic played a part in rulemaking?

I'm not trying to be nasty...just curious. I don't know. I'm thinking maybe 1928. After that, agendas got in the way.

 

[Carmine5]

My initial response is - I like the plan. However in fairness, you can't speed read it once and formulate an intelligent opinion. I also could live without relocating LPFM. How about "LPFM can migrate" or if they decline then they lose protection (Which they don't have now) and live where they are.
<snip>
I hope a groundswell of radio people support this and get it passed. I give it a Single digit chance of passage at best.

Clouseau

I find myself agreeing with the good Inspector. Forcing anyone to move seems counter productive. Would you want to be the first to be forced to a frequency that not many people can receive? I wouldn't, but over time, a voluntary move might be a really good thing.

I'm not saying this just because I'm an LPFM advocate. I just don't think it is right to take away whatever has been granted, be it AM, FM, huge conglomerate or Mom & Pop Broadcaster. Opening new opportunities is a good thing. Forcing people to do something that may harm them is quite another story.

That said, I hope a lot of people get behind the basics of this proposal. The details can be worked out, but all in all, it is a logical way to fix many problems.

Yeah, on second thought, I rescind what I said earlier about AM's making a swift transition to, I guess you could say, "expanded band FM." This is such a radical proposal, it would take years for an AM station to rebuild its audience if it transitioned to the new 'x-band FM.'

And, of course, there is the little matter of buying new radios. Would the public plunk down money for new radios?

C5

 

[Chuck]

Just out of curiosity, when was the last time logic played a part in rulemaking?

I'm not trying to be nasty...just curious. I don't know. I'm thinking maybe 1928. After that, agendas got in the way.

Not recently. Our government doesn't usually work that way, but perhaps it should. I don't want to get into a political tirade here, this isn't the place, but keep in mind this is "just radio" we're talking about. It makes you wonder about the decision making process for really big and important issues.

"Here's another fine mess you've gotten us into, Ollie...."*

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* Laurel and Hardy, for those of you who aren't old enough to remember.

 

[Chuck]

And, of course, there is the little matter of buying new radios. Would the public plunk down money for new radios?

C5

Well, there is that "little matter" right now with HD, and it doesn't seem to be going very well. If a change is going to be made, it is probably better to do it sooner, rather than later, so you partially obsolete less than a half million HD rather than a lot more later on. It will also partially obsolete the other 800 million or so analog radios people already own. They will still work as always, and that is an important consideration.

The good news is radios that can receive 76-108 MHz are actually pretty common. In the USA, they are marketed as "TV Radios." I have one in my bathroom, and lots of people do. The owner may not realize that they can already receive those frequencies. At least for analog types, they are cheap to buy, competing easily with the kind of junk you find in drug stores and dollar stores.

Of course, just like HD, getting new radios into cars is the key to success. Assuming that most people buy a new car every seven years, it will be a long time before there is any serious penetration. It will take 10 to 15 years to make them ubiquitous. That is why I am not in favor of forcing any class of station into a new frequency. Any move should be voluntary, and phased in over a number of years.

In case, this sounds like some of the same problems faced by HD, it should. It is really the same thing, just a different set of frequencies.

 

[Carmine5]

And, of course, there is the little matter of buying new radios. Would the public plunk down money for new radios?

C5

Well, there is that "little matter" right now with HD, and it doesn't seem to be going very well. If a change is going to be made, it is probably better to do it sooner, rather than later, so you partially obsolete less than a half million HD rather than a lot more later on. It will also partially obsolete the other 800 million or so analog radios people already own. They will still work as always, and that is an important consideration.

The good news is radios that can receive 76-108 MHz are actually pretty common. In the USA, they are marketed as "TV Radios." I have one in my bathroom, and lots of people do. The owner may not realize that they can already receive those frequencies. At least for analog types, they are cheap to buy, competing easily with the kind of junk you find in drug stores and dollar stores.

Of course, just like HD, getting new radios into cars is the key to success. Assuming that most people buy a new car every seven years, it will be a long time before there is any serious penetration. It will take 10 to 15 years to make them ubiquitous. That is why I am not in favor of forcing any class of station into a new frequency. Any move should be voluntary, and phased in over a number of years.

In case, this sounds like some of the same problems faced by HD, it should. It is really the same thing, just a different set of frequencies.

Actually, I was thinking about those "TV radios" as I wrote my earlier post. I have two "Ch. 6" radios myself that will tune down to 87.1.

But the proposal is asking for digital-only FM on channels 5 and 6 with 100 Mhz spacing, so these radios wouldn't work anyway.

So while the proposal eliminates the issue of interference and digital radio it doesn't solve the quandary HD Radio proponents are grappling with; getting the public on board with new radios. But I agree with you. If this is ever going to be adopted, it needs to happen pretty soon.

C5

 

[Chuck]

But the proposal is asking for digital-only FM on channels 5 and 6 with 100 Mhz spacing, so these radios wouldn't work anyway.

That is one of those "details" that would have to be worked out. The AM broadcasters who want FM translators would probably push for analog on those channels. I don't think many of them have the time to wait for the market to get saturated with digital radios. They could put an analog translator on the air for $5-10,000. A digital version would probably cost a lot more, and render very little immediate relief for the AM station.

Still, the proposal is a good place to start.

 

[jegrant]

Yeah, this is at least a very good starting point. I would also agree, it would work best if LPFMs and the short-spaced Class A full power FMs are told that they don't have to migrate, but, eventually, by a certain date, if they didn't migrate, they would lose protection on their analog signal.

I also highly support cleaning up the AM band, giving full power stations plenty of room to operate, and making room for a new LPAM & NCE AM service(s).

 

[georgetown3ham]

I love this proposal, very well thought out. A could of interesting notes, I noticed to AM stations in my area would be do well from this proposal, WXXY in Dover, Delaware and WKHZ in Ocean City, Maryland, two of the worst owners in the business. If there's a rule they haven't bent or broken, it's not for trying. I would suggest that the big AM's left should have both frequencies, since the AM band would be cleaner and they could again serve wide areas. All so wouldn't be a back idea for the "Z" stations to have at least a regional AM signal serving a good part of their state if possible, with appropriate emergency responsibilities.

 

[OKCRadioGuy]

In the grand scheme of things I love their proposal. I would make a few changes, however. First, the 87.5 and 87.7 channel would be reserved for the "all EAS all the time" channel. Many current radios can tune there, so they aught to be reserved for the emergency services. Next, I think i would allow the AMs that move to this new band in the channel 6 portion to do analog also so all of the analog TV recievers could get the AM stations. Current AM broadcasters should be at least afforded that preference. Also current AM stations should have to pick if they ultimately want to stay on AM or move off to the new band. I believe they aught to be given 10 years to make the change by being able to simulcast. (no seperate programming) When the 10 years are up they have to give up the AM signal, no exceptions. what will most likely happen is the big guns will want to keep their AM signal. The left over channels would open up room to do pure IBOC and also maintain analog service, maybe not necesssarly on adjacent channel space. I like the idea of moving the LPFMs down to new spectrum. Getting them off the current band would be great. LPFM should be afforded no protection as they were supposed to be when the service was created. If they get bumped off the go to the new band, like it or not. Eventually there could be a sundown for any remaining LPFM in the normal FM band to move. I don't have much faith that this proposal has any hopes of passing, but I really wished sanity would prevail. Savage, I hope your suit helps protect what is rightfully YOURS. The FCC was created to protect us from harmful interference, not Janet's boobs or to generate revenue. Too bad politics has changed their effective reason for existance these days.

 

[TheBigA]

Too bad politics has changed their effective reason for existance these days.

Well it's a bit more complicated than simply "politics," although everything that happens in DC is related to politics.

Martin's religious right past plays a part in his interest in indecency. But he has support in that area from the two Democrats, who just see indecency as a result of consolidation.

The bigger problem I see at the FCC is among the civil servants. They're the ones who do the real day to day work. They seem overwhelmed by what they're dealing with. The FCC used to do a lot of their technical work internally, and it's now outsourced. So when proposals like these are made, it goes way above the heads of a lot of the staffers there. That's how government has dealt with budget cuts: fewer full time employees, and more outside contractors.

I don't see anything on the horizon that will deal with this. Government has simply changed from what it was 25 years ago. Broadcasters are witnessing it with the FCC.

 

[Carmine5]

John Anderson over at his DIY Media site has a different take on this proposal. He sees it as a veiled attempt by the religious right to grab more FM spectrum.

While it's no secret that the godcasters have set their sights on FM and abandoned AM, I fail to see a strong correlation between this group and the Broadcast Maximization Committee which put forward the proposal.

Still there are some good talking points in John's essay that could be brought to the Commission's attention should this proposal actually come up for public comment.

http://www.diymedia.net/

C5

 

[Chad-Stevens]

I think a lot is going to depend on how smoothly the DTV transition occurs, but I do think there are a lot of broadcasters eyeing this spectrum closely. It's sort of a mixed blessing indeed to have EMF/Air-1 pushing for it.

FWIW, my take on expanding the FM band:

• Expand down to 76 MHz. Unlike other proposals that encompass the entire VHF-lo band, 76 MHz is a perfect place to start as Japan-spec radios usually tune the entire FM spectrum and thus imports could begin immediately.
• Permanent freeze on all applications for new stations on AM with the exception of TIS stations.
• Allot 86-88 for non comms and 84-86 for existing LPFMs and Class D's for the first five years.
• Allot 76-86 for existing AM's and shortspaced FM's only for the first ten years.
• Stations migrating must simulcast for a period of no more than three years, after which time the old license is revoked forever.
• No translators in this spectrum for a period of ten years, after which translators in the new spectrum may relay a primary that is no further than 120 miles or anywhere within the same state.
• Keep 200kHz channel spacing.
• No digital mandate.
• NOAA stays at 162 MHz as the VHF-Lo freqs are too prone to skip particularly during severe storms when these stations are at their most needed.

 

[tripinva]

They've included a tentative allotment table for every existing AM station and found substitute UHF channels for the remaining TV 5 and 6 stations. Reply comments are due August 29.

I'm thinking about commenting electronically... which proceeding should I submit my comments under?

- Trip

 

[Play Freebird]

I'm thinking about commenting electronically... which proceeding should I submit my comments under?

- Trip

Jack Mullaney (one of the committee members and an early proponent of expanding the VHF radio broadcast band down to 76 MHz) recommends you file under MB 07-294, the so-called "diversity docket".

Points I intend to cover in my comments:

1) The proponents have shown that alternative channels are available for full-service TV 5 and 6 stations which had planned to remain on those channels after February 2009. There will be some unforeseen expenses involved for these stations to move to UHF, but many other TV broadcasters have had to deal with this as well. (Remember, Channel 6 stations have been whining about NCE-FM interference for years and reassigned channels will eliminate that problem.)

The remaining question is where to put the Channel 5 and 6 LPTV and translator stations; however, those stations have far greater flexibility to take advantage of directional antennas and terrain shielding, so they can probably make use of "white spaces" in the UHF band that could not accommodate a full-service allocation. Most LPTVs and translators are located in smaller markets which are less congested to begin with.



2) The public interest would be far better served by AM digital operation in the expanded VHF band, rather than continuing with the medium-wave IBOC plan, for the following reasons:

a) Elimination of the digital sideband interference problem in the MW band, particularly at night.

b) All stations, including daytimers, would gain consistent day and night coverage

c) Reception would be much better during storms and near noisy power lines and other sources of RFI

d) "SFN" co-channel boosters could be added to fill in dead spots and improve building penetration in city centers

e) High construction and maintenance costs of multi-tower directional arrays would be eliminated. Keep in mind there was a "baby boom" of new AM stations following WW II -- their towers are now 50-60 years old and many are in need of replacement.

f) IBOC isn't even an option on certain narrowband DAs

g) A shorter wavelength would work better with "compromised" antennas built into cell phones and other portable receivers



3) A reasonable transition period should be set. Most AM broadcasters will not want to give up their medium wave channels until a sufficient number of digital receivers have penetrated the market. The FCC should consider measures to expedite this process.



4) The transition plan should place particular emphasis on public safety benefits as the "quid pro quo" for use of this spectrum, rather than selling it off to the highest bidder.

 

[TheBigA]

3) A reasonable transition period should be set. Most AM broadcasters will not want to give up their medium wave channels until a sufficient number of digital receivers have penetrated the market. The FCC should consider measures to expedite this process.

"Expedite" sounds like a mandate, which is something the FCC has been opposed to.

I know this has been brought up before, but the public simply isn't motivated to replace their radios. This isn't an HD Radio issue or a programming issue. They're not buying new radios. They're not buying XM or Sirius radios. They're not buying Bose Wave radios.They're not buying wifi internet radios. It doesn't matter if they're going to get crystal clear sound. They haven't been motivated to buy in other countries either.

The public is currently going through a 2 year ordeal where they're being told their TVs will stop working in February, and it really hasn't led to a huge rush of people replacing their TVs. They know they'll still get service if they're on cable, and more than half of the country uses cable TV. Not the same situation with AM. Is the Congress interested in apportioning hundreds of millions of dollars to cover the expenses of manufacturers and the public to "expeditite this process?"

In the meantime, station owners, who are already struggling to make ends meet, are going to have to run duplicate signals for a while, until, as you say, sufficient receivers are sold, and that may never happen.

AM radio has been allowed to collapse for 25 years. Stations have been sold to the lowest bidders, programming is terrible, and none of this is a motivation for the general public to want to get new radios. Even if it's mandated on all future radios made, including satellite. It's the radio equivalent of urban renewal. This is so pie in the sky that it's not even worth discussing. If IBOC is dead, this is not going to do much better, especially after the experience we've already been through.

Look at it from the FCC's point of view: They can give this space away to broadcasters, who've been a pain in their ass for years. Or they can sell it for hundreds of millions of dollars to cell phone companies. Why on earth would the FCC choose to give it away when someone else is willing to pay top dollar for the same space? The public interest? Oh please. We're not in Kansas anymore, Dorothy.

 

[Play Freebird]

I know this has been brought up before, but the public simply isn't motivated to replace their radios. This isn't an HD Radio issue or a programming issue. They're not buying new radios. They're not buying XM or Sirius radios. They're not buying Bose Wave radios. They're not buying wifi internet radios. It doesn't matter if they're going to get crystal clear sound. They haven't been motivated to buy in other countries either.

When people buy new cars, they buy new radios (equipped with 4 wheels). I realize car sales are slow right now, but they'll pick up again at some point, and over 99 percent of them will be factory equipped with radios.

If the expanded band proposal includes provisions to enhance public safety, then the Federal government could require inclusion of expanded band tuning in all car radios as a safety feature. The additional design and component costs would be minimal, as the same front end and DSP IF chips used in the Sony XDR-HD1 would support these new features with a change in firmware. Receiver technology in general is moving towards a software-defined platform -- so if you want to do something different, you just write new code. Of course, the cost to the public would be reduced if the non-proprietary technology were used, which means iBiquity is probably out of the picture. But once these expanded band receivers are included in cars, half the battle is won.

Look at it from the FCC's point of view: They can give this space away to broadcasters, who've been a pain in their ass for years. Or they can sell it for hundreds of millions of dollars to cell phone companies. Why on earth would the FCC choose to give it away when someone else is willing to pay top dollar for the same space? The public interest? Oh please. We're not in Kansas anymore, Dorothy.

Did you know that much of the prime UHF spectrum in Channels 52-69 is being given away, rather than sold at auction? It's set aside for public safety use by police and fire agencies and other "first responders". Noncommercial broadcasters are also given "free" spectrum, as are hams, WiFi and cordless phone users, etc.

76-88 MHz is much less desirable to cell companies than 700 MHz because of the longer wavelength and higher noise floor, but it would be quite useful to radio broadcasters. And it is outside the portion of TV spectrum which is up for sale at this time.

Anyway, the FCC answers to Congress, so that's the group which really needs to be convinced of the merits of this plan. The spectrum is available, we just need to "drill".

 

[georgetown3ham]

Where do you go on the FCC site to file comments?

 

[TheBigA]

If the expanded band proposal includes provisions to enhance public safety, then the Federal government could require inclusion of expanded band tuning in all car radios as a safety feature.

"If" and "could" are big words. Do you know how many years it took before FM radio was universal in cars? A very long time.

As we've discussed, car companies don't like the idea of giving away real estate on their dash boards. They will object. They're used to getting money, as they did from XM and Sirius. The time to have made this proposal was when satellite radio was looking to merge.

Anyway, the FCC answers to Congress, so that's the group which really needs to be convinced of the merits of this plan. The spectrum is available, we just need to "drill".

All this was discussed a long time ago, and it was decided that they don't want to force everyone to buy new radios. Especially after all the pain and expense of forcing everyone to buy new TVs.

The major radio companies can't do anything until their term with iBiquity is over.(Doing that sets up a bunch of ugly consequences, by the way) I wonder how supportive the public will be once Clear Channel starts saying how great an idea it is. I can imagine community groups demanding give-backs and divestitures from major broadcasters in order to get new and free spectrum space. Michael Copps insisting that consolidation be repealed in order for companies to qualify. Not exactly a ball of wax you want to open. Everyone has an agenda, and not everyone is in it for the public interest.

 

[Play Freebird]

Where do you go on the FCC site to file comments?

The link is http://www.fcc.gov/cgb/ecfs/

In the upper right corner, click "Submit a Filing" and enter 07-294 as the Proceeding along with your name and address.

Then, take satisfaction in knowing that you're part of the solution, instead of part of the problem.