FCC's AM Revitalization Docket Draws A Lot Of Comments
March 22, 2016 at 12:07 PM (PT)
The FCC's AM revitalization docket drew a huge number of comments from station owners, engineers, trade groups, and listeners, and even some sports teams. The comment period closed MONDAY (3/21), and the comments have now been posted at the FCC website.
The NATIONAL ASSOCIATION OF BROADCASTERS supported relaxing the criteria for locating FM translators for AM stations (but not the newly proposed 40-mile contour limit, noting that market geography varies widely and some areas over 40 miles away within an AM station's 2 mV/m contour may need the help to overcome interference and noise) and main studio rules, and offered a study by DOUG VERNIER TELECOMMUNICATIONS CONSULTANTS showing how changes in protection for Class B, C, and D AM stations' daytime contours would help some stations (with increased power) but hurt others (interference from nearby stations, especially when the affected station cannot increase power).
iHEARTMEDIA, in a meeting covered by an ex parte letter, focused on the proposed elimination of skywave protection for Class A stations and the harm it might do to the overall health of AM radio; in the same vein, the NEW YORK METS, CINCINNATI BENGALS, PITTSBURGH STEELERS, HOUSTON ASTROS, and FLORIDA MARLINS all urged the Commission not to harm the coverage areas of big-signal AM stations. But SAUL LEVINE's MT. WILSON FM BROADCASTERS took the opposite view, saying that the 0.1 mV/m signal is "nearly impossible to listen to" and therefore Class A protection can be limited to 0.5 mV/m, adding that "there are a plethora of program choices" today and the competing services, including satellite and streaming, are of superior sound quality and are more reliable than skywave AM.
SCOTT FYBUSH called for continued protection of Class A nighttime and critical hours operation, offering that "while most class A stations themselves now derive little or no economic benefit from their vast skywave coverage areas at night, the Commission should move with extreme caution on any proposal to further limit that coverage"; the proposal, he wrote, "threatens to diminish useful class A service while offering little real-world improvement to other stations’ signals in return." Citing previous blanket power increases for other stations, including the Class IV/C nighttime increase to 1,000 watts, FYBUSH suggested, "While an individual class D station might gain some useful new coverage in its local area were it the only such station to boost power against a co-channel class A at a distance, the cumulative effect of multiple such increases will be far less beneficial." He also predicted an "irreversible detrimental effect on emergency service" from diminution of Class A protection.
BEMIDJI RADIO, INC.'s EDWARD PAUL DE LA HUNT raised the issue of cross-service FM translators causing interference to full-signal FMs that could cause "the AMization" of the FM band; STEVEN R. BARTHOLOMEW of KIQN/COLORADO CITY, CO pointed at the problem of man-made noise from electronic equipment that will render any changes in the rules "totally ineffective"; WOLF RADIO INC. was concerned that reducing protection for Class C stations will "drastically" reduce coverage; RICK BRANCADORA of WIBG-A/OCEAN CITY, NJ proposed "salvag(ing) what is left of the decaying AM band" by giving the remaining daytimers full-time authorization and asked why Class D part-time stations pay higher regulatory fees than full-time stations; and BOB BITTNER suggested allowing all Class B stations to increase power to the point where their signals would reach the halfway point to other co-channel stations' same field strength, a power increase of an additional 500-1,000 watts for Class C stations, and a simular nighttime power increase for Class D daytimers.
In the SOCIETY OF BROADCAST ENGINEERS' comments, the group criticized the FCC's proposals as missing the primary issues, saying, "However necessary these short-term initiatives are, they are not going to lead to any meaningful, long-term improvement in MF AM broadcasting. To do that, the Commission is going to have to be willing to implement some difficult regulatory reforms that it has not heretofore addressed, and to commit to a regulatory plan which, over time, will reduce the levels of man-made noise in the MF bands, and more broadly in the bands below 30 megahertz." The filing added, " it is discouraging that in this proceeding, from the outset to the present time, the Commission seems content to allow the ambient noise levels in the AM broadcast band (and in the remainder of the MF and HF spectrum as well) to continue to increase and to accept the deteriorating RF environment as a 'given.'"
DTS, INC., now owner of HD RADIO company iBIQUITY DIGITAL, endorsed the proposal to increase use of the expanded band with all-digital broadcasts; A group of owners of stations with expanded band operations opposed any surrender deadline for the paired original AM station that gave rise to the expanded band allocations, and, separately, two SALEM subsidiaries made the same point, as did MULTICULTURAL RADIO BROADCASTING. Meanwhile, the MULTICULTURAL MEDIA, TELECOM AND INTERNET COUNCIL supported elimination of the main studio rule ("a 20th century holdover").
The AM RADIO PRESERVATION ALLIANCE, comprised of most large and medium-sized station groups, also protested the Commission's proposal to reduce skywave protection for Class A stations, comparing the big-signal stations to "anchor" department stores at shopping malls, bringing customers to the band.