"Rumors of my demise have been greatly exaggerated"

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Audra Griselda Ramsey
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2 "Rumors of my demise have been greatly exaggerated" FACT: AM still a vital force in many American communities Joplin, Missouri tornado disaster: an AM station remained on the air to play a critical role for accurate, life-saving information. Many minority oriented stations: MMTC Proposals In recognition of the vital role still played by AM radio, the FCC, urged by Commissioner Pai, opened a new revitalization of the AM radio service docket 2

3 Welcome from Commissioner Pai

4 AM Revitalization Commissioner Pai started the current AM revitalization effort with speech at Dallas NAB Radio Show: asking what regulatory barriers to AM could be removed to strengthen the service. As a technical matter, AM radio has been hit hard from many angles. Noise levels affecting AM reception have risen dramatically In Home: Proliferation of computers, noisy light bulbs, and dirty power lines. Different nighttime service Auto AM antennas & receiver degradation. 4

6 AM Problems FCC recognized that AM also threatened by: The migration of AM listeners to newer media Land use patterns: Land values have changed Ground system rebuilds Multiple towers 6

7 Some Proposed Remedies: 1. Dramatic AM power increases 2. Making AM all HD digital 3. Moving AM to TV Channels 5 and 6 or to a new band. 4. Elimination of skywave protection for clears 5. Elimination of the AM ratchet rule 6. Relaxation of AM nighttime coverage limits 7. Changes in AM antenna efficiency standards 8. Modifications of interference standards 9. Allowing use of low efficiency antennas 10.Elimination of critical hours requirements 11.Changes to pre-sunrise and post-sunset operations 12.Changes in partial proof-of-performance rules 7

8 Two categories: Enhancement of service to the community Technical changes Broadcaster Reports: AM on an FM translator makes a dramatic difference. BUT: For many AM stations: No FM translator available within the minimal several miles radius allowed. Best immediate solution to AM revitalization--- Remove Barriers to AM stations acquiring FM translators. FM translators are here now Enough out there, licensed & applied-for Immediate win!! 8

9 FCC s 6 Proposals 1. AM only FM translator filing window 2. Reduce the daytime community coverage requirement 3. Reduce nighttime community coverage standard. 4. Eliminate Ratchet Rule AM proposing modification must ratchet back RSS : (a) 10%, or (b) to a level where it no longer enters into the 50% RSS value. 5. Allow modulation dependent carrier level control technologies (MDCL) 6. Modify the AM antenna efficiency standards 9

10 AM Revitalization FM Translator Windows

11 Translator 250 mile Waivers Minor Modification 250 mile move Any non-reserve band frequency: Ch One (1) and only one: Per AM station Can be: Licensee, assignee or transferee, or time brokerage or rebroadcasting agreement Includes existing fill-in translators 250-miles measured: existing to proposed translator site Not to the AM station's transmitter site

12 AM Moving Must still satisfy the "fill-in" restrictions Within 2 mv/m daytime primary, or 25-mile radius. AM s licensed or permit facilities Change with AM station's future authorized transmitter site Pending App to MOVE to the non-reserved band No, only non-reserved band translators as of the date of modification application New, unbuilt translator OK, i.e., eligibility is not limited to translator stations that are licensed and operating. 12

13 Programming & Ownership FM translator must: Rebroadcast the new AM primary station Four (4) years of on-air operation Exclusive of silent periods Commencing with the initiation of on-air service at the new location. Exclusive: cannot share time with another station (e.g.; FM D2) May not be assigned or transferred except in conjunction with the commonly owned AM station 13

14 One Shot! Make it Count! Each AM station can be specified only once as the primary File in one (but not both) of the Modification Windows Not limited by their existing translators Already using one or more translators Still eligible for the windows Must indicate in Exhibit 1 that the proposal is a 250-mile window application If not the current AM licensee Must affirmatively state have a rebroadcast agreement with the primary station licensee. 14

15 First Come First Served Each window - day-by-day first-come, first-served basis. Old-fashioned race to the courthouse Same day considered mutually-exclusive Settlements or technical resolutions allowed Therefore: File as EARLY as possible, BUT Be VERY careful. Dismissed or Denied applications cannot be amended or re-filed New application for different translator cannot specify the same AM primary 15

Dismissed or Denied Assignment Application transaction fails for any reason, Including staff dismissal or rejection Cannot re-file a second modification

16 Dismissed or Denied Assignment Application transaction fails for any reason, Including staff dismissal or rejection Cannot re-file a second modification application for a different translator One application only for each AM station in any of the Modification Windows NO OPPORTUNITY TO RE-FILE UNDER ANY CIRCUMSTANCE. 16

17 Mutually Exclusive 2 + applicants file for the same channel on the same day Same channel, same day considered mutually exclusive ( ) Resolve through settlement or technical amendments ( (d)(1)) Move to a different rule-compliant channel 17

18 Settlements Financial settlement OK Not limited by (a) legitimate and prudent expenses for broadcast station No comparable Part 74 section 18

19 1 st 250 Mile Window - 6 Mos. Window Dates: First January 29 July 28, 2016 CLOSED 1 st Window: Class C & D AM s Recognition of the lower power and/or service limitations Must still comply with the FM fill-in translator siting rules Coverage contour cannot extend beyond 2 mv/m daytime primary protected contour, or 25-mile radius from AM primary transmitter site. 19

20 2 nd 250 Mile Window - 3 Mos. Window Dates: First July 29 October 31 Open to ALL Classes Class A & B Class C & D 20

21 1st Window Window Results So Far 1 st Day 412 Applications Using CDBS BPFT (Application designator) Texas: 46 Form 349 s filed (4 dismissed) USA: 690 matching applications 2nd Window 1st day: USA: 243 matching applications reported in trade press Texas: 19 matching applications over weekend 21

22 New Translator 2017 Windows Some AM s may not find an existing rule-compliant FM translator Eligible only for AM s not filing in mile windows 1 st Window Limited to Class C and D stations 2 nd Window All AM permittees and licensees Soon as 1 st Window closes and Mutual exclusive opportunity to settle or modify Same Rules: Limited to AM permittees and licensees One and only one translator Must comply with siting rules for FM fill-in translators Permanent link to the AM primary Opportunities for settlements or technical resolutions 22

23 Mattoon Waiver Continues Three criteria: 1. No history of filing serial (hopping) minor modification applications; 2. Proposed site is mutually exclusive with the licensed translator facility; and 3. 4 year Rule - Translator will rebroadcast the proposed AM primary station Commencing with on-air service at the new location Waivers, including the four-year operating condition, in appropriate cases 23

24 Tell City Waiver Change mutual exclusivity requirement to: Both licensed and proposed site within AM primary station s 0.25 mv/m interfering contour 24

25 FCC Online Tools 25

26 FCC Translator Tools FCC WARNING! You cannot rely on these search engines The FCC specifically disclaims responsibility; They are there for your convenience only. Verify your application through a qualified communications consulting engineer. Search for translators Coverage maps 26

27 Translator Search Tool Searches all translator stations 250 miles from AM site. coordinates, street address, or map Eligible translator Full protection Available Eligible Channels are tentatively available for use. Available with Waiver predicted overlap on a 2nd-adjacent and/or 3rd-adjacent channel Submit a proper showing of lack of interference per the requirements of (d) Also reviews location for Canadian and Mexican Borders Can view the contours of nearby stations Protected contour of all FM stations authorized within +/- three (3) channels GREEN have no relevant overlapping contours with a translator BLUE have overlap on 2nd-adjacent and/or 3rd-adjacent channels GRAY have overlap on co-channels and/or 1st-adjacent channels. 27

28 Call Sign, or Coordinates 28

29 29

30 30

31 Translator Channel Finder Identifies channels available for use by FM translators at a given location. 31

32 Summary View 32

33 Details View 33

34 Details for Channel 34

35 Details for Channel 35

36 Topography & Terrain Views 36

37 37

38 Interference Complaints 38

39 What if? You build and an existing station complains you re interfering EVEN WORSE: you build And a NEW FM station is dropped in, builds and complains of interference. Translators are secondary service: Must protect primary service Broadcast stations are primary service Entitled to protection 39

40 Interference Complaints Standard: An authorized FM translator or booster station will not be permitted to continue to operate if it causes any actual interference to: authorized broadcast station, or reception of the input signal of any TV translator, TV booster, FM translator or FM booster station direct reception by the public of the off-the-air signals of any authorized broadcast station (a)(3): Interference will be considered to occur whenever interferes with reception of a regularly used signal Regardless of quality strength of the signal, or channel 40

41 Interference Complaints Interference claims must be substantiated convincing evidence standard 4-part test first-hand evidence from bona fide regular listeners to the full-power station at the specified location Bona Fide Listener - Case law: Listeners must be unconnected with the full-service station Person or entity without a legal stake in the outcome of the translator station licensing proceeding Friends, advertisers, neighbors and others in privity to a complaining station s employees and owners are not bona fide 41

42 Remedies Remediation Opportunity Required: to the translator licensee to attempt to eliminate the interference If interference cannot be properly eliminated: Offending FM translator Shall be suspended, and Not be resumed until the interference has been eliminated. Or Demonstrate interference is not due to FM translator 42

43 MODIFICATION OF COMMUNITY COVERAGE STANDARDS 43

44 Community Coverage Standards Current Standard Daytime coverage to its entire community of license Substantial Compliance :80% of community area or population within the station s 5 mv/m contour Difficult standard to meet when have to move: Problems: Community size or shape changes Stations lose their existing transmitter sites or taken by eminent domain Selling land for debt reduction Difficult to find suitable tower sites in urban areas and land values. 44

45 Daytime Coverage Urbanized areas change urbanized areas are much larger than the actual city limits Requirements for optimal coverage of them are quite different than those for city of license coverage MMTC: Local community coverage requirement harms public interest Limits ability to reach the actual target specialized demographic audience MMTC proposed reducing the daytime requirement to 50% community coverage. Others: Eliminate it and redefine community 45

46 Nighttime Coverage Nighttime community coverage presents an even more challenging problem! Many AM radio stations must reduce power or cease operating at night. the nighttime coverage rule required 80 percent principal community area or population coverage. Site optimal for daytime, can be totally unsuitable for nighttime coverage requirement, or Stations may have to buy two sites and build separate daytime and nighttime tower arrays To escape new electronic and lighting technology interference in urban areas AM seeks a less urban site Still serves a target nighttime audience, but unable to provide the required nighttime geo-politically defined communitywide coverage 46

Nighttime Coverage Nighttime interference free levels: typically much higher than the 5 mv/m level 80% standard at night of little help Today: AM stations provide very small segment of the

47 Nighttime Coverage Nighttime interference free levels: typically much higher than the 5 mv/m level 80% standard at night of little help Today: AM stations provide very small segment of the electronically-delivered audio content Increasingly diverse number of over-the-air sources Not the age of the Waltons The community of license full coverage concept is an obsolete relic dating from the time 75 or more years ago when the FCC was responsible for rationing frequencies to be used by the very limited number of radio stations that would provide 100 percent of the over-the-air entertainment and information available to the public at the time. Ron Rackley, dutreil, Lundin & Rackley 47

48 Daytime Coverage Changes Existing licensed stations - Changed 5 mv/m contour encompasses either 50 percent of the area, or 50 percent of the population of the principal community Media Bureau may inquire into the facts justifying further modification in first 4years Compelling reason Proposals to re-define community As other than legal, political boundaries to reach underserved audiences REJECTED 48

49 New Nighttime Coverage Standard Rationale: Complexities of avoiding skywave interference require complicated nighttime directional patterns; multiple towers. Sometimes distance from daytime facilities MMTC: Nighttime rules creates entry barrier New Standard: new AM and AM seeking change of community 50 percent of the population, or 50 percent of the area Nighttime 5 mv/m signal or a nighttime interference-free contour, whichever value is higher Proposal to eliminate nighttime requirement: REJECTED But will examine requests to further reduce 49

50 Technical Proposals 50

51 Ratchet Rule Rationale Other Initiatives Class A or B AM broadcaster facility changes improvements will result in an overall reduction in the amount of skywave interference to other AM stations ( ratcheting back radiation in direction of certain other AM stations) Modulation Dependent Carrier Level Control Transmitters AM Efficiency Standards: reduced by 25% 51

52 AM Ratchet Rule The ratchet rule refers to Footnote 1 of (q) added in 1991: Class A or B AM stations: Seeking a change demonstrate an overall reduction in skywave interference (10%) caused to certain other AM stations i.e., ratcheting back radiation in the direction of certain other AM stations All agree it does not serve its intended purpose of nighttime interference reduction Stations with the greatest opportunity to provide interference-free nighttime service have been the ones most harmed Opposite effect: by reducing power Eliminated Simpler antenna systems with fewer towers 52

MDCL MODULATION DEPENDENT CARRIER LEVEL CONTROL TECHNOLOGY MDCL transmitter automatically adjusts power as a function of the modulation level Allowing

53 MDCL MODULATION DEPENDENT CARRIER LEVEL CONTROL TECHNOLOGY MDCL transmitter automatically adjusts power as a function of the modulation level Allowing lower power consumption Maintaining audio quality and signal coverage Savings can be considerable Requires newer model transmitters Not previously permitted by rules ( (a)) waivers or experimental authorizations Rule modified: No prior authority required Must electronically notify the Media Bureau of MDCL operation Within 10 days of commencement FCC Form 338 AM Station MDCL Notification in CDBS Must produced licensed full-power at some time 53

54 AM Antenna Efficiency Standards AM Antenna Efficiency A measure of radiation produced for a given power level Antennas with lower efficiency can radiate the same amount of signal by increasing their input power MMTC s Radio Rescue Petition Replace minimum efficiency with a minimum radiation standard. Minimum efficiency = hindrance ground radial & ant. Ht. limit location options. Move to less efficient and less space-intensive transmission system More power to offset the lack of efficiency ADOPTED 25% reduced AM antenna efficiency Will entertain experimental authorization requests Showing no increased interference Gather Real World experience Policy: More possible construction sites closer to audiences 54

55 A Survival Story KARR Kirkland Washington Land sold Over 51 years, Kirkland grew from 8,000 to 85,000 people Using Relaxed city of license minimum coverage rule, and Elimination of Ratchet Rule, and Specified minimum radiation efficiency rule STA granted to find a more appropriate, permanent antenna location 55

56 Radio World June 22,

57 Further NPRM 57

58 AM - NPRM Change Class A Nighttime & Critical Hours Protection Change Nighttime RSS Calculation Change Daytime protection to Class B, C and D stations Revise siting rule for cross-service Fill-in Translators 60 dbµ contour of FM translator contained within the lesser of (a) the 2 millivolts per meter (mv/m) daytime contour of the AM station, or (b) a 25-mile radius centered at the AM transmitter site Change to : greater of Modify Partial Proof : reduction of measured radials Modify Rules for Method of Moments Require surrender of dual expanded/standard band licenses 58

Modify AM Night Protection Standards (Clear Channels) Change Nighttime Critical Hours Protection to Class A Stations 200 licensed Class B and Class D AMs must reduce power and/or change to

59 Modify AM Night Protection Standards (Clear Channels) Change Nighttime Critical Hours Protection to Class A Stations 200 licensed Class B and Class D AMs must reduce power and/or change to directional antenna system Class D not protected at all Class A stations provided wide-area service Class A stations, clears, established to provide wide-area service when radio stations were few and far between. Is AM Clear Channel concept outdated? FCC Proposal: Eliminate Critical Hours Protection The FCC DAYTIME contour protections now afforded Class A stations are appropriate, day and night. Major opponents ihm Fybush, investigate 100 kw stations 59

60 Change RSS Calc Change Nighttime RSS Calculation Methodology Return pre rule changes (where Ratchet Rule was introduced) RSSing (root sum squaring) of interfering signals = adding powers together at the receive location 1991 overhaul Consensus: lowered the threshold for interfering stations to 25% percent exclusion Added first-adjacent channel stations in the interference calculations Stifled station improvement, and Not Produced the desired increased protection Proposal: Restore 50% exclusion level and eliminating firstadjacent channel stations 60

61 Change Daytime Protection to Class B, C, and D Stations Allow increased power to overcome increased level of environmental noise Change daytime primary service contour for Class B, C, and D stations to the 2 mv/m contour Harmonizes the protection with the Rural Radio proceeding Could be 0.5 m/vm for less noisy rural areas 2 mv/m contour allows greater flexibility for station modifications to increase signal strength to their primary service areas. First adjacent channels return to the pre db daytime 1:1 protection ratio Second adjacent channel groundwave protection Change and eliminate third adjacent channel groundwave protection 61

62 Revise Rule On Siting FM Cross-service Fill-in Translators Rule (g): 60 dbµ contour must be contained within the lesser of (a) the 2 mv/m daytime contour of the AM station, or (b) a 25-mile radius centered at the AM transmitter site Comments Unfair to rural communities Delete the 25-mile limit, Allow siting anywhere in 2 mv/m daytime contour FCC: Purpose to... ensure... used in the AM station's core market area, rather than in a fringe area... Proposal: FM translator coverage contour (1 mv/m) must be contained within the greater of either: the 2 mv/m daytime contour of the AM station, or a 25-mile radius centered at the AM transmitter site but 1 mv/m contour cannot extend beyond 40-mile radius 62

63 Proofs of Performance Partial Proofs Reduce radials only to those containing monitoring points Method of Moments Proofs Computer modeling 7 proposed changes Proposed 6 of the 7 changes and modified that 7 th 63

64 Dual Expanded Band / Standard Band Licensees khz Requirement that dual standard/expanded band stations relinquish one of their authorizations Intent to reduce interference in standard AM band Proposed: Require surrender of one within one year of a future Report and Order 64

65 Notice of Inquiry 65

66 Utilization Of AM Expanded Band Open the Expanded band to further development Relaxed Main Studio Requirements AND a big one not in the MPRM 66

67 AM Digital Transition

68 All-digital AM IBOC field testing Data collected (cont.): Audio recordings of analog signal (OEM receiver) at all-digital POF for all test routes (15 recordings) Audio recordings of indoor reception using Insignia Narrator (analog, digital, day, night) Signal strength measurements INSIGNIA NARRATOR 68

69 Summary of PRELIMINARY results Daytime solid all-digital coverage well beyond the 0.5 mv/m analog contour on most test routes Nighttime solid all-digital coverage well beyond the 5 mv/m analog contour Indoor good performance within the 5 mv/m analog contour 73

70 These are PRELIMINARY results EXPANDED BAND NON-DIRECTIONAL STATION SINGLE-STATION TEST Disclaimer Additional data is needed to fully understand the capabilities of all-digital AM IBOC 74

71 Gregg Skall Womble Carlyle commlaw TIME FOR YOUR?? QUESTIONS??????????

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC Comments of the National Association of Broadcasters

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC 20554 In the Matter of ) ) Amendment of Part 74 of the Commission s ) MB Docket No. 18-119 Rules Regarding FM Translator Interference ) ) I.