Analysis: Exploring the FCC’s AM Plan
     

 
The FCC released its NPRM to revitalize AM as Commissioner Mignon Clyburn’s tenure as acting chairwoman came to a close.  Photos by Jim Peck
There’s likely no single answer to the troubles of the AM radio band in the United States. Indeed, not everyone agrees AM needs help. But engineers and owners who seek its “revitalization” believe that both short- and long-term solutions are needed if the service will still be around in a decade.
 
Observers who spoke with Radio World said they were pleased that the FCC released a Notice of Proposed Rulemaking on Oct. 31, explaining steps the agency wants to take to help AM and inviting comments. Among other things, the plan would give every AM station the opportunity to apply for one FM translator to provide fill-in and/or nighttime service.
 
The NPRM was one of the FCC’s final acts while Commissioner Mignon Clyburn was acting as its chair; she had promised quick action on the issue at the fall Radio Show, though the government shutdown stalled things for 16 days. She noted a “special affection” for AM because of a friendship with a person at KKDA in Dallas in the early 1980s who helped her get her professional footing.
 
Clyburn said AM needs the agency’s help. “The number of stations is decreasing; AM listenership is dwindling; and young people just are not tuning in.”
 
In the NPRM, the commission stated: “The sustainability of the AM broadcast service has been threatened by the migration of AM listeners to newer media.” The agency said technical limitations have contributed to that consumer migration.
 
“Today, AM broadcasts provide lower fidelity than other sources of audio programming including FM, satellite radio, personal media players, podcasts and audio streams provided over the Internet. Digital media sources can also provide advanced consumer-friendly features, such as real-time data and information displays, that are not available via analog AM radio.”
 
Commissioner Ajit Pai, who took up the AM cause publicly a year ago, says the NPRM kicks off a “landmark” effort by the FCC to “energize” the nation’s oldest broadcasting service.
 
“If you care about diversity, you should care about AM,” Pai said at the fall show. “Most minority stations are in the AM band. Many AMs cover local news and community events when no one else will.”
 
PROPOSAL
Among planned changes, the agency seeks public input on the special window to allow AMs to seek FM translators. Each applicant would be able to apply for only one FM translator per AM station.
 
It also proposes to eliminate the so-called “Ratchet Rule,” which effectively requires that an AM broadcaster seeking facility changes that would modify its signal must “demonstrate that the improvements would result in an overall reduction in the amount of skywave interference that it causes certain other AMs,” according to the agency. In other words, the AM proposing the modification must “ratchet back” radiation at the pertinent vertical angle in the direction of certain other stations, according to the FCC.  
 
The commission had adopted this rule to reduce interference but says it “appears the rule may not have achieved its intended goal,” and experts say it has had the opposite effect. Consultants du Treil, Lundin and Rackley and Hatfield & Dawson proposed its elimination in 2009. They said the rule tends to discourage service improvements in general, because a station seeking a transmitter relocation, pattern change or other improvement must reduce power. They feel the rule hurts AMs that have been on the air longest and that therefore have the lowest nighttime interference levels and largest coverage areas, in favor of reducing interference to newer stations that agreed to accept existing interference levels when they began operations. 
 
The FCC tentatively agreed to eliminate the rule and asks for comment on the presumed benefits.
 
The commission NPRM also proposes to reduce daytime coverage standards for existing AMs.
 
Currently a commercial AM must provide daytime coverage to its entire community of license, though the FCC has what it terms a “longstanding policy” to waive the rule as long as the requesting licensee can show the station would cover 80 percent of the community or population within the station’s 5 mV/m contour.
 
 
Geoff Mendenhall, retired from Harris Broadcast and now a consultant, chats with Ron Rackley of duTreil, Lundin & Rackley and Stephen Lockwood of Hatfield & Dawson at the fall Radio Show, where Rackley and Lockwood spoke about AM issues.
The Minority Media & Telecommunications Council had said the rule harms the public interest because of difficulties in finding suitable tower sites in urban areas; that limits commercial AMs from changing sites and making other improvements, according to MMTC, which leads to a long and costly waiver proceeding. MMTC asked the FCC to change the standard to require a station to provide coverage to 50 percent of its community of license with a signal of at least 60 dBu, the current coverage requirement for non-commercial FMs.
 
The FCC agrees that tower siting for AMs, especially those with directional antenna systems that require multiple towers and land-hogging ground systems, has become increasingly difficult.
 
It has said in the past that AM coverage of less than 80 percent of the community of license is inadequate and does not want to change the daytime coverage standards for new stations.
 
However, for existing AMs, the FCC has proposed modifying the daytime coverage standard to either 50 percent of the community of license area or 50 percent of the population with a 5 mV/m signal. It asks for comment on whether this change would provide flexibility for smaller and minority-owned AMs and whether the commission should extend the change to new stations as well.      
 
The commission further has proposed modifying nighttime city-grade coverage standards for existing AMs.
 
Currently AMs must reduce their power or go off the air at night to void interference to other AMs. However the commission also requires non-Class Ds to maintain a nighttime signal sufficient to cause 80 percent of the area or population within the principal community to be “encompassed by the nighttime 5 m/Vm contour or the nighttime interference-free contour, whichever value is higher.”
 
Effectively, this means a station must continue serving the bulk of their community of license at night even though the rules mandate reduced maximum power levels.
 
The FCC says it values nighttime service to communities, especially those with little or no FM service, and believes applicants for new AMs or those proposing to change community of license should provide a level of nighttime service. The MMTC argues the nighttime coverage rules make it difficult for AMs to move their antennas.
 
So the commission has tentatively concluded the nighttime coverage requirement should be eliminated for existing AMs and modified to require new AMs or those wanting to change their community of license to cover 50 percent of the population or 50 percent of their community of license with a nighttime 5 mV/m signal or a nighttime interference-free contour, whichever value is higher. The agency asks for comment on the possible benefits or harm and asks whether it should require the station’s nighttime transmitter site and nighttime interference-free contour to be completely within the predicted daytime protected 0.5 mV/m or 2 mV/m contour, to ensure the station serves at least part “of the area in the vicinity of its community of license.”
 
The commission also asks whether — rather than eliminating the nighttime coverage rule entirely — it should consider relaxing the requirement from 80 percent to 50 percent for existing stations, as it did when adopting rules for the expanded AM band and as it has now proposed for daytime coverage.   
 
The FCC also plans to allow more implementation of modulation-dependent carrier control technologies, which decrease transmitter power and potentially save energy costs; and modification of AM antenna efficiency standards to allow for shorter towers that could be located on rooftops or in other more limited spaces.
 
EARLY REACTION
Reaction to the FCC’s proposals has been varied.
 
NAB President/CEO Gordon Smith praised Clyburn and Pai for their interest in the band. “AM radio is a cultural touchstone and jobs generator in cities large and small. Many of the top revenue-generating stations are on the AM band.” The association “strongly endorses” the proceeding, he said.
 
Ben Downs, vice president and general manager of Bryan Broadcasting in Bryan, Texas, and chair of the NAB AM Task Force, was encouraged that the commission sees AM as a strong component of local communities. The proposal for a special translator window “is the lifeline many AM operators have been hoping for,” he tells Radio World.
 
Ron Rackley, a principal engineer at duTreil, Lundin & Rackley, characterized the “Ratchet Rule” as intended to fight interference but actually being “anti-coverage rather than pro-coverage.” Speaking at the fall convention, he said the rules are “taking groundwave signals that are there 100 percent of the time and forcing them to be reduced when stations make changes in [their] directional antennas to reduce interference that’s caused at a station that’s 100 miles away 10 percent of the time. That’s never made any sense to me.”
 
Womble Carlyle attorney John Garziglia called the proposed rulemaking a good first step but said the agency could have done more by proposing to relax prohibitions on moves of existing FM translators to where they can better serve AMs; he feels such a change could go a long way toward helping AMs now. Garziglia and his client Bud Walters, owner of the Cromwell Group, have been pursuing the so-called Tell City waiver at the FCC so Walters could move an FM translator further than is now allowed.
 
Walters too said the waiver is something the FCC can do to help AM broadcasters immediately. “It really deserves favorable consideration by the FCC.”
 
Several sources expressed concern that the NPRM could take a year to wind through the commission’s typical procedures, meaning it would be months — or years — before many of the proposals would take effect.
 
Walters said the NPRM is a “great idea” overall but feels the FCC is asking many questions similar to those raised in 1988 during an earlier agency attempt to help AM. He worries that implementation of many of the suggestions “may take many years.”   
 
Said Downs after the notice was released, “I was very pleased to see that the FCC is asking what the ‘next steps’ should be. I think this speaks to how well they understand the problems AM stations face and the commission’s desire to help.” But he hopes the process reaches a conclusion soon. At the fall show, he said, “There are AMs on the edge. If we take 10 years to implement solutions,” AM stations “might not be here then.”
 
‘NEXT STEPS’
The question of nighttime community coverage standards brings up the contentious issue of skywave protection. CBS Radio Senior Vice President of Engineering Glynn Walden said during a show session that although this is not a formal policy, the company is less concerned about protecting skywave than in the past. “But we are concerned about our groundwave.”
 
The commission hasn’t proposed changes to the nighttime skywave protection rules for Class A AMs, but it encouraged comments on the topic, classifying this as more of a long-term proposal that some believe would help AM.
 
One proposed change — modifying AM antenna efficiency standards that impose minimum requirements regarding effective field strength — will help operators who are boxed in by community growth, Downs said. The MMTC had asked the FCC to replace “minimum efficiency” for AM antennas with “minimum radiation,” allowing stations to use short antennas and enjoy more tower siting flexibility. The upshot, MMTC contended, is that such AMs could increase power, use less land and be able to move closer to urban areas, a key factor as land prices are forcing some AMs to move farther away from more populated areas.
 
In the notice, the agency says the record “is not yet sufficiently developed” to make any radical change, however it does agree with MMTC’s overall premise that reducing the existing minimum effective field strength values “would offer AM broadcasters some relief by enabling them to propose shorter antennas.” The agency asked for comment on whether it should reduce the minimum field strength values by “approximately 25 percent” or by some other amount and the potential impact, good or bad, on other AMs or the public. The FCC specifically seeks comment on situations in which the current minimum efficiency standards prevented an AM from moving or using a lower-cost or more site-specific antenna system.
 
Pai said he has talked with broadcasters over the past year and is convinced the proposals can make a “substantial, positive difference” to many AMs.
 
Until 1978, more than half of all radio listening was to AM, according to the FCC, but by 2010, AM listenership had dropped to 17 percent of radio listening hours. There were 4,728 AMs in the United States as of Sept. 30, the latest statistics available from the commission.
 
“What steps can the commission take so that there will be a vibrant AM radio service 10 or 15 years from now?” Pai asked. He expressed the hope that broadcasters, engineers and anyone else with an interest in AM radio will submit creative ideas to the commission.
 
Comments to MB Docket 13-249 are due by Jan. 21 and replies by Feb. 18.
 
AM IN EMERGENCIES
Only one comment had been filed in the docket at press time; Nick Leggett, an electronics technician who was one of the original petitioners for the establishment of low-power FM radio, told the commission that AM is still a valuable service that provides effective broadcasting to numerous battery-powered portable and mobile radio receivers. “This aspect of AM radio is very valuable in a widespread emergency where electric power is not available,” he wrote.
 
Leggett suggested the agency use AM radio to enable inner-city neighborhoods to provide local neighborhood broadcasts. Such a service would allow minority groups to organize and develop their own neighborhoods and the talents of community residents, he told the FCC, adding that he originally thought LPFMs would have provided this service, but noted the commission recently decided against allowing “especially low-powered stations that could have been accommodated in the urban FM spectrum.” Presumably he was referring to a commission decision not to allow 10 watt stations.
 
For higher-powered AM stations, Leggett also suggests allowing “specially credentialed engineering firms and individual professional engineers to build and test AM broadcast radio equipment for their customers. This would allow lower-cost competition to the certified (type approved) equipment provided by the current vendors.” He also suggests the FCC allow AM owners more flexibility in designing their own antenna systems.
 
Got a thought? Post a comment below or email radioworld@nbmedia.com with “Letter to the Editor” in the subject field.
 
 

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Comment List:

The only part of the plan that makes sense to me has to do with the allowance of new antenna technology. AM directional stations with multiple towers would benefit greatly from dramatically reduced tower costs because of the smaller towers (no paint, no lights, smaller footprint). The quarter-wave efficiency standard prevents many of us from making antenna changes.
By Chip Giannettino on 12/13/2013
The FCC is the source of trouble for "AM" radio. They put too many stations on the air at night and now the broadcasters are suffering. A new allocation is needed so stations can move off the medium wave band.
By James Johnson on 12/10/2013
Am I the only one that sees this whole plan as very-short-sighted? -) How does giving an AM an FM translator help the AM band? -) How does lower the standard for covering a city oif license help the AM band? -) How does eliminating the night time coverage requirement help the AM band? How are these going to bring more listeners to AM radio?
By Doodle on 12/10/2013
Are there ever cases where the deep null should be aimed a bit to one side of the protected station to have the null optimized for where the listeners are, as opposed to where the station is? The example might be protected Station 1 with a unidirectional pattern aimed towards their metro audience. So Station 2's null should be aimed at the metro audience, not at Station 1's transmitter.
By J. Harvey on 12/10/2013
I worked for 20 years @ a Daytime-only AM with a tight DA pattern. I see many potential benefits for such stations. For one thing, their DA has a deep null toward the "protected" 50Kw station it has to sign-off to "protect". This station is in a highly congested area (near the NYC metro) so an FM x-lator seems unlikely. Giving them (and others) substantial night power would be a big plus for all.
By Willie Barnett on 12/9/2013

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