DLR to FCC: No More New AMs

The engineering consulting firm of du Treil, Lundin & Rackley says there’s a lot the FCC can do to improve AM.

DLR says the AM band is mature and the agency should not allow more applications for new AMs, given the numerous delivery options available today. “Existing AM stations should be encouraged to improve their service to their actual audiences with as much flexibility as possible in choosing their transmitter site locations and the details of their technical facilities — or get out of the way to let other stations make improvements subject to agreements submitted to the FCC for that purpose,” states DLR in comments filed with the FCC.

Specifically, the agency should not hold any more filing windows for short-form applications, according to the engineering consulting firm, which notes “Much harm has been done to the prospects for improving AM stations in recent years because filing windows were held to allow in short-form applications for new stations and major changes that effectively blocked improvement possibilities for existing stations for years because of the need to protect the new short-form applications based on their assumed facilities. This should never happen again.”

Many of AM’s woes are caused by rising noise levels from items like computers and fluorescent lights. Adopt daytime protected contour levels that are more noise-resistant, advises DLR, suggesting 2.0 mV/m, up from the current 0.5 mV/m for Class B, C and D stations “is more representative of the signal levels needed to overcome present day noise levels.”

Additionally, the 0.1 mV/m daytime protected contour for Class A stations should be raised to 0.5 mV/m, “a change that recognizes the historic wider area coverage of Class A stations for listeners amenable to listening through noise while giving approximately the same decibel increase.”

Further, DLR proposes: “We believe that the rules should be changed to make the protected contour for daytime co-channel overlap, daytime first-adjacent channel overlap, daytime critical hours protection and nighttime overlap from co-channel skywave signals the 0.5 mV/m groundwave contour for Class A stations. In the daytime, this will replace the presently protected 0.1 mV/m contour — which we believe should not be considered a coverage contour under today’s noise conditions. At night, it will replace the 0.5 mV/m skywave contour — which we believe to be obsolete.”

The firm discusses 20+ proposals in its filing.

Several proposals concern skywave protection and how that needs to be reconsidered in the modern age. Of the proposal suggested above, DLR adds: “The proposed daytime change will allow increased flexibility for daytime coverage improvement by co-channel and first-adjacent channel AM stations while still providing a greater degree of protection to Class A stations than what we have proposed for Class B, C and D stations. The proposed 0.5 mV/m protected level will provide for listeners who might be motivated to listen through receiver noise to Class A stations’ programming content, in recognition of Class A stations’ historic role in providing such content to the public.”

Of skywave protection in general, DLR says the radio industry has had a difficult time acknowledging that Class A station 0.5 mV/m nighttime coverage has become obsolete, “because of our own tendency as well as that of others to romanticize listening to distant signals fade in and out overnight and the hobby aspects of ‘DX-ing’ distant signals.” However, the wide area programming that used to be carried overnight by Class As exclusively is distributed to listeners wherever they are with consistent audio quality using other modern technologies like satellite and Internet Protocol delivery, according to the firm. Much of the overnight programming that has historically been provided by Class As has migrated to satellite distribution and IP delivery is threatening to overtake satellite delivery someday soon.

The connected dashboard coming to more vehicles allows more choices of audio programming delivered from more sources. The reality, according to DLR, is listeners who remain for AMs will be there for the programming. AMs need to focus on finding what programming that is and delivering it in a way that competes as well as possible with the other modern-day delivery methods, “meaning with signals optimized for quality reception — something that nighttime skywave service cannot provide.” We hope that “by proposing replacement of obsolete Class A standards with a plan to protect 0.5 mV/m groundwave service, giving Class A stations enhanced protection relative to other classes of stations, we can avoid a situation where lesser protection might be enforced someday,” states DLR.

DLR also discusses FCC proposals and proposals that DLR has offered previously. It’s behind the proposal discussed this fall to open an FM translator window specifically for AM applicants, in a “one per customer” offering.

However DLR cautions the commission that FM translators alone are not the solution. “FM frequency availability will limit the extent to which AM stations are able to use FM translators, particularly in and near larger radio markets.”

The engineering consultants say the daytime community coverage standard should be eliminated and AMs should not be licensed to cover communities, calling the requirement “an obsolete relic” dating from the time when the agency was responsible for rationing frequencies “to be used by the very limited number of radio stations that would provide 100% of the over-the-air entertainment and information available to the public at the time.”

The AM landscape today is far different, “with AM stations providing a very small segment of the electronically-delivered audio content available to the public from an increasingly diverse number of over-the-air sources.” Thus a “radical” change is needed to allow AMs flexibility to see normal business forces guide them in how to best serve their actual audiences, according to DLR.

DLR favors elimination of the so-called “Ratchet Rule,” and wider use of Modulation Dependent Carrier Control technologies.

The engineering consulting firm also favors killing the minimum AM antenna efficiency requirements, noting that the 1930s’era justification for ensuring a minimum amount of service was provided for each of the “scarce AM channel assignments at the time” is no longer enough to justify impairment for flexibility in choosing antenna locations. “AM stations should have complete flexibility in choosing tower height and ground system dimensions and normal business forces can be relied upon to influence their owners to seek optimum locations for serving their audiences,” states DLR. 

Comments on AM revitalization are due to MB Docket 13-249 next week. Read DLR’s filing.

Watch our page radioworld.com/amcomments for summaries of other comments to the FCC NPRM.

Take a Fresh Look at AM Rules


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Comment List:

What happened to the idea of opening up the former Channel 6 frequencies (82-88 MHz) and migrating current AM's there along with LPFM's, then sunsetting the AM band?
By Tom McKenzie on 1/23/2014
DLR made some good points. The one that nags me the most is the fact we can't use more efficient antenna systems, which folks in other countries can use. The other problem is that Real Estate is going up in price, and the lack of availability. No one wants towers where they can see them. Back many years ago, the FCC had frozen AM licenses, and would not issue new CP's. Although at the time I disagreed with this, I now know I was shortsighted in my opinion. Receiver technology "should not" be a issue at all. If Mr. Collins could do it with tubes, we have no excuse today.
By Michael Payne on 1/16/2014
Saving AM Radio - Part 3 of 3. Because the digital processing circuitry draws a great deal more power than conventional analog receivers, the battery life of a portable digital receiver would be much less than that of the same-size battery in a conventional portable analog radio receiver. The FCC could save AM broadcast radio by allowing AM broadcast stations to increase their analog bandwidth to the same 15 kHz they had before 1989. The FCC could also issue recommendations for AM broadcast receivers to automatically adjust to take advantage of the full received audio bandwidth. Restoring the sound quality of AM broadcast radio, by allowing it to use its full original 15-kHz analog bandwidth, is the best way to save it.
By N5SK on 1/15/2014
Saving AM Radio - Part 2 of 3. Although conventional 10 kHz analog broadcast stations are still allowed, the IBOC stations' digital sidebands cause harmful interference to other stations on both sides. People will not listen to broadcast stations with poor quality signals. Some advocate converting the entire AM broadcast band to IBOC or to fully digital transmission. However, fully digital schemes are not compatible with existing receivers in the U.S., and it is impractical to convert existing analog receivers to digital. Existing radios (including car radios and portable radios) will not be able to receive fully digital broadcasts.
By N5SK on 1/15/2014
Saving AM Radio - Part 1 of 3. Broadcast AM and FM radio stations used to transmit a 15-kHz audio bandwidth signal. But in 1989, the FCC reduced the bandwidth of AM stations to only 10 kHz. Although this bandwidth reduction allowed more radio stations to be squeezed into the same amount of spectrum, this greatly reduced audio fidelity. More recently, the FCC authorized the use of a digital AM system (IBOC) which further reduced the analog audio bandwidth to only 5 kHz. IBOC stations still use 10 kHz of bandwidth because they split the remaining 5 kHz in half and fill both halves with digital signals on both sides of the 5-kHz analog core. The digital signals cause self-interference, which further degrades the quality of the analog audio signals from stations using IBOC.
By N5SK on 1/15/2014
I say it IS time for the FCC to stop expecting the radio industry to operate by ancient rules, as I see is the spirit of DLR's petition. But better yet, I believe the FCC MUST act now to save the radio broadcasters, by moving the AM's from the static of the MW band and actually expand the FM band down to 76MHz. Take the old TV CH's 5 & 6 and allocate digital only carriers for ALL of the AM's to move to first, then reallocate the FM stations as well to a digital only mode. AM clear channels are no longer clear anymore and some regional and local's weren't even in their own markets! Then, with TIS type antennas, allocate the old MW band to cities for their local public information purposes. It's time the FCC stop expecting radio to put a 4' square in a 2' hole!! That's my 2 cents worth.
By Scott Clifton on 1/14/2014
This quote is the best thing said yet about AM Revitilization. “AM stations should have complete flexibility in choosing tower height and ground system dimensions and normal business forces can be relied upon to influence their owners to seek optimum locations for serving their audiences,” states DLR. The engineering consulting firm also favors killing the minimum AM antenna efficiency requirements..." RIGHT ON!
By Chip Giannettino on 1/14/2014
'“AM stations should have complete flexibility in choosing tower height and ground system dimensions and normal business forces can be relied upon to influence their owners to seek optimum locations for serving their audiences,” states DLR.' Would that this was the case! --Keeping an AM on the air in some minimal way in order to justify an FM translator is increasingly common. Perhaps it is inevitable, but without sufficient signal, receiver makers don't have any incentive to treat AM any better than they have for the last 20 - 25 years. Perhaps DLR is being diplomatic and what threy really mean is that FCC should bow to the (apparently) inevitable.
By Roberta X on 1/14/2014

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