are pleased to see attention being paid to the question of what changes might
be made in radio regulation to enable AM broadcasters to plan for a future. We
believe that AM radio is being held back from realizing its best uses, now and
in the future, by long-obsolete technical regulations.
consulting engineers, AM radio station owners rely on us for studies on how
their facilities can continue to operate when they are forced to move
transmitter sites and, sometimes, how their coverage can be improved with
antenna system changes.
this capacity, we can see how the present technical rules of the FCC impair,
rather than assist, AM radio in remaining relevant while filling roles where
its service will be needed in the ever more diverse technological marketplace
of the future.
present rules, we believe, are based on principles that may have reflected the
situation in the 1920s and 1930s, when AM radio was the only over-the-air
electronic medium, communities consisted of centered population areas, rural
areas were sparsely populated and man-made noise levels were low. But they fall
short of what is needed today.
rules have their roots in a time when an AM radio station provided one of only
a few sources — if not the only one — of electronic entertainment and information
within its coverage area. Most AM licenses were valuable business franchises. It
was the FCC’s job to see to it that as many communities as possible were served
by them as well as possible.
AM radio is but one of a multitude of electronic options for its potential listeners,
and most stations are in survival mode searching for audiences to serve with at
least modest profitability.
is more. The rules have been changed over the years with the focus on reducing
interference between stations instead of improving coverage. But now AM
stations are in “straightjackets” imposed to restrict stations from interfering
with each other but that instead severely limit their ability to improve
coverage or to make transmitter site changes.
see examples of how AM broadcasters are hampered in providing service by
obsolete rules all the time, when AM stations are forced to move.
typical situation arises when an AM station loses the lease on the transmitter
site it has occupied for decades and comes to one of us wishing to build a new site
more centrally located for its listeners (often minority and/or foreign language
have to make them face the reality that the station’s power must be reduced to
avoid increasing “grandfathered” signal overlap with other stations. A tower of
the height that can be approved for a building permit locally will not meet the
FCC’s minimum efficiency requirements. The city of license will have to change
because coverage requirements of the rules cannot be met for the present one.
to make matters worse, the city of license change is going to be difficult, if
not impossible, because it will be caught in the “net” put in place to stop FM
stations from moving out of rural communities closer to large cities — a
situation nothing at all like what the AM station needs to do.
with the unnecessary requirements makes lots of expensive work for consulting
engineers, too. We would like to be able to provide the services that are
really needed for the survival of AM radio stations for much lower costs than are
possible in the present regulatory environment.
There needs to be a totally fresh look at
what the AM radio technical rules should be, taking into account the flexibility
stations require to best serve the population segments they desire in the expanding
universe of electronic media.
• Eliminating the city of license coverage requirements to allow stations
to use a marketplace approach to providing service to their actual audiences;
• Eliminating antenna minimum efficiency requirements to allow stations
flexibility in tower height as long as the maximum radiated field can be known
for the actual transmitter power;
• Eliminating the minimum ground system requirements for AM antennas to
allow stations flexibility in choosing new transmitter sites when they have to
• Increasing the daytime protected contour level from 0.5 mV/m to a
higher value more representative of man-made noise levels to allow higher power
for AM stations;
• Returning the daytime first-adjacent channel protection ratio to 1:1
and eliminating the nighttime first-adjacent channel RSS contribution since the
very wideband radios that were posited when the present rules were developed never
• Returning to the 50 percent exclusion method of calculating nighttime
interference-free coverage areas, since the 25 percent method adopted in 1991
has served to hamper coverage improvement more than to decrease interference.
the pending rulemaking to eliminate the “ratchet clause” that stifles
improvement of nighttime coverage by AM stations is awaiting FCC action to take
care of that problem.
it is time to consider whether the nighttime 0.5 mV/m skywave coverage areas of
Class A stations provide service that warrants curtailing the nighttime operations
of other AM stations, now that direct satellite programming is here too.
do not wish to discourage long-term thinking about how AM broadcasters might be
granted new spectrum for replacement of their present service — such as the TV
Channel 5/6 idea that has been receiving a lot of attention lately — but we do
not see that proposal becoming a reality for many years, if ever.
is a lot that can be done now, including some non-technical rule changes we
haven’t included here, to improve the viability of AM stations that have a chance
to survive in the meantime. We say, “Let’s get to it.”
Ron Rackley is a partner in the firm of
duTreil, Lundin & Rackley. Ben Dawson is a partner in the firm of Hatfield
& Dawson. In naming the duo to receive its 2006 Radio Engineering
Achievement Awards, the NAB described them as “icons in the field of AM
broadcast antenna system design and optimization.”
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