“Do no harm.”
That’s the first point made by iHeart officials about AM
revitalization in a recent presentation to one of the FCC chairman’s legal advisors. The company owns the largest number of radio stations in the U.S., including
239 AM signals, or 5% of the total licensed AMs in the country.
Our Leslie Stimson noted this and other recent ex
parte actions. Below is more info about it.
On Oct. 28, Jeff Littlejohn, the executive
vice president of engineering & systems integration of iHeartCommunications
Inc. (formerly Clear Channel Communications), Jessica Marventano, senior vice
president of government affairs for the company and attorney Marissa
Repp met with Maria Kirby, legal advisor to FCC Chairman Tom Wheeler.
Below is the text of iHeartMedia’s full public summary of the meeting,
as filed with the FCC:
Littlejohn’s responsibilities at iHeart include oversight of the technical operations
of iHeart’s 239 AM radio broadcast stations as well as the innovative
iHeartRadio platform and the Total Traffic + Weather Network. Mr. Littlejohn’s
contributions to the industry were most recently recognized by his being
awarded the NAB Radio Engineering Achievement Award in 2014.
As set forth in iHeart’s Comments and Reply Comments in MB Docket No. 13-249,
iHeart supports the expeditious adoption of many of the tentative proposals set
forth by the Commission in its Notice of Proposed Rulemaking (“NPRM”) in
that docket. In his meeting with Ms. Kirby, Mr. Littlejohn emphasized the
Do No Harm. In an industry
already hampered by interference, Mr. Littlejohn asked that the Commission be
guided by a “Do No Harm” principle when considering changes to the AM band. The
laws of physics that govern AM stations have not changed, thus any change in
regulations that would cause increased interference would hurt a band already
suffering from interference issues. Therefore, the Commission should be
extremely careful in evaluating any proposals that could have the effect of
increasing interference to AM listeners.
Translator Window. Mr. Littlejohn noted that a large number of radio
listeners never sample programming on the AM band, with AM listenership overall
going in a downward trend. In iHeart’s experience with FM translators
rebroadcasting AM stations, the public has been exposed to AM programming,
thereby increasing AM listening, either through the FM translator, or by the
consumer tuning to the newly discovered AM signal. Moreover, the difficulty of
AM signals penetrating into buildings, particularly office buildings, is a
universal issue for all AM stations, which can be addressed by an associated FM
translator. As all AM stations face these impediments, all AM stations should
have equal access and equal priority in an AM-only FM translator window that is
opened quickly to address these universal needs. iHeart furthermore supports
the NPRM’s tentative conclusions to limit the award to one FM translator
per AM station in such a window, to encourage the goal of each AM station obtaining
an FM translator, and to permanently link window-awarded FM translators to the original
AM station, to discourage speculative applications and to avoid consumer
confusion as to where to tune for the AM programming.
All-Digital Operation. Mr. Littlejohn noted that initial testing of AM
alldigital operation (in lieu of AM hybrid mode) has shown promise for
replicating analog coverage. However, Mr. Littlejohn explained that more study
is required on the impact of alldigital AM operation on adjacent analog
signals. Moreover, currently, less than three percent of radios are equipped
with HD digital receivers. Thus, while iHeart continues to support the grant of
all-digital authority for AM stations on an experimental basis, it would be
premature for the broad implementation of all-digital authority.
Enforcement of Part 15 Interference Rules. Mr.
Littlejohn noted that many commenters in the AM Revitalization proceeding have
called for increased enforcement of existing Commission Part 15 rules to
address interference to AM signals from non-broadcast sources. iHeart supports
those views, and in particular, would find valuable Commission involvement and
mediation when AM stations bring to the Commission’s attention interference complaints
from sources such as power utilities, which often require education to resolve.
Possible Further NPRM Matters. The Commission’s NPRM
noted that suggestions to reduce interference protections to existing AM
stations would require additional comment, research, and analysis. On this
point, Mr. Littlejohn noted that a preliminary analysis of suggested proposals
to reduce interference protections for Class A AM stations could result in an
average of 8 million listeners per Class A station being susceptible to
receiving interference. Such a result would be contrary to consumer
expectations of continued listening. The principle of “Do No Harm” should guide
the Commission in any future consideration of such proposals.