It’s not often a
filing to the FCC is dedicated to someone who’s passed away.
Comments about AM revitalization from the Broadcast Warning Working
Group honored the late Larry Estlack, one of its members and the
director of technology for the Michigan Association of Broadcasters.
late Larry Estlack, shown in a Facebook page in his memory. Search
“Friends of Larry Allen Estlack.”
is all about EAS, so it has an interest in AM. You probably know most
if not all of its members: Adrienne Abbott,chair of the EAS
Nevada State Emergency Communications Committee; Clay Freinwald,
chair of the EAS Washington State committee; Suzanne Goucher,
president/CEO of the MaineAssociation of Broadcasters; Barry
Mishkind, the veteran engineer and industry journalist; David Ostmo
of the Sinclair Broadcast Group in San Antonio, Texas; and Richard
Rudman, vice chair of the EAS California SECC.
write that AM is “an invaluable national resource” but that the
band needs a “resurrection” and not just revitalization. They
noted that EAS was enhanced when some AMs became part of the Primary
Entry Point system in 1997 and that recent hurricanes demonstrate
what can happen when communications are slammed and officials need a
reliable way to talk to the public. AM’s simplicity and reliability
are assets then. But what to do?
power increases aren’t the answer; they “will eventually be
negated by the still rising tide of RF noise in the band,” BWWG
writes. Nor will digital transmission will overcome this. “Masking
of power line-radiated noise is only effective until the noise rises
to a level where Bit Error Rates exceed their ability to function and
the digital signal vanishes.”
group reiterated what many have been saying: The noise floor has
increased sharply, stealing signals and audiences. It pleaded with
the FCC to enforce Part 15 rules and support delivery alternatives
other than broadband over power lines.
high-voltage power grid infrastructure generates its own “unique
but devastating” noises, a problem that seems to be getting worse.
Further, new high-tension lines near directional transmitters act as
long-wire antennas that “broadcast” harmonic noise; BWWG says we
should hold utilities accountable.
over-modulation causes “splatter” to adjacent channels; older
transmitters and poor processing practices can mean problems 20 kHz
away. The group thinks the FCC should reduce negative peak modulation
to 96 percent for AM and clarify wording in Part 73 on this topic.
should allow a 4–5% margin for error for settings, power supply
issues and measurement errors. This will provide a better spectral
median strip between broadcasters vying for what most audio experts
believe is a race for a mythical audience bent on searching for the
loudest signals on the band. … It is time for the commission to end
the destructive AM modulation race that some broadcasters continue to
pursue, despite solid technical data that such a race has no basis in
group throws up its hands on the topic of devices that make noise
like computers, switching power supplies, compact fluorescent lights
and fish tank thermostats; it says Part 15 controls are not
effective, but: “We have no answers, only questions about why these
sources are still allowed to contribute to the damage being done to
the AM band.”
BWWG is (relatively) restrained about HD Radio but thinks “it may
be time for an honest and rigorous revisiting of IBOC for AM to see
if turning it off can help revitalize this troubled band by giving
amplitude modulation signals ‘breathing room.’” It also cites
bandwidth standards adopted by some broadcasters that reduce analog
audio fidelity as well as “compromise advantages” that favor
digital but hurt coverage of adjacent-channel stations. Blending and
noise floor problems exacerbate the digital situation.
group’s comments are well worth reading. (I’ve saved them for you
further want to see receiver standards that mandate or encourage use
of synchronous AM detection or other detection methods that can help
stave off electrical noise. “The commission regulates standards for
receivers in other services. Why not do this as a key component for
AM band resurrection?”
BWWG suggests that Congress should not allow manufacturers to market
FM-only receivers, even in cars. It feels that Congress could do this
as part of a national public warning strategy, treating AM as a
national emergency resource.
FM translators are part of AM revitalization, BWWG continues, tie
each to an AM station and specify that the license is
non-transferrable. Allow installation of translators at AM
transmitter sites; and make it clear that a translator can only be on
the air if the AM is on the air, except for night operation by
says the FCC should not apply the “ratchet rule” in certain
cases, to avoid unintended consequences. (For more on this, see
The group further asks that the FCC require stations to certify that
reports for tests as described in Section 73.44 have been carried out
at least once a year. And they suggest making better use of the band
above 1610 kHz: “Directional array AM (DA) stations literally
running in ‘sardine can’ or narrow local AM channel conditions
should be given preference in the expanded band, as well as for other
options that will allow for power and coverage increases.”
FCC should explore making different use of 530 kHz, too. Should the
frequency be allocated to bring back “clearer channel” stations
that could bring AM coverage, “especially for major emergencies,”
to areas where service is missing?
would be permitted Pre-Sunrise Authority at 500 watts, Post-Sunset
Authority at 500 W at least until 6 p.m. Protection coverage for
Class A stations would be reduced, to help AMs that are running “at
or near financial failure an opportunity to serve a wider audience.”
Further, AMs should be allowed to use any antenna/transmitter, with
no minimum efficiency, basically as long as annual NRSC measurements
show compliance; but BWWG wants the FCC to stiffen and enforce rules
against stations running more than 10 percent over.
also suggests an upgrade preference for licensees that promise to
maintain emergency power generation and other “resilience measures”
and that commit in writing to devote resources to emergency public
information as needed.
group concludes by saying no ideas filed with the FCC will produce a
total cure for the AM patient. “Full recovery will require
aftercare by responsible licensees offering quality local programming
and public service that really matters to the public, and to the
overall public safety emergency communications picture.”
think the Broadcast Warning Working Group offers great ideas here,
though I’m dubious about the chances (and advisability) of a
government mandate. Usually the market knows best.
do you think? Comment below. To see more opinions about AM, visit
radioworld.com/amcomments.To read an obituary of the late Larry Estlack, go to our website
and enter keyword Estlack.