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Opinion on AM Revitalization: From Hard Facts to Whimsical Fantasy

The latest comments filed on 13-249, the FCC’s AM revitalization proceeding, make for some very interesting reading. From hard facts to whimsical fantasy, you can find it.

The author is owner of WGTO(AM) and W266BS in Cassopolis, Mich. His commentaries are a regular feature at radioworld.com. Opinions are his own.

The latest comments filed on 13-249, the FCC’s AM revitalization proceeding, make for some very interesting reading. From hard facts to whimsical fantasy, you can find it.

At the top of the facts column would be the well-written and well-researched comments of Kintronic Labs. Obviously a leader in the field of AM RF, Kintronics makes a most excellent case for AM receiver improvement with documented demonstrations of what the medium can sound like if only the FCC would make a move on minimum standards for receivers and a crackdown on Part 15 violators. It suggests bandwidth of 10 kHz typical, adaptive, with a minimum nominal bandwidth of 7.5 kHz signal-to-noise ratio: minimum 55 dB, preferably 60 dB and sensitivity: –120 dBm for a signal-to-noise ratio (SNR) of 10 dB.

[Read the Kintronic filing.]

For sheer entertainment take a close look at the comments filed by the AM Radio Preservation Alliance, which is made of the AM heavies like CBS, Tribune, Cumulus and iHeart. Parts of this document in my opinion show how lobbyists and creative attorneys can sell snake oil and make it sound like a good deal. They want to preserve night and critical hours AM protection for Class A stations. OK, we get that, but some of the wording to boost that position is laughable. WBT in North Carolina is used as an example of how “great harm” will come to some stations if critical hours protection is lessened. They state that their analysis shows WBT would lose 31% of the listeners now in the 0.1 millivolt contour in the morning hours. Yes! It says the POINT ONE contour. Really? How many people actually listen to an AM station at 0.1 millivolts unless they are carrying a field strength meter for conductivity measurements? I submit the answer is very few if any.

[Read the comments of the AM Radio Preservation Alliance.]

James Potter in his reply comments does a great job of taking the alliance people to task. It’s almost embarrassing how ridiculous parts of the alliance comments look after Potter pulls back the curtain to show what’s really going on. Oh, yes, and he points out how if CBS is so behind serving the public with Class A stations, why are they selling the whole radio group? To be fair the alliance does summit a very nice exhibit on the possibility of interference between stations using the proposed daytime protection standard changes from 0.5 to 2 mV.

[Read the comments of James Potter.]

IHeartMedia has pushed a massive PR campaign to get average listeners to make comments in support of keeping full protection for Class A stations. I have reviewed many of the comments that were spurred by the iHeart petition. But I also must comment that when you see or hear the ads that ask for support of the petition it sounds like someone is about to turn off AM radio. The petition over-speaks the situation, making it sound like every 50 kW station in the country is going to disappear if the FCC goes forward with proposed changes. I see no real change in the primary footprint of these flame throwers. Yes, some nighttime coverage will go away and be picked up by local stations. That is correct but the emotion here sounds like the end of the world! IHeartMedia is trying to turn its listeners into lobbyists with lots of emotion and little fact. Good luck with that.

WOLF Radio makes a good case in their comments about the proposed power increase for AM stations. A great analysis of how the impact on stations must be looked at from several points of view and how Class C stations could really be hurt unless they are given special treatment.

Now if you want to see some real “spin” look, at what was filed by DTS Inc., owner of HD Radio. They want the expanded band to be used for pure digital operation. They also want to make the sure the commission does nothing that will slow the rollout of digital AM. I guess they don’t know that most AM operators may feel the AM digital train has not only left the station but has already derailed. DTS wants the FCC to be cautious on receiver standards so as not to harm the DTS rollout. What that really means in my opinion is they don’t want any better analog bandwidth that will better show the buzz that is the trademark of hybrid digital service. Again, look at the reply comments of James Potter. He takes DTS to the woodshed for some real education.

[Read the comments of DTS Inc.]

Lots of comments on the main studio rules.

The main studio rule will no doubt be relaxed, and in some cases that might be a good thing; but little by little the FCC has allowed stations to abandon the towns they are licensed for. Time and time again we see suburban stations built or bought up and run as “rimshots” into a large city and this even includes running simulcast on two or more suburban stations to mimic urban coverage of a station licensed to the actual city they WANT to cover. In Chicago we have AM stations that got the CP by posing as a new service to a suburb of Chicago but were built to cover the actual city of Chicago. The only mention of the licensed town is the hourly ID! No local-based programming, no studio in the actual town and no community input. But when they sought the license they had page after page of history on the small town and how they would be a big part of it if granted the license. So much corporate BS! It would be nice if the FCC actually made these stations carry programming that really did reflect the city of license. I mean for real, not the syndicated stuff many of us run and call local issues programming. The main studio is not the real problem; the lack of responsiveness to the actual city of license is the bigger issue.

There is a lot for the FCC to look at, and some serious money may be riding on the forthcoming proposals. And you have not seen the end of posturing, persuading and badgering to get everyone’s position out in front. It’s a real show and the admission is free!

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