Mr. Galasso's suggestions about the proposed expanded FM band are based more on compatibility today rather than looking forward to tomorrow. The proposed band is new territory; let's not encumber it with old technology.
Here are my replies to his comments (by section) with which I have issues:
- If digital is the way the world is going, let's not saddle the new band with the kludge that is iBiquity. Allow either analog or digital; not both. Existing radios won't tune the expanded band anyway; converters can have digital decoders built into them; and new radios can have the ability to decode any popular digital signal in use. These radios are available now, and they will get cheaper with mass production.
- The proposed plan calls for a "re-farming" of the AM band leaning towards full-time high-powered stations with wide coverage. This will accomplish a lot of what Mr. Galasso suggests.
- While I agree the translator situation has gotten completely out of control, that is the subject of another proceeding. However, I do agree that translators should not be allowed in the new band.
- There is nothing more wrong with the present frequency and power allocation scheme than what we have today! The original scheme was fine for its day, but that day is long past. The FCC has patched the present scheme as best they can, mainly by adding subclasses of the original As, Bs and Cs, but today there are disparities that are a mockery of the original Table of Allotments.
I've long advocated for a new broadcast band for stations to migrate to and be full digital. An expanded FM band gives us the opportunity to do just that.
Clear Channel Radio/Urban Radio Broadcasting