If you haven't read about or carefully considered the BMC's ambitious proposal that could literally save broadcast radio, keep reading.
The idea of converting TV Channel 6 for use by radio following the DTV transition has been around for a while and suggested by many. An enterprising group of broadcast consultants, lawyers and engineers decided to get busy and start developing the concept into a formal FCC proposal. Calling themselves the Broadcast Maximization Committee and led by Paul Reynolds, Jack Mullaney and Bert Goldman, the group has put together a compelling case. They filed their initial proposal as part of the FCC's Diversification of Ownership proceeding in July. Comments are still being accepted as "late filed" since that proceeding has ended.
The BMC wants to reuse TV Channel 5 along with Ch. 6 to create enough space to migrate all existing AM and LPFM stations to new spectrum. The scheme would also open up more space and coverage for LPFM and NCE opportunities. The resulting interference relief to existing bands that could then be "repacked" would be dramatic.
NEW CHANNEL DETAILS
Let's take a look at their basic plan. TV Channels 5 and 6 would add 12 MHz of additional spectrum immediately below the existing FM band. The BMC envisions creating 117 new 100 kHz channel allocations out of this spectrum called the EXB (EXpanded Band).
One hundred channels between 77.0 and 86.9 MHz would be allocated for AM migration. Four sub-classes of stations would be created to roughly match the existing 2 mV/m primary contour coverage reach of all existing AM stations. Class A-X stations would reach a 30 km primary contour, Class B-X to 60 km and Class C-X to 90 km.
(click thumbnail)Coverage map shows comparison between existing AM station WCNN 2 mV/meter contour in red and proposed class C-X digital contour in blue.
Class Z is reserved for existing class A, 50 kW, clear-channel AM stations with projected primary coverage in the EXB out to 150 km. These migrated operations would use digital-only, 100 kHz channels. The BMC filing includes an appendix that lists all existing AM stations and their projected new channels and classes in the proposed EXB.
The bottom of the EXB at 76.1 to 76.8 MHz would become eight channels allocated for exclusive use by LPFMs. The top eight channels at 87.0 to 87.7 MHz would be added to the existing NCE FM band to relieve congestion for new and existing NCE operations. One channel on 76.9 MHz would be set aside for NOAA/HSD use nationwide.
PAYING FOR THE BIG MOVE
The single most obvious challenge that must be addressed is what to do with the remaining 24 TV stations that have chosen to remain on Channels 5 and 6 with their new DTV operations.
Most all had the opportunity to choose the replacement UHF channel offered for DTV or file separately for one and give up their stake in the old low-band VHF. But for various reasons, they chose to stay put. Come February, those stations will merely turn off their analog transmitters and switch the antenna to their new DTV rigs.
The good news, according to the BMC, is that all 24 can rather easily be relocated to open UHF channels. The bad news is that whoever gets to reuse Channels 5 and 6 is undoubtedly going to have to pay for that use. If television stations are forced to move to another channel by virtue of an imposed new allocation scheme, those stations would have to be compensated.
The broadcasters and engineers I've talked with largely support the BMC proposal, but realize that for there to be any chance of this becoming reality, quite a few rather high hurdles must be negotiated. It's going to take a lot more than engineers and small operators talking with the FCC to make it happen.
Considerable political muscle with help from the NAB and other lobbyists will be needed to convince the commissioners that the broadcast radio service deserves this spectrum more than other users. This comes at a time when the commission seems much more interested in new technologies that would augment the burgeoning wireless Internet revolution.
AIRWAVES ON THE AUCTION BLOCK
The DTV transition was crafted to free unused analog spectrum long allocated to analog TV, and put it up for auction to the highest bidder. It is supposed to generate revenue for the federal government and create opportunities and demand amongst competing new technology players needing spectrum.
With that mindset, it would seem the commission would be more inclined to put a price on Channels 5 and 6 to compensate those 24 DTV stations that must relocate, and then auction the spectrum off instead of merely giving it back to broadcasters for free.
On the other hand, the history of spectrum auctions has not been the cash flowing bonanza of success the commission had been hoping for. Witness the collapse of the Iridium satellite phone service. It produced little income and the need to re-auction the spectrum for much less money.
Auctioning off Channels 5 and 6 to the highest blue-sky bidder that could easily fail may not be the prudent thing to do here. It could be that this spectrum would be best used to support and improve an existing beleaguered service with almost 100 years of legacy value and public service.
DO MORE STATIONS EQUAL LESS MONEY?
Unfortunately opening up a lot of new spectrum and opportunities for more stations always means more dilution of ratings and revenue potentials.
Existing licensees are almost never receptive to such proposals. Docket 80-90 taught us that lesson all too well. And now we are already facing the prospect of doubling or even tripling the total inventory of FM program offerings with the new HD2 and HD3 channels.
The radio industry is a complicated mix of both large- and small-market interests as well as both private and publicly owned stewardship. Certainly the smaller markets and more marginal facilities in terms of coverage, including LPFM, will enthusiastically welcome the BMC proposals. The larger groups and major-market stake-holders with successful AM stations may not be so enthusiastic.
Bert Goldman of the BMC anticipates that and realizes those players will need to be lobbied hard to become convinced of the long-term benefits. He thinks 90 percent of existing FMs will support the plan and perhaps 60 percent of the Class A AMs would be willing to relocate to the EXB. That would leave the remaining AM stations a much cleaner band with much better fringe and skywave coverage.
The NAB traditionally has lined up behind their larger and more influential group members when faced with making tough and controversial choices. They tend to follow the money, or at least the interests of the largest audiences being served.
So far, the NAB has been on record as saying they oppose any plan that would force DTV off Channels 5 and 6.
SORRY, NO VACANCY
Perhaps the most compelling part of the BMC proposal is that it presents a very real solution to the over-crowding and interference quagmire the FCC has unwittingly created for both AM and FM over the years.
Nobody disagrees that the AM band has become virtually useless at night, except for the 50 kW powerhouses. And the ever-increasing noise levels make it tough to hear even good signals in many locales during the day.
All of the dockets that have created more opportunities for more stations, all within the same original band limits and channel bandwidths, have essentially filled up all the available rooms at the inn. Yet there is still a ton of pressure for more stations every time a new NCE, translator or LPFM application window has opened.
And the pressure is unrelenting. The LPFM service has yet to fulfill the promise of its original goals or intentions. Most large population centers that would benefit the most have no LPFMs because of present spacing rules. We are now facing the possible elimination of third-adjacent and relaxation of second-adjacent protections on FM as a way to solve that problem.
But with the advent of HD, relaxing interference protections increases the prospects of even more interference. Clearly this madness of doing "business as usual" must stop or the FCC itself may become the primary contributor to the continued erosion and eventual demise of broadcast radio.
(click thumbnail)Map showing spacing requirements for new spectrum channel allocations
BROADCAST RADIO MAY BE BEST CHOICE
There is a silver lining for radio in the DTV cloud hovering over Channels 5 and 6.
The BMC points out in its filing that low-band VHF does not work all that well for DTV channels compared to high-band VHF and UHF. Impulse and other noise, as well as skip propagation, degrade DTV performance. Several key studies back that up. Most savvy TV engineers knew that, and as a result most low-band TV stations opted to switch to their UHF assignments for DTV.
These same characteristics, along with the longer wavelengths of 76 to 88 MHz, also make this spectrum less suited as a place to put wireless Internet technologies intended to serve small handheld devices. These channels are thus less attractive and less valuable for such applications if they were to go to auction.
If an acceptable plan to compensate those existing 24 DTV stations for moving to UHF substitutes can be struck, broadcast radio could be the only serious contender for this spectrum. It's entirely possible some of the 24 might opt to vacate Channel 5 and 6 on their own after they get a full-time opportunity to evaluate DTV performance starting in February.
On the benefit side, the BMC proposal offers a solution to a problem that is likely to cause more angst and get a lot more attention in the next year or two. Simply put, radio's digital transition needs a better chance of succeeding. Despite iBiquity's and HD Digital Radio Alliance's recent proclamations that HD Radio is doing well, there is almost no demand for HD Radio in the consumer marketplace. A lot of work and creative thinking remains if radio is to have a successful digital future.
Moving AM stations to the new EXB with digital performance along with all LPFMs would give those stations a huge shot in the arm, although it would take perhaps up to 10 years for radios with the new band capability to reach any kind of useful critical mass for consumers.
An immediate benefit for NCE operators would be the removal of the restrictions on NCE channels operating in TV-6 areas. These have greatly limited NCE station coverage potentials. After Channel 6 is vacated by TV, hundreds of upgrades and new stations could be accommodated in the existing NCE band by itself, in addition to those in the eight additional new channels proposed.
All existing FM stations would be able to reclaim real fringe coverage lost to translators and LPFMs that have been shoehorned in. That's going to become even more important if and when the 10 dB digital power increase is approved.
One large unknown in the BMC proposal is what kind of digital modulation standard would ultimately be used. The BMC wants to create 100 kHz channels to be able to accommodate the entire AM inventory for migration, saying that 100 kHz is adequate and more efficient to serve that purpose. Nothing is being said about supplemental channel capacity or if iBiquity would be receptive to such a fundamental change.
We wonder if the AM service can remain viable long enough to be in any position to be lobbying for an entire new home for every occupant. Increasingly, more AM formats are being migrated to HD2 and HD3 channels on sister FM stations to achieve an easy "digital upgrade." That might diminish the need for the AM part of the BMC plan.
The prevailing NRSC-5 HD Radio standard still uses the 200 kHz FM channel and mask. IBiquity has staked its future and success of HD on the present standard. Changing it to work in half the bandwidth for the EXB could create early obsolescence for all of the HD receivers in use at the time this proposal might be adopted. The BMC does mention the compatibility of the DRM system for VHF use with 100 kHz channels in its filing. As of this writing, they are saying it would be best to let the FCC decide this issue when the time comes.
Even before the FCC commissioners and staff will give serious consideration to the BMC proposal, it seems likely that the NAB and the major group owners would have to mostly buy into it as a worthy idea. Beyond the need to relocate those 24 DTV stations, undoubtedly this will be the biggest challenge of all.
To get more solid support and momentum moving for their idea, the BMC needs to enlist the services of additional high-profile industry experts who have close connections with the NAB, major group and FCC decision-makers. Effective lobbying is still the best grease to lubricate the wheels in Washington, and it is how most FCC initiatives find their way to ultimate adoption.
The initial BMC proposal is by far the most comprehensive and persuasive plan yet presented that would give the broadcast radio infrastructure a much needed booster shot to remain a strong and vibrant part of the American cultural experience. It's a brilliant effort for getting the conversation started.
Repurposing 76 to 88 MHz for radio would certainly go a long way to resolve band crowding and AM interference issues and make it easier for radio's digital transition to succeed. But those arguments may not be as compelling or persuasive for the commission as selling those channels to support some other promising new technology initiative. It will be up to a concerted BMC effort, with support from the overall industry and the NAB, to convince the commission that broadcast radio is the best use of this spectrum for the foreseeable future.
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If you haven't read about or carefully considered the BMC's ambitious proposal that could literally save broadcast radio, keep reading.