The author is a lawyer with Fletcher, Heald & Hildreth. This commentary originally appeared at CommLawBlog. Radio World welcomes commentaries with a variety of viewpoints from numerous sources.
Late on Friday, October 5, the Federal Communications Commission released a Second Further Notice of Proposed Rulemaking in a five-year ongoing effort to “revitalize” the AM radio broadcast service. The new proposals continue a trend toward allowing higher power operation by smaller stations, by reducing nighttime signal protection for some 60 Class A AM stations located in the continental United States and 16 stations in Alaska. The end result would be less wide area coverage and more local radio service to the public.
To understand why the FCC is considering this action, it helps to understand a bit of the science behind AM signal propagation. AM radio signals travel through both the ground and through the air. At night, the airborne signal component (“skywave”) is reflected back to the earth from the ionosphere — a layer of the atmosphere extending from about 50 to 600 miles above the earth’s surface. The reflected signals may come back down to earth hundreds, if not thousands, of miles away from a station’s transmitter. Class A AM stations — formerly known as “clear channel” stations (no relation to Clear Channel/now iHeartMedia) — are powerhouses, transmitting with 50 kilowatts of power 24 hours a day – 200 or more times the power of the smallest AM stations. You may know of some of them, including historic voices that still have three-letter call signs: WGN and WLS, Chicago; WOR in New York, WBZ in Boston, WBT in Charlotte, WSB in Atlanta, WJR in Detroit, KYW in Philadelphia, WWL in New Orleans, WHO in Des Moines, KSL in Salt Lake City, KOA in Denver, KGO in San Francisco, and KNX in Los Angeles (apologies if we left out your favorite station). Once upon a time, their signals were fully protected from interference at night and boomed across the land, keeping us connected us with civilization as we chugged along remote rural highways in our cars and trucks and perhaps spawning a lifetime of fandom for a far away major league baseball team to whose games a young boy surreptitiously listened on a transistor radio after bedtime.
Signal reflection doesn’t work so well during the day, so the FCC has allowed other stations to occupy the Class A frequencies in other markets. But those stations have to curtail power during “critical hours” (two hours before sunrise and after sunset) and often have to reduce power to nearly nothing or shut down altogether at night. In today’s 24-hour-a-day, nonstop world, not being able to reach an audience at night is a losing proposition; so the FCC has yielded to constant pressure over the years to allow more power and longer hours of operation by those “other” stations, at the expense of long distance reception of Class A signals.
Now the FCC is proposing to go further, rolling back some previous restrictions on non-Class A AM stations and perhaps eliminating whatever remains (and it’s not much) of the protection of far-away reception. Under the proposals, which are sufficiently complicated that you should talk to your engineer if you really want to understand the details, Class A AM stations would be protected only within a higher strength signal contour (and so within a smaller area) than they are now; at least some, if not all, skywave protection would be eliminated.
While some nostalgia buffs might weep at the final demise of long distance AM service, the FCC asks some thoughtful questions that merit serious attention if you want to get involved in this rulemaking. These questions invite comments as to whether long-distance AM radio service is an anachronism that must now go the way of the dodo or has continuing important value to national security that needs to be preserved.
For example, Class A AM signals are now protected to their 0.1 mV/m daytime service contour. Is that a meaningful signal level? Can today’s AM receivers pick up that weak a signal anymore, particularly with all the radiofrequency “noise” generated by LED and CFL light bulbs, power lines, and electric motors? If no one can receive such a weak a signal, why protect it?
What about programming services? Although Class A AM stations may broadcast wide area signals, do they provide any programming of regional or national interest, or do they compete only for hometown audience ratings along with weaker stations in their local market? If they don’t provide programming of widespread interest, why do we need their widespread signal? And even if some of their programming is not strictly local, we now have satellite and Internet-based audio services with increasingly reliable nationwide reach; so is it worth crippling many small town and/or minority-owned stations to make room for service that doesn’t exist or isn’t needed even if it does exist?
But there is another side of the coin.
Class A AM stations provide critical links in the nationwide Emergency Action Notification (“EAN”) system. They serve as Primary Entry Points for Presidential and other emergency messages. Federal money has been spent to provide backup power to these stations and to harden them against the huge electromagnetic pulses that could result from a nuclear attack. In an emergency, broadcasters all over the country can pick up Class A AM signals on their EAN receivers and get emergency information out to their listeners; and often the public can tune in the distant signals directly. Are we sure that the recently established Internet-based IPAWS emergency alert system is reliable enough to deliver emergency information to every broadcast station and to reach the public in a really serious disaster, especially through small stations that aren’t built like concrete fortresses?
And what about FM translators? If you ask any AM station that has to go dark or cut back to flea power at night, you will likely hear that an FM translator is what they really need — never mind more throwing AM nighttime power into the cacophony of nighttime interference that isn’t getting better and will probably get worse. If FM signals are the better answer, why are we spending all this time and effort trying to balance competing interference, diversity, and economic interests in the AM band? Are we really “revitalizing” AM, or are we walking around in circles?
What is your answer to the conundrum of how to make sense out of the AM band and to provide relevant programming services to the largest number of viewers while creating an economic environment in which broadcasters can realistically survive? If you have ideas, you will have an opportunity to tell them to the FCC in comments, which will be due 60 days after the proposals are published in the Federal Register. Watch Commlawblog.com for a post when the comment deadline is announced.
