A Closer Look: the AM Radio Revitalization Order

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This item has been updated with additional or clarified language regarding daytime and nighttime coverage standards, and in the additional proposals section.

More than two years in the making, the long-awaited AM Radio Revitalization Report and Order was released on Friday by the FCC.

Among the new items in the announcement — which included a Report and Order, a Further Notice of Proposed Rule Making and a Notice of Inquiry — there are several items of note, including:

  • Six actions from the original NPRM
  • Several additional proposals drawn from comments submitted to the FCC in a NPRM; and
  • An NOI that poses additional questions about further use of the AM Expanded Band and on maintenance and siting of main studios

Several commissioners issued statements of support for the order. Chairman Tom Wheeler said the order will “ease regulatory burdens on AM broadcasters and address practical problems and interference-related issues that have long plagued AM stations.” Commissioner Ajit Pai released a statement just prior to the order’s release, and Commissioner Mignon Clyburn said the order “acknowledges the realities of the upcoming incentive auction and the need for immediate relief for AM stations.”

Industry execs immediately dove into the lengthy document as well.

“On first blush, it looks like the FCC was truly focused on helping AM licensees survive; either by technical improvement or migration,” Ben Downs, VP and GM of Bryan Broadcasting, told Radio World. “There are enough revitalization elements in this Report and Order to improve the service for most broadcasters.”

AM WINDOW FOR FM TRANSLATORS

One of the more hotly contested issues was centered on FM translators. In the order, the commission adopted a two-pronged approach to enable more AM stations to acquire FM translators.

First, the commission voted to begin a process in 2016 whereby an AM licensee seeking to rebroadcast on an FM translator may acquire and relocate one FM translator station up to 250 miles.

Then, in 2017, the commission will open new FM translator application auction windows (specifically for those AM stations that do not file a modification application in 2016). Class C and D stations will be able to take advantage of the modification window and the auction window first; second windows will be available to all classes.

The translator section of the order eventually will help many more daytime AM stations use 24/7 FM translators that do not sign off at night. Ben Downs emailed RW on Friday, “Today we saw the closing of the daytime-only slum. Every station that has lived through being off the air during half of morning and afternoon drive time is now able to serve their listeners 24 hours a day. That’s a change that would be impossible to minimize.” Translators are the solution that make the most difference to small to medium-market broadcasters, he said.

The report also denied grant of the so-called Tell City waiver and confirms the continued use of so-called Mattoon waivers with an added four-year operating requirement (which states that the relocating FM translator must rebroadcast the proposed AM primary station for a period of four years).

MODIFICATION OF DAYTIME COVERAGE STANDARDS

The FCC hopes to make it easier for existing stations to relocate despite reduced availability of land and expanding city boundaries. Its order modifies daytime coverage standards — for existing licensed AMs only — to require that a station’s 5 mV/m contour encompasses either 50 percent of the area or 50 percent of the population of the principal community. At present, commission policy in effect requires 80 percent. The change does not apply to new applicants or permittees with unbuilt stations; and the FCC gave its Media Bureau authorization to inquire into requested modifications “in order to preserve the limited intent” of this move. It said the change is not intended as a means for AMs to provide inferior coverage to their communities.

MODIFICATION OF NIGHTTIME COVERAGE STANDARDS

Most AMs currently must continue to operate at night even when the rules require them to cut back power to avoid skywave interference. That raised numerous complications. Now the commission has eliminated that nighttime community coverage requirement for existing licensed stations. Further, applicants for new AM stations (and those seeking a change to their communities of license) will have to cover 50 percent of the population or 50 percent of the area of the communities of license with a nighttime 5 mV/m signal or a nighttime interference-free contour, whichever value is higher. That’s down from the current 80 percent.

“We are mindful of striking the appropriate balance between the need to provide relief to AM broadcasters with few siting options … and the need to provide the community of license with some kind of service,” the report said.

As with the daytime change above, the FCC said it would keep a close eye on any station that asks to reduce nighttime community coverage during its first four years of operation.

ELIMINATION OF THE AM “RATCHET RULE”

The commission eliminated the ratchet rule, which required Class A or B AM stations who were looking to make facility changes that would modify its AM signal, to “ratchet back” radiation in the direction of certain other AM stations. The real-world result tended to discourage station improvements, the FCC found, because compliance with the rule often required the modifying station to reduce its power.

ADOPTION OF MDCL TECHNOLOGIES

Since 2011, AM stations have sought waivers in order to use Modulation Dependent Carrier Level control technologies, which vary either the carrier or the carrier and sideband power levels as a function of the modulation level, thereby allowing the licensee to reduce transmitter power consumption while maintaining audio quality and signal coverage. These MDCL control technologies often reduced the station’s antenna input power to impermissible levels.

In an effort to reduce the burden on stations wishing to employ MDCL control technologies, AM stations no longer must file a wavier but must electronically notify the Media Bureau of the station’s MDCL control operation within 10 days after first use.

AM ANTENNA EFFICIENCY MODIFICATIONS

The order reduces the existing AM antenna efficiency standards by 25% as a means to provide relief to AM broadcasters. Some commenters called for the outright elimination of the commission’s minimum efficiency standards for AM transmission, and instead using a minimum radiation standard. But the commission found that that proposal lacked specifics.

ADDITIONAL PROPOSALS

In its 74-page document, the FCC also proposed the following changes in a further NPRM, and is asking for comment on them:

-All Class A stations should be protected, both day and night, to their 0.1 mV/m groundwave contour, from co-channel stations; all Class A stations should continue to be protected to the 0.5 mV/m groundwave contour, both day and night, from first-adjacent stations; and the critical hours protection of Class A stations should be eliminated completely.
-Rolling back the 1991 rule changes that pertain to calculation of nighttime RSS values of interfering field strengths and nighttime interference-free service. The commission proposes to amend the rules to return to predicting the nighttime interference-free coverage area using only the interference contributions from co-channel stations and the 50-percent exclusion method.
-Revisions of daytime protection contours for Class B, C and D AM stations, which the FCC believes will result in greater flexibility to improve their signals.
-Revision of the rule on siting of FM “cross-service” translators to provide additional flexibility .
-Modification of partial proof of performance requirements to reduce the number of measured radials.
-Modification of rules for Method of Moments computer modeling, used to verify the performance of AM directional systems.
-Return of an authorization from any licensee with dual standard/Expanded Band authorizations. There are 25 such “station pairs” left. Licensees would be required to surrender one of the two authorizations within one year of release of a future Report and Order.

The commission also issued an NOI in which it asks how best to continue use of the AM expanded band, including the types of stations that should operate and the technical parameters under which they should be run. The commission also is looking for comments on whether it should relax its rules and policies on maintenance and siting of AM main studios. Radio World will have further coverage of many of these proposals in subsequent issues.

AM advocates felt the order was a long time coming.

LOOKING BACK

Three years ago, Commissioner Ajit Pai, a Republican and at the time a new member of the FCC, told a fall Radio Show convention audience in Dallas, “To me, it’s time to take another look at our AM radio regulations. The FCC last conducted a thorough review of those rules 21 years ago.” He worried then about AM’s overall market share and its particularly dismal performance among younger people. “These younger listeners should represent the future of AM radio, but many of them never tune in,” Pai said then.

Mignon Clyburn, a Democrat and the acting FCC chair at the time, subsequently put forth a notice of proposed rulemaking setting out questions and possible steps toward “AM revitalization.” Our industry has been debating and watching since then.

Many of the items in that NPRM made it into the final order: elimination of the “ratchet” rule, modification suggestions to the daytime and nighttime community coverage rules for existing AMs, wider implementation of MDCL technologies, changes to nighttime interference protections and modification of antenna efficiency standards.

And the biggest topic of contention — which resulted in some very public jousting among commissioners — was the decision about translators.

The back-and-forth over the last few weeks was so pronounced that Clyburn chided the process in a statement. “Though much of the back-and-forth on the best way to provide this relief played out in the press, instead of within the walls of the commission, I am nevertheless pleased that we have achieved what I believe is an outstanding result,” she said. Related:
This AM Owner Gives the FCC Order a C+

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