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BMC Hopeful About EXB Proposal

Two years later, Goldman says new band is getting a second look

DALLAS — The possibility of creating a new broadcast radio band using spectrum where TV Channels 5 and 6 had aired analog audio might seem unlikely, for a number of practical and political reasons.

But Bert Goldman, a leading proponent, says that though the idea is moving ahead slowly, he senses growing comfort with it among some brokers and regulators.

An important reason, he says, is that with many AM stations struggling, owners are looking for alternatives to make their assets more competitive.

Bert Goldman. ‘We’re hoping … that this is going to take off and we’ll get a Notice of Inquiry out of the FCC to bring the debate to a formal position.’ AMs would not be the only beneficiaries. The idea for an expanded FM band, or EXB, was advanced by a group of prominent consulting engineers, the Broadcast Maximization Committee; it proposed allowing AMs, LPFMs and noncommercial stations to move voluntarily to 76–88 MHz, just below the existing FM band, after the DTV transition (see “Could EXB Band Be Your New Home?” Sept. 10, 2008).

The idea of using that spectrum to expand radio had surfaced before, but the BMC laid out a specific migration plan supported by an engineering study and including a significant component aimed at benefitting AMs.

Goldman is vice president of Dallas-based Independence Broadcast Services and a member of the BMC. He discussed the state of the EXB proposal and of AM in general with Radio World News Editor and Washington Bureau Chief Leslie Stimson.

RW: What’s your general feeling about the state of AM? An executive who talks with group heads told me recently they’re wondering if AMs are going to be around in five years because they’re costing owners more money and they’re not the assets they used to be.
Goldman: Some AM stations are more valuable for the land they occupy than for the radio station itself. We’re starting to see a lot of attrition, especially in smaller markets. There’s just not enough return on the investment there.

I think AM in the U.S. will remain for a number of years, but unless something can be done to make it more viable and competitive with other forms of audio entertainment, it may become less and less relevant. …

RW: The AM noise floor is rising, due to man-made noise. WOR’s Tom Ray recently suggested in our pages it may be time to redefine AM’s service contours, saying that in many locations, listeners can’t listen reliably to an AM station much beyond its 2 millivolt contour, “never mind the half millivolt.”
Goldman: I think Tom may have been generous. In my work in Texas, in urban areas like Dallas and Houston, usable, reliable audio requires at least 5–8 mV/m. In downtown areas, that’s more like 8–10 mV/m. Unfortunately, just because the urban signal levels must be high, if one is looking at the rural service, then signal down to about a millivolt still works for the most part.

I’m not sure how we’re going to be able to redefine AM service contours when it comes to allocation and interference criteria. AM coverage maps will still show coverage down to 0.5 mV/m, but they’ve never been considered “real.” When I show coverage in urban environments I show the 2 mV/m contour as being the station’s coverage for daytime and at night either NIF [Nighttime Interference Free] or 1/2 NIF as the night coverage depending on where the station is located and what frequency it’s on. …

In the end, I don’t really think that shuffling power and protections and coverage definitions is much more than a Band-Aid. What’s necessary is a whole new band for AM stations to go to and operate in a digital format.

RW: How are the Broadcast Maximization Committee efforts going?
Goldman: As we expected, it’s going slowly, but we’ve noticed that there has been a steady increase in interest by the broadcast community in general and even some interest in some areas at the FCC.

Our plan calls for all AM stations who want to [to have] the opportunity to relocate to this new band with 100 kHz digital bandwidth. We have done engineering studies to show how this could work and believe it could be a huge benefit to the floundering AM band. It would finally give AM stations a competitive platform to operate from and could cut operating costs substantially for some operators.

Interestingly, Tom Ray suggested that the 2 mV/m contour is the real contour, and we agree, since the contours we reproduced for our engineering study to move the existing AMs was the 2 mV/m contour. The big difference is that the 2 mV/m day contour of the subject station would be the operating contour for both day and night, and depending on the digital platform used could support between one and three additional program streams.

Even with all AMs moved over to this new band, there would still be a large portion of spectrum that would be set aside for noncommercial and LPFM stations. Moving some LPFMs from the FM band over to the new band with a promise of better coverage could also work to unclutter the FM band. From my experience, many LPFMs are not very happy with their coverage due to the incoming interference from full-power stations. LPFMs would be fully protected in the new band.

RW: FCC Commissioner Mignon Clyburn recently proposed that the commission explore options to help radio, like using Channels 5 and 6 for radio, and I wondered if that signals some movement at the agency on this idea.
Goldman: We have heard that there is some interest by some at the commission in our proposal, and as you might expect less enthusiasm by others.

We always knew this would be a long process, but as time goes on, we and the commission are finding that Channels 5and 6 are not particularly good places to put DTV, so the physics and the public interest points to using that spectrum to relieve the huge amount of pent-up demand for radio facilities.

RW: Where does the proposal stand?
Goldman: We’ve filed on a number of dockets. For example, in the LPTV docket, the FCC wants to allocate LPTV stations in Channels 5 and 6; we don’t think is a good idea, either for them or for us. We’re hoping we have more interest at the commission from people like Commissioner Clyburn and we can get some steam going here to get interest.

RW: Will that happen naturally as the FCC focuses more on spectrum?
Goldman: I think so. It takes the commission awhile to get comfortable with an idea. At first, we were hearing, “Why would you want to even think about that?” Then as time went on, we started hearing from various portals at the FCC that “Maybe this isn’t such a bad thing. The television stations aren’t having much luck with it. Maybe this is a way to relieve some of the pressure of pent-up demand for radio stations. Maybe this is a way we can save the AM band from extinction.” In fact, a couple of people at the commission that we’ve talked to have done a 180 from when we first talked to them about it.

We’re hoping … that this is going to take off and we’ll get a Notice of Inquiry out of the FCC to bring the debate to a formal position.

RW: What kind of feedback are you getting from AM operators?
Goldman: AM operators are extremely interested in this proposal, but many are so beat down that they don’t know how they can have a voice to support it.

To my knowledge, there is no national association that represents only the AM operators … They just don’t have a unified voice, and that’s unfortunate because most don’t know about our proposal, and if they do, they don’t have much clout to push it forward.

RW: To be clear, any changes would only apply to those who want to move to the new band, correct?
Goldman: Yes, we understand that the big Class A 50 kW stations may want that huge footprint, and ultimately, with the regional and local stations gone, that footprint can get even bigger; but this is a long-term process.

Even when all stations are allocated to the new band, it will take, we feel, at least 10 to 20 years before the existing stations will sunset from the AM band, although some may move more quickly because it costs so much to operate.

The daytime stations that don’t operate at all at night now would be able to operate 24/7. There are some 50 kW daytime-only stations that are spending a lot on electricity but don’t have a lot of listeners because they go away when the sun sets.

RW: What kind of costs would be involved for stations that choose to move? How does the poor economy play a role in making stations hesitate to do this, should the FCC allow it?
Goldman: Well, first, many stations, after the AM sunset, would have large very valuable parcels of property they could sell, so that’s some incentive. Brokers I’ve talked to about this feel that the value of AM stations would rise dramatically, so financing this conversion shouldn’t be too hard. The cost would be similar to that of an FM station signing on.

Since the band would be all-digital, there would be opportunity for stations to add programming to increase revenue. Noncoms and LPFMs could share the multiplex channels so the costs would be divided by two or three; and finally, for the most part, the electrical costs would likely be less than those for an AM station. …

RW: Your group thinks it can help AMs, LPFMs and the noncoms; but is the BMC the only group pushing this so far?
Goldman: To my knowledge, there are some that are interested in various versions of using Channels 5 and 6. Some have proposed just moving more analog channels down there. Some have proposed putting two or three channels appended to the bottom of the existing FM band and then the rest digital. That would actually be relatively compatible with what we’ve proposed.

Of course, some of the TV operators don’t want any of this. I think ultimately the commission is going to have a hard time, if all you wind up with is a few full-power digital Channels 5 and 6, leaving all that spectrum open just to protect a handful of television stations that opt to be there, especially if it’s possible to move them elsewhere just doesn’t seem to me to be in the best public interest.

RW: Is anyone else against it?
Goldman: There are also a few who are concerned about the additional competition these stations would bring, some others don’t want to wait for the process and want more analog stations allocated right away, other than those, most people I’ve talked to see this as a great long-term opportunity to revitalize the AM and noncommercial band.

RW: Given Chairman Genachowski’s focus on using any available spectrum for broadband, does that complicate the BMC efforts?
Goldman: That’s kind of funny since the FCC sponsored a forum a few weeks ago. The point was to determine of it made sense to repack the TV stations to free up wireless broadband space. From what I could tell, for the same reasons that TV works better at UHF frequencies and poorly at low band, none of the broadband proponents had any real proposal for use of the 5 and 6 bandwidth. …

RW: The BMC purposely did not recommend a specific digital technology for AM; is that still its stance and if so, why?
Goldman: It’s probably too soon to lock in on a technology because we don’t have a request for comments in an NOI from the FCC. We’re still leaving it open.

But I will tell you that there have been some great tests using DRM+ in Europe and I understand there’s a small area of Australia now deploying the system commercially.

DRM+ is of particular interest to some AM operators because it is an open standard with no licensing fee and it operates natively at 100 kHz bandwidth. IBiquity operates at 200 kHz. We’ve talked to iBiquity and they say they could easily develop a 100 kHz system, basically as a subset of the existing 200 kHz digital-only system. So that’s of interest as well.

From a receiver standpoint, however, I don’t think it makes much difference. Once the DSP is in the radio, it’s all software after that. DRM+, HD or whatever, it doesn’t much matter; but this also brings up a big benefit to even the current FM community. If this new all-digital band comes to fruition, all the new digital receivers will, of course, pick up standard FM HD as well. We think this could provide a great boost to the FM band and might really kick-start the digital uptake.

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This is one in a series of articles about the challenges and health of AM radio. See past articles here.