As was to be expected, on the last day that comments are being accepted, filings rolled in on many of the potential proposals for revitalizing the AM radio band.
Advocacy groups, broadcast stations and listeners alike shared concerns with the Federal Communications Commission, including LPFM advocacy group REC Networks, which expressed its support for the preservation of nighttime Class A AM service and support for reasonable expansion on the placement of FM translators for AM stations. The group also weighed in on the expanded band, calling for the release of AM spectrum by those stations with dual-band licenses and pressing for the addition of hyperlocal community stations inside the band.
REC also urged the commission to migrate Class D and C AM stations into spectrum that is currently reserved for a small number of TV stations, and said that other alternate spectrum — such as the 11-meter shortwave band and adjacent broadcast auxiliary spectrum — should be considered for future local Class C and D all-digital operations.
“The commission needs to take the thoughts of radio listeners more seriously than they have been,” said Michelle Bradley, founder of REC Networks, in the 21-page comment filing. “We, the citizens of this country, own the spectrum within our borders. We the citizens of this country, through Congress, entrust the FCC to manage that spectrum and license entities to use the spectrum that will act in the public interest, need and necessity and not just in the best interest of their advertising market. Programmed correctly, clear channel AM can be great again and local (Class C and D) radio can have a better fit in the spectrum, in a newly expanded FM band.”
An analysis of the commission’s proposals related to AM transmission standards and the licensing of AM stations came from the engineering consulting firm du Treil, Lundin & Rackley, including comments on noise and interference issues.
“The present FCC requirements for protection from interstation interference in the AM band are based on assumptions about the signal strength levels required for acceptable service dating back approximately 80 years,” dLR wrote in its 105-page comment filing. “Much has changed in those 80 years.”
“It is time to roll back other changes in the rules that were made at the same time which have hampered radio station signal improvements ever since,” the firm said. “It is also time to adopt changes to the definitions of protected and interfering contour levels to realistically reflect the present day situation with regard to noise and man-made interference.”
The firm said it does not support the standard for nighttime protection of Class A stations that has been proposed by the FCC. “The proposed change could result in excessive nighttime skywave interference within the coverage areas of Class A stations and severely restrict their ability to provide service to their listeners.”
As an alternative to the FCC’s plan, du Treil, Lundin & Rackley proposes that Class A stations be normally protected to their nighttime 0.5 mV/m groundwave contours in a similar fashion to how Class B stations are normally protected to their 2.0 mV/m contours at night.
The firm also suggested that the commission adopt site-to-site calculations for nighttime skywave interference analysis.
Others say it’s time to eliminate “incredible and excessive protection” for Class A stations. According to Butte Broadcasting Co., licensee of KKXX(AM) in Paradise, Calif., and KYIX(FM) in South Oroville, Calif., the protection for Class A stations was critical in the days before public services such as the Internet and cellphones were widely available.
“In today’s broadcast world, the commission’s emphasis is, as it should be, on localism, better service and thorough reach to the rural areas,” the licensee said. “Class A stations simply do not require the kind of protections historically given, that protection is crippling for more local AM radio stations required to reduce power or cease operation at night. Excessive protection at night on the AM dial serves no purpose.”
Similar sentiments were shared by Hatfield & Dawson Consulting Engineers. “[I]t is clear that the protection of Class A station skywave service is at best anachronistic,” the firm said in its comment filing. “[I]ts protection in the rules should be eliminated.”
The firm clarified that critical hours protection of Class A stations should not be eliminated, but should be modified to provide protection of the 500 μV/m groundwave service of the Class A station.
The group also weighed in on the proposed modification of adjacent-channel groundwave overlap standards, saying that modification of the rules to return to 0 dB first adjacent channel protection is justified. “Additionally, a 500 μV/m signal is essentially unusable in the noise environment that now exists,” the firm said in its comment filing. “Therefore revising the second adjacent channel protection to 25 mV/m overlap and modification of the normally protected service area to the 2.0 mV/m contour is another method of providing standards which will allow station modifications to overcome the prevalent noise level of the modern environment.”
The firm also expressed support for the elimination of the recertification rules for moment method proofs.
The expanded band remains an area of contention. While groups like Hatfield & Dawson and REC Networks have called for the release of AM spectrum by those stations with dual-band licenses, others, like Baybridge Communications said expanded band licenses should be exempted from the proposed surrender requirement because the FCC’s stated purpose of interference reduction does not apply to those noninterfering stations.
The retention of both expanded band station KDIA and standard band station KDYA, both in Vallejo, Calif., will serve Congress’ goal of bringing full-time aural service to certain underserved communities, Baybridge said, without undermining the commission’s interference reduction objectives.
Firms like Hatfield & Dawson have a different take. “We agree that dual operation of original ‘high interferer’ stations and their expanded band companions should be terminated, and we do not believe that a notice or further transition period is justified.”
In a second comment filed on the same day, du Treil, Lundin & Rackley said that the designation of the “expanded band” term itself be dropped altogether, and that all frequencies between 540 kHz and 1700 kHz be referred to in FCC Rules as the same band.
“We believe that the technical regulations for the expanded band and the remainder of the AM band should be identical,” the group said in its second filing. “Migration will occur guided by business forces that focus on increasing service to the public to increase station values as stations apply to change frequencies there. There are a sufficient number of audio services available to the public using various technologies to make it unnecessary for the FCC to attempt to dictate special uses for the expanded band.”