National Public Radio opposes applications for review of the Media Bureau order allowing stations to raise their digital power, filed by Prometheus Radio Project and Press Communications.
In comments to the commission, NPR wrote that neither Press nor Prometheus presented a valid basis on which to grant a review by the full commission of the power increase decision.
As I wrote previously, Prometheus called the decision to allow the power hike arbitrary and capricious.
But NPR wrote that, in order to make that argument, Prometheus misrepresented the findings of the NPR Labs "Digital Radio Coverage & Interference Analysis Research Project Report," or DRCIA.
"Prometheus quotes a report conclusion that substantial interference to analog reception could occur as a result of a blanket 10 percent IBOC transmission power increase, but it fails to mention that the DRCIA testing considered reception without regard for the commission's protected service contours. Thus, substantial interference was predicted to occur, but beyond the point of protection under the commission's current rules," wrote NPR. In addition, the bureau's order actually authorized a significantly smaller power increase than had been proposed and the DRCIA testing assumed, NPR noted.
Prometheus also challenged the power increase decision based on NPR's further testing of mobile reception, claiming that the usefulness of the testing was limited because the AICCS testing did not examine indoor coverage. NPR said Prometheus ignored that indoor and portable FM receivers were tested in large numbers in the DRCIA study, and population-based map studies using the receiver data indicated that a limited number of indoor listeners would be affected at the –10 dBc power level.
One of the big thrusts of Prometheus' opposition was the potential effect on LPFMs.
While the Media Bureau said in its power increase order that as secondary services LPFMs are not entitled to special treatment, NPR wrote: "Prometheus now claims that the bureau overlooked its argument that low-power FM stations should be treated as primary services in relation to full-power stations operating digitally." NPR said this "would require a fundamental change in policy" that goes beyond the bureau's authority.
Finally, NPR notes that Prometheus contends that the bureau failed to consider alternatives to the increase as a way of expanding a station's digital coverage. NPR notes that some alternatives, like asymmetrical digital sideband power, are under development but are not a viable alternative now. Others, such as reallocation of TV Channels 5–6 and improving receiver and antenna performance, exceed the scope of the bureau's authority or are not compelled by the record, according to the broadcaster.
As far as the opposition of Press Communications, NPR said the New Jersey-based broadcaster didn't really demonstrate why the power increase should be overturned; and while NPR rejected "as unfounded the more extreme claims of interference," neither the order nor the FCC's decision authorizing the power hike assume "the complete absence of interference." The order included a "rigorous process" for addressing interference claims, wrote NPR.