Critics Say NRSC-5 Would Cause Irreparable Harm
Nothing about terrestrial digital radio in the United States has been easy, and now, the burden of making tough decisions about it falls to the FCC.
As the commission begins sifting through opinions about the transmission standard for terrestrial digital radio, staffers will be making judgments about what is needed to complete final rules authorizing the service. Words are strong, with many on both sides arguing that this standard will determine nothing less than the future success or failure of many broadcasters.
Those who oppose IBOC, and others who believe it is a suitable standard for terrestrial digital radio that requires fine tuning, raised concerns in their written comments to the commission. They worry about authorizing AM IBOC at night, about interference to nearby AMs and FMs and about the lack of a codec specified in the transmission standard for digital radio.
Taking an opposing view are those who want the standard approved swiftly in order to bring certainty about terrestrial radio's digital transition to broadcasters, equipment manufacturers and consumers.
"Having real rules will do a lot to move it forward," said a participant in the National Radio Systems Committee, the standards-setting body sponsored by NAB and the Consumer Electronics Association. He said he didn't envy the FCC the job of sorting through the comments and crafting the final IBOC rules.
The commission sought public comment in June on the IBOC standard, dubbed NRSC-5.
Replies due Aug. 17
Contacted by RW for reaction to the opinions expressed in approximately 40 filings to MM Docket 99-325, most declined, saying the public comment period was still open in July. Reply comments on the standard are due Aug. 17.
In an NRSC vote in April, 20 organizations voted to support NRSC-5, among them NAB and CEA, the co-sponsors of the NRSC. The standard thus has the backing of two industry entities that represent commercial broadcasters, on one end of the U.S. radio infrastructure, and receiver makers on the other.
Both associations described as urgent the need to adopt a single IBOC standard to give certainty to all parties that terrestrial radio really is going digital and that IBOC is the appropriate U.S. terrestrial digital radio standard.
The rules, NAB said, will "permit free over-the-air radio broadcasters to better serve listeners and compete in an increasingly digital world."
A big point of contention leading up to the spring vote on NRSC-5 was whether to include a codec specification. As Radio World has reported, many members wanted to include details about Ibiquity's HDC codec in the voluntary standard. Ibiquity has said that due to contractual agreements, it could not release specifics. In order to have a standard at all, members of the DAB Subcommittee decided to proceed with NRSC-5 without the codec specifics.
CEA urged the FCC to adopt an IBOC digital radio standard, noting that receiver manufacturers, broadcasters and consumers "need the certainty ... in order to have enough confidence in the long-term usefulness of IBOC digital radio equipment to invest in it."
While the lack of a codec specification is "not optimal," CEA wrote, it is acceptable. "While CEA would prefer that a codec be included in the specification, we note that the NRSC made its best effort toward this end and, ultimately, concluded that NRSC-5 is an appropriate standard even without an audio codec."
Also writing in favor of the standard, Harris said more than 350 of its HD Radio transmitters have been purchased so far. A single IBOC standard, it said, ensures equipment compatibility for broadcasters and consumers.
Codec specification contentious
Others don't agree that the standard is complete.
In a joint filing, Microsoft Corp., Broadcast Signal Lab and Impulse Radio, three of the seven NRSC members who abstained from voting on the standard this spring, urged the FCC to adopt a single standard but pointed out what they see as holes in NRSC-5.
The lack of a codec specification, they contend, is serious, and the FCC should send the standard back to the NRSC with instructions to complete it by incorporating both an initial codec and a mechanism that enables the use of alternative, optional codecs. They want the FCC to make it clear that the Ibiquity HDC codec is a market-starter codec only.
They also asked the agency to establish a procedure for resolving disputes concerning further development and licensing of the DAB technology. The commission should "review the terms and conditions on which Ibiquity licenses the technology," the companies state.
"Without this type of commission oversight, it is possible that Ibiquity's licensing decisions could slow innovation and/or hinder the deployment of new products," they state.
An Ibiquity spokesman declined comment on all filing-related questions.
Microsoft, which makes an audio codec, and the other companies in the filing are interested in the data capabilities of HD Radio.
The advent of multicasting, or splitting the digital signal into several streams, opens doors for codec makers, Microsoft, Impulse and Broadcast Signal Lab believe, referring to NPR's tests with different codecs at low bit rates.
"Although a single codec, such as HDC, could successfully be used over a range of data rates and implementations, other codecs might be optimized for particular applications with higher efficiency and/or quality than would be possible for a single, generalized codec," they wrote.
"Given that NRSC-5 allows up to eight audio services to coexist within the relatively constrained bandwidth of a single IBOC DAB channel, it is quite conceivable that such highly efficient and optimized codecs would be in demand. These codecs are most likely to emerge and evolve successfully in the market if the IBOC standard allows their easy and widespread integration."
Johnathan Hardis, who represented the National Institute of Standards and Technology in the NRSC meetings but submitted comments to the FCC as an individual, believes the lack of a codec spec leaves the standard "substantially incomplete and, as such, not suitable by itself for either engineering or regulatory purposes."
He said the HDC codec "remains a trade secret," which violates Ibiquity's commitment to an open standards process.
He urged the FCC to reject NRSC-5 and rescind all temporary and interim authorizations for IBOC radio broadcasting.
"(N)ow that the Ibiquity system has become successful, overcoming market resistance to become entrenched as the only viable DAB option, they appear to assert trade secrecy rights that would benefit them with a perpetual stream of royalties and a stifling of competitive innovation," Hardis stated. "This is wrong."
Two sources who spoke on background said the commission was unlikely to rescind all station authorizations to go IBOC, given that the rollout has begun and the FCC made it clear it sees IBOC as the technology for terrestrial radio to go digital in the U.S. and supports the activities of the NRSC.
Ibiquity said that by mid-July, more than 450 stations were broadcasting the combined analog/digital signals; 75 percent of them are FM and 25 percent AM. It expects 600 to be on the air by year-end.
The company warns of the possible consequences if the FCC doesn't act swiftly.
"Failure to designate such a standard can create confusion in the marketplace, slow the introduction of this important new technology and possibly sow the seeds of the (technology's) failure," stated Ibiquity.
Whether and under what circumstances AM stations, especially those with directional antenna systems, would experience harmful interference from their IBOC neighbors, was of great interest to many commenters. Several debated whether and how AM nighttime IBOC operations should be allowed.
Leonard Kahn, in his filing, reiterated support for his Cam-D system for AM digital rather than IBOC, and wondered what had happened to his suggestion that the FCC form a panel to replace the NRSC.
"The Blue Ribbon Panel would propose to the commission appropriate procedures for replacing the NAB/NRSC failed advisors, who are clearly subject to a serious conflict-of-interest disability," Kahn states.
Some small-market AM broadcasters opposed IBOC due to the necessary bandwidth changes.
"Recent experience with HD Radio has proven to me that in-band HD is not the way to go," wrote engineer Edward Jurich of Blue Springs, Mo. "This is especially true in the AM band, where interference is a big factor and degrading the current system to 5 kHz is just plain stupid. Considering the number of current AM radios in use today, there is no reason to degrade the AM band any further."
Some commenters suggest the commission establish clear, bright-line numerical targets for what constitutes interference, and how that interference could be mitigated, for AM operation with IBOC.
These would be "targets not based on casual observations, but on real numbers. This is arguably the biggest job the commission has before it," an NRSC source said.
The commission is accepting reply comments on NRSC-5, which is in MM Docket 99-325, until Aug. 17. To submit a filing, go to www.fcc.gov/cgb/ecfs/.
Critics Say NRSC-5 Would Cause Irreparable Harm