SACs, AM at Night And Receivers Dominate Comments
WASHINGTON Station workers and group owners. Consumers. Citizen groups. Manufacturers of transmission and receive equipment. All are affected by terrestrial radio's digital transition.
As the FCC gets down to shaping final IBOC rules, approximately 250 commenters wrote to the commission this spring about how terrestrial radio's digital transition should proceed.
In the first of several articles, we excerpt here a sampling of comments in the FCC's Further Notice to its IBOC Rule Making. Commenters touched on such vital topics as spectrum fees, datacasting, the receiver rollout, personal recording, the supplemental audio channel and radio reading services.
Reply comments are due July 16.
WGN Continental Broadcasting Co., the licensee of WGN(AM) in Chicago, wrote:
"WGN believes that the unlimited authorization of nighttime HD Radio is premature at this time because it may unnecessarily create interference to existing AM service when there is no significant penetration of HD Radios. For this reason, WGN proposes that the commission authorize broadcasts of HD Radio only from 5 a.m. to 7 p.m. without regard to the time of local sunrise and sunset. ...
"As an AM station that has been in operation continuously since 1924, WGN has a keen interest in providing the best possible service to our listeners. WGN sees digital radio as an exciting enhancement to the existing service that will provide much-needed improvements in audio quality as well as new digital data services that were previously unavailable on the AM band.
"WGN cannot, however, support the proposal by NAB and others that the FCC authorize immediately unlimited operation of HD Radio by all stations authorized to operate at night. WGN submits that the NAB's proposal may unnecessarily cause severe interference to existing service at a time when there are very few digital receivers in the marketplace. ...
"Because the interference testing of nighttime HD Radio done to date is limited in scope, the actual amount of interference to existing service could be more severe than predicted in the testing. ...
"One advantage to the WGN proposal is that it would give the commission time to evaluate how severe the interference from nighttime HD Radio will ultimately be by observing the impact of HD Radio on existing service during the pre-sunrise and post-sunset periods that will occur in the fall and winter of this year and next year. Ultimately, as more and more HD Radios are sold in the marketplace, the commission will be in a position to decide when there is sufficient penetration of new digital radios to justify the loss of service that may result from full time HD operation at night."
National Public Radio wrote:
"We believe the importance of DAB is ultimately more about content than just audio quality, and we are excited by the opportunity to expand our program service offerings to the public. ... In short, based on the Tomorrow Radio test results, including the lack of interference associated with subdividing the digital bitstream, and the public interest benefits inherent in multicasting, we urge the commission to authorize digital audio multicasting without delay and without requiring special licensing. ...
"With respect to NCE radio stations specifically, the commission should authorize such stations to offer ancillary and supplemental services for remuneration and without having to pay spectrum fees. ... Just as NCE radio stations were authorized to use their analog SCAs for remunerative purposes, the digital capacity will allow stations to further diversify their revenue sources.
"At least during the period of hybrid operation, NCE radio stations should be required to offer free over-the-air analog and digital NCE services, but they should be free, as a commission matter, to utilize their remaining capacity for other purposes. ...
"NPR is committed to preserving existing SCA-based analog services during the digital transition. In addition, NPR will work to address instances of harmful interference that may result from the deployment of the Ibiquity IBOC system.
"NPR is also committed to developing the Ibiquity technology so that radio reading services may be offered via stations' digital spectrum for reception by generally available radio receivers. Toward that end, NPR has taken the initiative in exploring the use of the extended hybrid spectrum for the digital transmission of radio reading services.
"In collaboration with the International Association of Audio Information Services, NPR will conduct audio and transmission platform tests this summer to determine the suitability of the extended hybrid digital spectrum for radio reading service transmission, pursuant to a Corporation for Public Broadcasting funded grant. This testing will measure the coverage capabilities of extended hybrid operation and provide full perceptual testing of the latest digital audio codecs that may be used for radio reading services. ...
"(W)e believe it is premature for the commission to consider specific receiver-based mechanisms to prevent the copying and distribution of copyrighted works. It is incumbent on the Recording Industry Association of America ('RIAA') to demonstrate a concrete harm associated with DAB, and, given the nascent state of the technology, we do not believe such a showing can be made at this time."
David P. Maxson, managing partner of Broadcast Signal Lab LLP, wrote:
"The beauty of the IBOC approach is that there is no spectrum to return at the end of a transition period, as there is in the DTV arena. Adoption can take as long as it needs to, enabling it to remain transparent to the consumer.
"If adoption of IBOC by the consumer becomes slow or stalled at some point in the future, the consequence is primarily that other digital media may be developing a market advantage over local digital radio broadcasting. Perhaps the best bellwether of a failing IBOC adoption in need of FCC intervention is in a measure of the industry's confidence in the technology - the number of stations transmitting hybrid IBOC signals. The commission could annually inventory the number of stations transmitting IBOC signals, say, 90 percent or more of their analog broadcasting time.
"This figure should rise steadily for several years and then plateau. If industry confidence wanes, it will be apparent in an erosion of the transmission of hybrid IBOC systems. Industry confidence will be a valuable indicator of the interest the public has in IBOC broadcasting and ultimately the probable success of the technology. ...
"The biggest obstacle to a smaller broadcaster is the cost of the system. Other than offering spectrum fee rebates to smaller broadcasters who adopt IBOC by a deadline, the best incentive that the FCC could provide is in its regulatory structure of the IBOC medium. Ibiquity Corp. has done a fantastic job developing what many predicted would be impossible and it deserves recognition and recompense for its efforts.
"At the same time, the company holds a central position in the IBOC marketplace. With such dominance of the technology comes the potential for too much control in the hands of one enterprise. As the regulatory authority, the FCC should be certain that all standards and policies encourage competition in all levels of the IBOC marketplace.
"Chipsets, firmware, protocols, system control software, data service definitions, receiver features and functions, and much more must be placed on a level playing field so that real competition and innovation can occur. Innovators should not be forced to get the permission of the dominant competitor to develop new ideas. ...
"The role of the commission is best played in setting the tone for innovation and competition in the digital radio marketplace and in permitting industry cooperation through open standards to guide the development of features that serve the public demand."
Kenwood USA Corp. wrote:
"With or without a regulatory mandate requiring conversion, we expect that there will still be a significant number of analog-only products in the field well past 2014. Therefore, the sheer magnitude of analog receivers in the field will not be forced out by a regulatory mandate in the next decade.
"Consumer action to replace existing receivers is the strongest leverage to bring to bear on this situation. Commission action to make IBOC broadcasting highly desirable over analog broadcasting will help drive demand and accelerate the conversion of the analog base of receivers in the field to a digital base.
"History has shown that new content available only on digital receivers is the best way to stimulate this demand. ... Broadcasters and their listeners should determine the appropriate number of audio streams based on their different content requirements. ...
"Our strong belief is that the FM supplemental channel capability is absolutely critical to the success of IBOC in this country. ... Our belief is that most receiver manufacturers will consider this capability a requirement on future IBOC receivers. ...
"We expect this ability to tune to multiple supplemental channels on a single frequency will be a standard feature on receivers within a year. More specifically, Kenwood is preparing supplemental channel radios in anticipation of possible commission action permitting supplemental channel broadcasts in hybrid and extended hybrid modes.
"When the commission feels the time is right, Kenwood will be ready with products. We believe our competitors are similarly positioning themselves.
"The commercial stations have a different business model, and there is less of a clear picture on how the commercial station owners and radio groups will use supplemental channels.
"Several proposals are common. One idea is to put dedicated local traffic and weather on the first supplemental channel. A listener would never be more than a minute or so away from current traffic and weather. Another proposal is to simulcast in a second language. The third is to revive formats previously enjoyed in the community of license but no longer available. ...
"We support radio reading service digital deployment in ways that can be integrated into mass-market products for little or no additional cost. The intent of this goal is to make reading service products available at mass-market retailers. It is possible that the average digital radio can have reading services as a standard feature in a few years."
SACs, AM at Night And Receivers Dominate Comments