Quite a few radio people have raised the idea of expanding the U.S. FM spectrum to help AM stations, but Michelle Eyre Bradley has laid out an actual proposed FM Table of Allotments.
Bradley is founder of REC Networks, an unincorporated entity that advocates for the LPFM service and operates resources such as myLPFM.com. She is among those who accepted the FCC’s challenge to submit ideas for helping the AM band. In doing so, she outlines several dramatic proposals, also keeping an eye on the interests of the newly expanded low-power FM service.
A summary of her key points:
-She laid out a plan to move Class D signals from AM to an expanded FM band on the “mostly abandoned” TV Channels 5 and 6 spectrum. She would reallocate 60 FM channels between 76 and 88 MHz for that purpose. She found hypothetical allotments for most of the 1,900 or so existing Class D AM stations.
This would allow Class A and B stations to be more viable as regional services. “We feel that with fewer daytime and nighttime interfering stations, a regional AM service can once again flourish while the truly local (Class D) stations would be able to continue serving a local audience using FM frequencies.”
Class D AMs that are transitioning would be granted a Class A facility (equivalent 6 kW at 100 meters HAAT) in the expanded FM spectrum. (They would also have the option to migrate to any vacant allotment on the current FM Table of Allotments.) She said receivers to listen to the new spectrum are already available, serving listeners in Japan. “REC is aware of radio receivers that have continuous 76 to 108 MHz receive capability.” She said the expanded FM band could be used for analog, hybrid digital and eventually full digital operation.
She added that 25 digital TV stations would need to be repacked; but even if not, Channel 5 and 6 spectrum could be used in most of the continental United States.
-Big AM stations (“like KFI or WABC”) don’t need FM translators, but “AM stations that have been disadvantaged for decades, those that are designed for local service” should get a temporary opportunity to use an FM translator to improve nighttime service. She would limit this translator window to standalone Class D AMs.
-Any translator window should not begin until the FCC has finished settling any competing, or “MXed,” LPFM applications.
-She reiterated her call for creation of a commercial low-power AM service using channels in the AM expanded band. “Unlike many of the traveler’s information stations in this spectrum, LPAM stations would operate full-time. This LPAM service should be limited to ‘new entrant’ applicants and mutually exclusive applicants would be settled through auctions.”
-In general, roll AM back to the time when “clear channel” stations dominate at night and let local AMs migrate to “more appropriate” spectrum.
-Eliminate AM HD Radio “due to its poor performance, especially at night,” and look at Digital Radio Mondiale (DRM) on alternate spectrum such as the 11m shortwave and BAS spectrum at 26 MHz. But the industry should step up its pace of implementation of FM HD Radio.
Bradley wrote that REC lacks technical knowledge to form an opinion on aspects such as the “ratchet rule,” daytime and nighttime coverage standards and antenna efficiency; but she emphasized that “one of the primary goals of REC Networks is to assure a citizen’s access to the airwaves.” She states: “It is our desire to see a diverse selection of voices on the dial spanning race, culture, language, sexual orientation and gender identity. This includes a mix of faith-based and secular voices.”
She also urged the FCC, prior to a translator filing window, to reevaluate the Nielsen Audio (Arbitron) metropolitan markets to make sure the interests of LPFMs are protected. “As we go into this window, we must stay in the mindset that the [Local Community Radio Act] is still in effect.”
Regarding her suggestion of an expanded FM band, her Appendix A shows a proposed FM Table of Allotments for the expanded spectrum, and Appendix B cross-references those allotments with current Class D AM stations that can migrate to that channel under the proposal. In Appendix C, she included an allocation plan that would migrate all Class D stations as well as many Class C stations to the expanded FM broadcast band.
The filing delves into greater detail as to how these proposals could be implemented.
Read REC Networks’ comments.
http://apps.fcc.gov/ecfs/document/view?id=7521066977
Read other summaries:
https://www.radioworld.com/amcomments
