Last week, acting FCC Chairwoman Mignon Clyburn delivered a speech at the NAB Radio Show, which talked about new technology and old, and her affection for AM radio. In the most newsworthy aspect of the speech, the Chairwoman announced that the FCC is currently considering a draft Notice of Proposed Rulemaking looking to improve the service delivered by AM radio. As we wrote here, the issue of AM improvement has been a major initiative advanced by Commissioner Pai, looking to restore AM radio’s competitive posture. Attention is needed to overcome some of the many obstacles that AM faces, including those from interference that has increased significantly in many metropolitan areas, causing more and more electronic “noise” that disrupts the AM service. The discussion at the Radio Show raised several proposals for AM relief. But will they really help AM stations?
First, it is important to understand that the Chairwoman was talking only about a series of proposed actions – nothing has yet been decided. There is a Notice of Proposed Rulemaking that is circulating at the Commission. This means that the proposal has been drafted and is being reviewed by the other Commissioners. Once they finish their review, the Notice will be released to the public, which will then have some period of time (probably a few months) to comment on the suggestions made by the Commission. According to the Chairwoman’s speech, and echoed by Commissioner Pai in an address that he delivered to the Radio Show, broadcasters will also be urged to come forward with their own ideas as to how to improve AM radio. All of the comments filed by the public will have to be digested before the Commission can actually implement any of them. With that background, what is to be proposed, and which actions will likely move the fastest?
Here are the specific proposals made in the speech:
- Opening a one-time FM translator filing window, limited to current AM licensees and permittees, which will allow each to apply for one new FM translator station to fill in its service area.
- Relaxing the AM daytime and nighttime community coverage rules to allow existing AM broadcasters more flexibility to propose antenna site changes.
- Eliminating the AM “ratchet rule,” which requires an AM station to “ratchet back” its nighttime signal to reduce interference to certain other AM stations when changes are made to the AM station’s facilities. The rule, while intended to reduce nighttime AM interference, has instead reportedly discouraged service improvements and has apparently resulted in a net loss of interference-free AM, nighttime service.
- Permitting wider implementation of Modulation Dependent Carrier Level, or “MDCL” control technologies, which allow broadcasters to reduce power consumption. The proposal is to allow AM stations to implement MDCL operation by simply notifying the Commission, rather than having to seek experimental authorization or waiver.
- Modifying AM antenna efficiency standards by reducing minimum effective field strength values by approximately 25 percent, thus allowing the use of shorter AM antennas.
While all of the proposals would have their benefits, many of these benefits would be limited – applying only to those stations looking to make some sort of site move or other change in the facilities with which they operate. The proposal for FM translators for AM stations, while probably providing the most immediate relief for many broadcasters (and the proposal probably most easily implemented), itself faces several problems. First, it is unlikely to happen until applications from the upcoming LPFM window (see our article here) have been processed. Depending on the number of applications filed in that window, it might very well be some time until such processing will be complete. Moreover, there will no doubt be many markets in which there will simply be insufficient spectrum to allow for an FM translator for all AM stations. Instead, there may be few if any available frequencies in many if not most larger markets (especially after the LPFM window), and what few frequencies may remain may be subject to competing demands from multiple AM licensees (which would have to be resolved through the auction process).
Issues not specifically addressed, but much talked about in other sessions at the NAB Radio Show, include moving to an all-digital AM band – which has shown promise for an interference-free operation in recent tests, but which would require that there be a digital transition for AM radio just as there was to digital TV. That might be problematic, as it would require new AM receivers for almost everyone (except for those few people who already have Ibiquity IBOC receivers which should work in an all-digital environment). Are AM licensees ready to make such a big change?
This is a thorny question, but one which we applaud the Commission for beginning to tackle. AM broadcasters, get your comments ready!