This afternoon the Commission released an Order authorizing FM radio stations to increase power on their hybrid digital radio operations. This power increase is a welcome boost to HD radio operations and was eagerly awaited by many FM stations broadcasting in digital. In a nutshell, the rule change allows stations to increase from the current maximum permissible level of one percent of authorized analog effective radiated power (ERP) to a maximum of ten percent of authorized analog ERP. In raising the power permitted for digital radio operations, the Commission acknowledged that the current digital power levels are insufficient to replicate stations' analog coverage and that indoor and portable coverage are particularly diminished. Building on proposals advocated by National Public Radio (NPR) and iBiquity, the Commission has provided for an immediate voluntary 6 dB increase in Digital ERP (except for super-powered FM stations, as discussed below). In addition, stations will be allowed to seek authority for increases over 6 dB up to a maximum of 10 dB using an informal application process.
Once the Order becomes effective, eligible FM stations may commence operations with FM digital operating power up to -14 dBc (that is, up to a 6 dB increase), consistent with the existing IBOC notification procedures. Stations availing themselves of the voluntary power increase must notify the FCC electronically of the increased digital power within 10 days of commencement using the Digital Notification form via the Commission's Consolidated Database System (CDBS). The exception to this is super-powered FM stations, which, regardless of their class, are limited to the higher of either the currently permitted -20 dBc level or 10 dB below the maximum analog power that would be authorized for the particular class of station, as adjusted for the station's antenna height above average terrain. The Audio Division's web site contains an FM Super-Powered Maximum Digital ERP Calculator available here to assist super-powered stations with determining the maximum permissible Digital ERP. Licensees of super-powered FM stations must file an application, in the form of an informal request, for any increase in the station's FM Digital ERP.
For power increases over 6 dB, licensees will be required to submit an application to the FCC, in the form of an informal request, for any increase in FM Digital ERP beyond 6 dB. Licensees wishing to operate with an FM Digital ERP in excess of -14 dBc must make a calculation and determine the station's max permissible Digital ERP as detailed in paragraphs 17 through 20 in the Order, available here.
The revised rules will become effect 30 days after publication in the Federal Register, which will likely occur within a couple of weeks. There is a chance that the effective date of the new rules could be pushed back if the administrative review regarding the collection of data isn't completed before then, but that is not expected to be an issue here. In any event, the Commission's Order states that stations can seek to commence operations with increased HD power of up to -14 dBc before the effective date of the new rules by filing a request for Special Temporary Authority (STA). So digital FM stations that are itching to increase their power ASAP should start working on a request for STA seeking to utilize increased power.
Finally, two additional notes, both dealing with the potential for interference. First, today's Order solidly rejected the suggestion by some commenters that Low Power FM (LPFM) stations were more likely to be affected by full power stations operating with increased FM Digital power and thus should be afforded greater protection from the blanket increase in Digital ERP. Although the Commission in the past has seemed to be leaning towards affording LPFM stations greater protections (as we've discussed in previous posts), today's Order firmly states that "Analog LPFM... stations are secondary services, and as such, are not currently entitled to protection from existing full-service analog FM stations." In rejecting the notion of special protections for LPFMs, the Commission stated that it viewed the protections sought by the commenters as a potentially "dramatic change in LPFM licensing rules and the relationship between LPFM and full-service stations." In sum, "Licensees will not be required to take into account nearby LPFM stations in calculating permissible digital power levels in excess of -14 dBc."
Second, the Order adopts an explicit digital FM into analog FM interference resolution procedure for full-service FM stations. If a full-service analog FM station is receiving verifiable listener complaints of interference within its protected contour from a digital FM station operating with a Digital ERP in excess of -20 dBc, the licensee of the affected analog FM station should contact the licensee of the digital station and the stations must work cooperatively to confirm the interference and to attempt to eliminate it using voluntary tiered FM Digital ERP reductions. If the stations fail to reach an agreement on how to remediate the interference, then the affected analog FM station may file an interference complaint with the FCC's Media Bureau. In order to file such a complaint, the affected analog FM station must have at least six reports of ongoing (not just transitory) objectionable interference and submit a map showing the location of the interference and details about the nature and extent of the problems.
The Commission's Order notes that although there are approximately 1,500 radio stations operating in digital in the country today, notifications of new digital operations has been in decline for the past two years, meaning fewer stations have been commencing digital operations. It will be interesting to see whether the increased power levels now permitted for digital radio will breath new life into HD FM radio operations.
