Broadcasters' Desktop Resource

... edited by Barry Mishkind - the Eclectic Engineer    


From the Editor:                                 Previous Editorials



With this week, the BDR Newsletter has completed eight years. As we enter our ninth year, we want to stop and thank you, our readers, for your loyalty. We often get notes from folks who tell us they look at the site or wait for the Newsletter each week, and appreciate the contents. Thank you folks for those thoughts and for passing our URL on to your friends, so they can share the information.

Of course, there are some new things planned for the coming year, adding some new features, improving some others, and dropping a few items that do not appear to be used. Your input is welcome on this matter: is there something we should add that will help you? Please reply to this Newsletter and let us know!

Something else that you may want to know about the BDR: you will find that we do not track your every move. Aside from an occasional URL from a banner advertiser, you will not find our links include long, convoluted URLs to track where you go. And although occasionally we do get questions from potential advertisers who want information on readers, we do not do that. We will not do that. Even when it costs us money.

Getting the last dollar is not our mission. Getting the information you want is our mission.

What do you think? Share your thoughts:  You are welcome - and invited, yes, encouraged - to do so.



Over the past few weeks, the FCC has once again created a turmoil over the use of the word "immediately" in respect to the NPT scheduled for September 28th.

And once again, the FCC has sat on its hands while the industry struggled to determine how to react to an official statement from a Commission that has become more interested in fines than solving problems.

Meanwhile, the FEMA sent out two tests this week with an "invalid certificate" which exposed several more EAS issues, even as manufacturers struggle to help customers ensure they can receive tests and EANs with the 000000 location code.


Is it "immediate" to relay an NPT as soon as the EOM is received, or must the broadcaster instantly interrupt programming as soon as a header is received? When the FCC tinkered with the Part 11, an apparently inadvertent dropping of the word "live" through everything into confusion.

Firmware updates, some of which cost as much as $500 a station became necessary with the worry that the "immediate" might be the more instantaneous type of "right away" and without new firmware, which required a lot of recoding, some stations might be a minute or two behind.


All of this continues to point to the matter of no one at the FCC seems to have ever worked in broadcasting, nor cares about the effects of what they are doing.

Many broadcasters have offered to assist and review any proposed changes, but the FCC continues to operate, as does the FEMA, in virtual silence. They do have some advisory committees, but these are dominated by non-broadcasters. It would be so much better if the changes were discussed before being circulated.

Prime example: The "new" EAS Handbook, long an example of a nearly useless requirement to print and have on hand, was replaced with a new handbook which, for example, on page 11, states: "Three data bursts and a tone indicate that the End of Message (EOM) code has been received, and that the test is over." One has valid reasons to wonder if the person that wrote this ever was at a station when the EAS was activated or tested.

And on and on it goes. There are other "odd" statements indicative of a quick cut and paste without ever talking to anyone.


Despite these issues, the FCC has remained fairly quiet about the meanings. Yes, they did acknowledge the blatant error in the "handbook" as noted. A new revision is coming, sometime. Of course, we have been waiting for a complete Part 11 rewrite for over 5 years now.

And 2011 was the year of the National EAS Test. Have you seen any real changes?

It is past time for the FCC to operate "as usual" in lawyer mode, and get with the industry and solve problems, rather than add to them with each new pronouncement.


What do you think? Did we get something wrong? Share your thoughts:  You are welcome - and invited, yes, encouraged - to do so.




Last week was the latest in the series of NPTs being run around the country by the FEMA. (Due to the lack of the 000000 code in some EAS receivers and a limitation in the "destination codes," the testing is being rolled out by regions, more or less.

What was learned?
        1. Some stations still have not gotten their filters set right to received and forward the NPT.
        2. A few stations had trouble with the analog vs AES digital audio. An incorrect setting in
                some stations resulted in "Darth Vader-like" audio.
        3. Perhaps also from the analog vs digital, or maybe from analog vs CAP text to speech,
                a few stations reported no audio at all.

All these are easily correctable, if stations will just take a few minutes to fix the settings.

        4. Last minute cancellations of the test, due to weather in six Southern/Atlantic states
                left a lot of confusion and frustration in the field. The FEMA did announce the
                cancelled states would get another change on a future NPT.  But, why?

Yes, the potential for a bad storm/hurricane does normally "trump" a RWT or RMT, etc. Yet this test was called off literally minutes before the test. Stations and state associations were caught in a "Dead Zone" for 20 minutes to an hour or so, before there was any notification of the cancellations.

To some observers, it seems a lot like the confusion could have been prevented with a short  ADR-type message notifying the states/stations of the cancellation. To others, it seemed like the test should have just run, and allow stations in locations where the weather was not a problem to see the test, while others would have dismissed the test in favor of more local response.

Unfortunately, these tests are being rolled out very slowly, only to find unprepared stations at the local level. Perhaps a better quest would be to run these more often until "issues" are resolved, much like the RWT is now essentially a "nothing ball" where few stations really pay any attention past the electronic log. As far as the RMT goes, if the SECCs were to take stock and identify any stations that are having trouble with the state RMT, it would go a long way to making the NPTs more productive.

Instead, the FCC in its current NPRM, proposes a web reporting system. If this follows other recent tests, including our one national test (another is finally scheduled for September), the data sits and sits for months, with little help to solving more recent problems. SECC and LECC's should be taking stock at each test, weekly, monthly, and pseudo-national. Issues  can and should be resolved with some sense of urgency.

Make no mistake - they are tests, and tests are there to identify issues. To that extent, these NPT are valuable. But unless they are run frequently enough and the follow up is many magnitudes faster, the stations where there are problems cannot be identified and helped in any timely manner. Simply running an NPT is merely a snapshot - of some use - while a fuller "status and state of action" of any particular  station would be more helpful - especially when initiated on a state or local level.
It may be time for the RWT to go away and be replaced with a bi-monthly "system health" test.

What do you think? Did we get something wrong? Share your thoughts:  You are welcome - and invited, yes, encouraged - to do so.


AM .... Revitalization?



Jay Walker
Bill Putney
Alan Parnau
Mike Shane

Ted Thayer

On Friday, the FCC released the First Report and Order (R&O) on AM Revitalization, finally bringing some action to the process that has ground on exceedingly slowly.

It may be the Ajit Pai's efforts over the past few years should be applauded. He was, perhaps, the first FCC Commissioner to actually make it his mission to get things moving. During one appearance at NAB, he noted that AM owners have been asking for help for a long time - more than a few proceedings had been going for a decade and longer.

One interesting aspect is the shift in recent months in the common rallying cry for help: from AM Improvement to AM Revitalization.


There is no question that AM, in general, is in trouble. Kids, if they refer to it at all, refer to "Ancient Modulation." The lack of stereo audio quality approaching that of FM is usually considered why many AM stations are floundering. Yet, studies as far back as 1980 concluded that with the same audio on both AM and FM, car listeners picked AM more often.

Other studies concluded listeners were attracted to stations with better content. Yet, consolidation has turned station after station into juke boxes playing the same automated formats.

At the same time, sports programming and foreign languages have found a great home on AM. Many small market stations do very well, thank you, superserving their community - especially when they are on the air.

But then, Daytimers really do suffer in Winter, with late sign on and early sign off - for some, barely 6 or 7 hours total air-time in a day. RFI has grown to be a major problem in most places.

Yet when disaster strikes, there is no better resource than an AM that covers the area with EAS alerts, news, and critical information.


The situation has gotten so dire that the FCC, despite a lot of opposition, finally permitted AM stations to own and operate FM translators.

This thrilled AM and translator owners. The AM stations could have an FM signal, the translator owners got a super hot market, with translator values skyrocketing as AM stations, even those owned by large companies, sought to grab them first, just as in the "consolidation race" of the late 90s and early 2000s. 


However, those that could not afford to buy a translator went back to begging the FCC for something, some help.

A translator Window - just for AM stations - was a major desire. And, there were all the other proposals that have been made over the years, from PSA/PSSA to using Channels 5 and 6, to just raising everyones' power at once.

Different groups proposed different solutions, some of which can be found on this site. But, above all, popular pressure continued building for the translator solution - even after FCC Chairman Wheeler said it was not his solution.

Of course, when you think of it, it is clear what the owners want. It is a legitimate desire. But it is not AM Improvement or AM Revitalization. You have to add another word.


So, here we are. The First Report and Order, Notice of Further Proposed Rule Making, and Notice of Inquiry.

To give the FCC its due, it took a lot of time, effort, and compromise for the full panel to come up with the solutions and proposals advanced. The NAB, usually TV oriented these days, came on board and made the FCC listen to the clamor. And the first thing on the table was to answer the call for more translators.

How this Revitalizes AM is unclear. An FM translator certainly does not improve the AM signal. It does not solve any AM problems. But adding one word makes it clear why it meets the major desire of AM operators: just call it AM Revenue Revitalization.


To be sure, many AM stations need more revenue, especially in the small markets where stations struggle - and have no where near the millions of dollars to pay bonuses to CEO's.

So the R&O has welcome news: the four promised Windows will open opportunities for AM stations to grab more of those FM translators - so essential to quickly get more air time and money. But is there anything in there for improving AM itself?

The FCC does plan to change coverage contour requirements, kill the Ratchet Rule, allow less efficient antennas, and encourage MDCL - carrier power reduction schemes - among other items. Will it be enough?

Some stations are already trying to convert the translator into the "Main."

Which again begs AM Improvement.


Just as the US Congress seems incapable of cooperating to solve problems, so, too, the FCC Commissioners meet the political necessity (translators), but miss the goal of helping AM to grow on its own.

Ever since the FCC lost its PSA and PSSA records, they have been loathe to solve the problem. Why must stations sign on late in mid-morning and off in mid-afternoon, while HD-AM stations are allowed to throw hundreds (or thousands) of Watts on their channel all day and night?

Here's an idea that should have been easy, and now should be even easier to push out: Let all daytimers have PSA and PSSA from 6 to 6 right now, until the station has a translator on line.  

Another item not even mentioned in the R&O is the ever increasing RFI on the AM band. Part 15 noise has gotten so bad that some car radios are unlistenable as they approach a traffic light, for example. However, just as they did with CB, the FCC seems to have tried to pretend there is no problem, allowing the increasing noise to destroy the AM band.


Again, we understand the financial realities. AM owners need money. FM translators make it happen. But, why not help stations to improve the quality of AM transmissions?

It would be a double win.

Unless ... the long term goal is to get translators for every AM ... and turn all of the stations into FM operations ... ultimately to kill the AM band off.

What do you think? Did we get something wrong? Share your thoughts:  You are welcome - and invited, yes, encouraged - to do so.

Jay Walker writes:
It seems the focus on AM REVITALIZATION is in fact more of an AM OWNER'S REVITALIZATION proposal.

For decades many AM operators let their properties languish running automated place holder formats from the bird all to keep the facility on the air the cheapest way possible. In the 80's the format 'flavor of the month' was 'Talk Radio'. The market then became flooded with first, then second, and finally third tier syndication. After siting and doing nothing but collect a pittance the remaining AM audience which listened to talk finally 'aged' out of a sellable demographic. The next magic format to come along was Spanish, and sports. With the exception of a handful of MAJOR markets sports has delivered minimal sellable numbers. Spanish in most markets is a placeholder format and in most cases a desperate roll of the dice to keep audio on the air the cheapest way possible.

Now the grand idea involves the killing of FM thru saturating the band with 250w translators only so AM operators can simulcast their failed formats on FM as well. It makes no sense to go that direction. Recently there were a number of poorly preforming AM stations that added a full C FM simulcasts and saw ratings increase an average of ONE share. ONE share from 100KW. Seems the format is the problem and if a format is bad, it won't be magically better by just changing the modulation scheme. If AM operators want revitalization they need to look beyond using the AM delivery system as an excuse for a format's failure. Across the US there are a number of owner operators running successful AM stations, and the majority are playing MUSIC. Folks it's not the car, it's the driver who is the problem..

- - -

Bill Putney writes:

Just to make it clear, giving FM channels to AM owners does nothing to revitalize the AM band. It does revitalize AM owners investments. Some of these owners bought AM's at bargain basement prices and now want the FCC to make them whole. Hey, I'm for people making money but changing the rules to fix a bad investment isn't the answer. For the most part these folks knew the rules when they bought and whatever handwriting there was was clearly already on the wall for everyone to see.

Local content has largely left the band and owners want to be allowed to own even more stations in a market. It's the wrong direction.

If the band suffers from anything it's to many stations at too low power levels to overcome the increasing noise floor. This is largely a problem the NAB lobbied to create. If these owners want to be FM owners, create a digital band in TV channel 6 and offer an exchange for their AM spectrum.  Then let the sick AM's die off. After the shake out do a reorganization to put the AM band back to its highest and best use as a regional coverage band with clear channel high power stations. One per owner per region.

Do low power FM translators really help AM? I suppose if you're a day timer it helps you to stay on the air after dark but shouldn't you look into a full service FM if that's what you need to do? How many translators would you need to have to replace your daytime AM coverage? Putting bunches of FM translators, each on a separate frequency just makes a mess of the FM band. Doesn't it make more sense for an AM station to "buy" the FM HD2 of an existing full service station? Most radio listening is happening in cars and newer cars are increasingly equipped with HD receivers. AM'ers can stream to people at home over the Internet too.

The next call is from the FM owners that have been invaded by AM translators cutting off their fringe coverage.

Meanwhile the channel arbitragers have another gold rush. Is this in the public interest?

As a rural FM broadcaster in mountainous Western Washington state, there are a few corners I'd like to fill in too. I've asked about a translator window and been told we won't see one for FM'ers "in the forseable future". The FCC's suggestion is to buy an existing translator. The only one in the county is for sale. For $350,000. That's in a county of 29,000 people. Rural stations just can't afford these prices and it hurts listeners. Why so expensive? Because the CP owner is looking for a big payday when they sell it to someone and move it to Seattle. This owner never intended to build this translator. It's licensed to a nonexistent site (the land owner was never contacted) and it's listed main station knows nothing about this translator. Here is an example of the FCC allowing fraudulent filers to warehouse spectrum waiting for a payday. The blood is being drained from rural communities on behalf of "to big to fail" big market broadcast chains.

Where's the concept of regulating in the public interest? Where is localism? Who does the FCC work for? The NAB or the citizenry?

- - -

Alan Parnau writes:

What about taking the 50 KW power cap off AM's? From what I saw during my 38 year career (now retired), those AM stations with compelling content AND good signals served their communities extremely well, and made a boat load of money for their owners. Look at a list of the top 10 billing stations in the country, usually half are AM, but big signal AM's (WCBS-AM, WFAN, WINS, KYW, WBZ, WBBM-AM, KNX, KCBS-AM all make pretty good coin).

- - -

Mike Share writes:

There is something buried in the proposal which may be good for some while bad for others, if I understand it correctly (I have not read the R&O yet; I have only read about it, so my opinion may or may not hinge on fact):  Reduced protection for "clear channel" AMs. 

One of my stations is on a 1-A clear, which has been a blessing and a curse.  A curse, obviously, because for years we were not allowed to operate at night, and now operate, but at peanut level power.  A blessing because this state of affairs, of having to protect the mother hen on the channel, means fewer stations on the channel, which means greater coverage for us.  In the daytime, about a 200 mile radius of coverage (0.1 mV/m) on 1000 watts; at night, with just 54 watts, a 20-30 mile radius of listenable signal as long as the IBOC/IBAC hash isn't coming in from an adjacent 1-A about 500 miles away.

What I see here is that skywave protection will be eliminated.  This should open the way for more stations on these channels, as well as higher nighttime power levels doable for existing stations.  Even upgrades from class D to B status for many. 

Part of me doesn't want to see more stations on our frequency, however, if my owner moves fast enough, there will be an opportunity for improvements which will reduce interference, especially at night.  A simple power increase at night would involve no construction expense but just a readjustment of a power level on the transmitter.  Up to but no higher than the daytime power level, that is. 

Concerning the PSA/PSSA debacle, I believe the PSSAs are actually still ok, though way too conservative considering that a station that may have 10 watts of PSSA power may be authorized for up to 100 watts nighttime when applying for sort-of-permanent authority. 

The PSA about this?  Just throw out all the PSAs and blanket them as up to 500 watts, or the licensed daytime power if lower than 500, starting at 5am.  If interference complaints ensue, deal with them case by case.  It is entirely possible no complaints will be forthcoming.  Then, extend daytime facilities an hour or more beyond sunset.

The FCC's policies in this area seem to be two-faced.  On one hand (or face) they now would prefer not to authorize a station which is not going to fully serve its market day and night, but will take a former daytimer and give it some inferior level of nighttime power which may or may not be usable.  It does appear that some greater consistency from a user viewpoint is coming with this new policy.

When I was a boy (50's 60's), our main local news station did not have good coverage of the market.  Where I lived, you couldn't tell you were listening to a local station the interference was so bad (this was a Regional channel and the station was originally a Class IV assigned to a Regional channel, about the most awful allocation situation for an AM station), but people did listen to it for local news and sports, as well as the music programming which was offered.  You would have called the format "community radio" in that time.  Evenings featured a different genre of music each night.

Now when I listen to certain class D stations at night even within their city of license, I recall listening to that station from my childhood that you could barely read for static and interference, primarily on-channel from stations that were a few Hertz different in frequency.  So it's not anything that I'm not used to dealing with, but the garden variety listener is not going to put up with it in 2015.  They probably don't understand and don't care why many can be heard part of the day and not at other times.  They just know that things are available 24 hours a day these days.

- - -

Ted Thayer writes:

AM revitalization is a ruse as near as I can tell. The big guns want more hardware to grow future revenues - buy now cheap, sell later a profit. This doesn't help the little guys. There is no revitalization, just limited future profits for a very few well-connected chain owners.

The reason AM has, for the most part, gone in the dumper is the lack of experienced, educated business-people at the helm of vast numbers of AMs.  Most experienced managers won't touch the meager wages paid by most AMs, leaving inexperienced or poor performing candidates for the jobs. There are many lousy managers who have been promoted from within because good ones are not available. It's not a revenue problem - it's a labor problem!

Every successful station I ever worked at - and there were a lot! - had a firebrand professional salesman as the general manager. This people were always educated with at least the equivalent of a BA in business administration and either many years of broadcast experience or a minor in broadcast communications, advertising or journalism. They knew how to promote their product, motivate their sales staff, and to make the subtle changes that increase audience share. They say a good salesman can sell ice-cubes to Eskimos!

Notice, I said nothing in this tome about format. Talk, sports, ethnic, music, mixed formats ... it doesn't matter. Without a competent sales staff no station AM or FM can make a reasonable profit, much less a marginal return on investment.

The cold, hard fact is that broadcasting, even cable, is slowly being replaced by the internet, social media and other sophisticated devices in the ether! Broadcast owners and managers have simply not adapted. Sadly, no rule change on earth is going to "fix" that fact.


If You Have A CP, Build It!

Calculated moves by broadcasters to gain competitive advantages are nothing new.

For example, applications have always sought to maximize coverage and, sometimes as a bonus, block the competition. Such MX applications, along with groups buying as many stations in a market as possible, seek to increase market share by acquisition. No longer do you have to beat your competition by superior programming. All you have to do is have more signals and, playing chess, seek to dilute your major competition's format successes.

Other ploys include filing on and seeking any CP available in an area, even if the company does not want to operate it.

In recent years, we have seen an increase of stations holding a CP and on the last day, sometimes at the last hour, certify that "the station was built as authorized, thank you, but may we have an STA to go off the air for up to a year."


Word coming out of DC indicates there is increased annoyance with "temporary facilities," sometimes little more than a transmitter and antenna mounted on a pickup truck.

Some were used to "walk" a translator from one market to another, hundreds of miles away. Others claim to have built a station according to the CP, so no one else can get the frequency, but now say they need time to begin programming operations - as long as a year. The effect is, essentially, like throwing an elbow at the competition.

Finally, in response, the FCC Media Bureau has taken to note on some CP that a permanent station must be constructed - and operated for a year - before any STA for going silent will be considered.


The BDR suggests that this is actually an indication the FCC is making an effort to do its job on one issue.

Applicants should not be able to get a CP merely to prevent another service to a community. Furthermore, if an applicant has a CP, they either should serve the community or return the CP to the FCC, rather than playing games with the FCC to build a string of STAs.

Indeed, there is evidence, by the lack of interest in the current Auction (98) that there are few places left in the country where FMs that can support themselves can be built.

Might we even go so far as to suggest all of this is proof that the FCC should allocate TV Channel 6 to radio, so that demand for frequencies can be met where people (and businesses) live. 

What do you think? Did we get something wrong? Share your thoughts:  You are welcome - and invited, yes, encouraged - to do so.


The FCC in "normal" mode - Continued

It is interesting to see the "compromise" the FCC struck with Congress did not last long. More field offices are to be closed and/or turned into a sort of "summer cabin" for occasional visits.

Reports have increased from around the country that applications are taking longer and longer before being handled. Combined with the field office closures, is a reminder that the first thing a bureaucracy protects is itself. Background reports indicate that the FCC is pitching, not just remodeling/moving money, but a staff increase in DC.

As it is likely the speed of action on applications will be linked to the FCC's staffing budget, we will know as soon as the appropriations for 2016 are done. .  


The FCC in "normal" mode - Part 2

The Proposal to shut down the field offices

It is interesting to see the way this is being handled - a contractor's study has led the EB to plan closing 2/3 of the field offices and laying off 1/2 of the staff.

Of all the moves the FCC has made recently, this is one that truly seems to have elicited more concern from the folks in the trenches rather than anyone inside the Beltway (in some areas, like the Pacific Northwest, broadcasters joined to tell the FCC how important the offices are to them). But at the same time, the FCC continues to boast to Congress - and to anyone who will listen - about how transparent they are, and how much they listen to those who they regulate.


Should we mention that the industry found out about this from a leaked internal memo?  Or that the FCC denied to Congress that they had received the proposal referred to in the memo over a month earlier and this was their plan?

Want an exercise in frustration? Try calling or emailing the EB for an explanation/clarification. Unless you are high up in the US Government somewhere, you will learn the EB does not feel it needs to communicate with "outsiders" - transparently or any way.

Make no mistake: Closing the field offices is bone-headed. There are a number of reasons, which any clear-thinking person can quickly realize. Quickly indentifying and clearing interference is only one of them - but truly an important one, even if Part 15 noise has not been a priority in recent years.

Services rendered by the field offices are important in the day-to-day activities, although the FCC has made it harder and harder to get the local phone numbers. Fortunately, the Resident Agent usually reaches out to the local community, so someone knows how to contact them. 

Discussing the issue with the industry should have been a natural impulse - unless the goal was something else.

Is there something else going on?  Some other motivation?


While it is impossible to know exactly what are the Enforcement Bureau's motives, there is a well-documented tactic used at many levels of government where proposals and actions often are actually slightly disguised plays by an agency or department for more money.

For example, when a city really wants a tax increase, you will never see bureaucrats or lawyers laid off, nor any perks eliminated - or even reduced. You will see potholes allowed to grow to car-eating size, or the police announcing that after a robbery or non-injust accident they only will send out questionaires because they can only turn out for situations involving injuries.

Eventually the frustration of dealing with the potholes, lack of police response, closed libraries, and other amenities, citizens fold and the taxes are increased. Potholes are fixed. Police respond. Library hours are increased.

Until the next time the City needs money for pay for union raises and benefits.

Is this the FCC's plan? Moving/Remodeling and raises? It seems that the current priorities at the Portals include remodeling the current site and - yep - picking up and moving to a new location in 2017. Of course they want more money to do this, "just" another $51 million. On the other hand, the $21 million spent on field offices - something like just 5% of the budget - is apparently too much.

So it could be that to make sure Congress gives them the money, they will continue until then to impact the end user as much as possible.


The biggest problem is that if the EB does close offices and lay off staff, they may never get them back.

There seems to be an endless supply of lawyers, but qualified broadcast engineers - that is another story. We already know the majority of the current FCC believes broadband is the answer to all the nation's ills from emergency information to social media. Turning off broadcast RF - aside from WiMax - seems to be a priority.

The FCC has lost a lot of talent in the past 20 years. Some still remember the way the FCC prompted an exodus of engineers and other technically capable people in the late 1990s. It would be a shame if the FCC got more money from Congress, but lost a large part of their technical expertise.

At least the bureaucrats and lawyers will get their pay raises.

Sorry for the cynicism. But, closing the field offices is just plain wrong.

What do you think? Did we get something wrong? Share your thoughts:  You are welcome - and invited, yes, encouraged - to do so.


The FCC in "normal" mode

Many broadcasters remember the time when the agency was proactive and helpful, not adversarial and punative. But that time seems to have passed.

One can hardly miss the issues the FCC has put on the front burner in recent weeks. A great deal of it has been in the news.


No, they did not tackle the Part 11 EAS re-write that broadcasters have been waiting for ... and waiting .. for over four years now. (By the way, a recent FCC directive about close captioning takes things backward, as many stations likely will drop relaying EAS alerts rather than risk fines.)

No, they did not tackle the long-needed reforms to many outdated rules and policies that waste tremendous amounts of time and money. Should we mention the horrid "window" scheme for most CP applications that run on for years and years? Should we mention the virtual impossibility of getting most anyone at the FCC to answer simple questions from stations (and absolutely never by email)? Should we mention those three little letters: EEO (and the tremendous hassles contained therein)?

No, they did not tackle the Part 15 RFR interference problems that are crippling many AM stations and other services. Even AM improvement initiatives appear to be on the "back burner," if that. About the only sop to AM operators has been to open the gates on a great translator land rush.

No, they did not tackle reforming the Enforcement Bureau, where thousands (millions) of complaints were just tossed out as "too old" and Forfeitures dropped as the Department of Justice pointed out the EB had run long past the Statute of Limitations with many of its actions.


If there was any confusion that the FCC has become as hyper-political as most of Washington, it should be clear to any objective reader. What are their top priorities?

So-called Net Neutrailty was passed on a party line 3-2 vote.  Ditto a ruling to overturn laws stopping municipalities efforts to provide broadband service. Meanwhile, the FCC found it imperative to change the definition of "broadband" from 4 to 25 Mbps.

And, now we hear the Enforcement Bureau has commissioned a study (like the one that eviscerated the experienced personnel in the mid-1990s) that thinks it is smart to close 2/3 of the field offices and lay off 1/2 the staff. This, by the way, does not seem purely a monetary issue, as the FCC budget continues to grow.

To be fair, the FCC does regulate more tha broadcasting. And they do have to help keep thousands of lawyers employed. But ... these are the most crucial things needing attention?

It is all sort of like Congress letting important deadlines pass while naming new post offices or government buildings.


The whole issue of Net Neutrality - which brought more than 4 (or 6) million Comments to the FCC once the TV Comedian John Oliver encouraged viewers to vent about the equivalent of hiring a dingo as a baby-sitter - hinges on typically shallow reporting, Oliver's rant actually crashed the FCC servers. 

Did you notice the ISPs, cellular and cable companies are generally pretty happy with what has happened?  Do you think that is a good sign?

On the other hand, US consumers pay some of the highest prices in the world for Internet connection, with some of the least competitive marketplaces. There is more monopoly in most places than competition. And that is also the case with cable fees.

The FCC has acquiesed to a system where the program makers say "we want to charge more" and the cable companies say "we have to pass these new costs on." If you notice the similarity to wage negotiations with "public unions," you understand the issue only too well.


The FCC has indicated it is pleased with putting the Public Information Files for TV staitons on line, and now wants to do the same for radio stations, etc.

Those are the files that, in most cases, have only seen daylight during official inspections, ABIP inspections, and the occasional political operative looking for cheaper spot rates. Many stations report seeing a total of one non-official request in 40 years. Some have never had anyone from the public ask to see their Public Files.

But the FCC knows better. After all, it will be easier than ever to fine stations for being a day late in filing their quarterly Issues and Programs lists. Or, an alleged EEO violation.

So, who needs those FCC offices anyway? Only those that need help in resolving interference and other matters. Like broadcasters, for instance?

Sadly, the bureaucrats do not see that as a priority.


A few Congressmen are touting what they call a demand for transparency or, at least, a responsiveness from the FCC to Congressional questions, which it currently works hard not to answer.

The NAB has indicated its support of legislation by Senator Dean Heller (R-NV), which would direct the FCC to let the Congress and the Public know what they were doing, instead of hiding behind ongoing studies and "proceedure."

The whole concept of closing field offices is as bone-headed as the EB was when it tried to fine a station for an EAS Test that failed. We wil not go so far as to suggest eliminating the EB. There is a job for it.

Still, many broadcasters remember the time when the agency was proactive and helpful, not adversarial and punative. It is time the FCC return to those days of being an agency that helps the entities it regulates, rather than being a "hit squad" seeking to pursue political agendas while wringing money out of the regulated by continuing to rely on obscure policies, complex rules, and offering only minimal/limited interaction with the regulated companies.

We may never see the FCC of the 60s and 70s again, but a tiny baby step or two in the direction of enlightened regulation would be most welcome.

What do you think? Did we get something wrong? Share your thoughts:  You are welcome - and invited, yes, encouraged - to do so.


AM Improvement - or not?

In the past two years, we have observed more and more little rumblings and discussions about how to improve the lot of AM broadcasters, who seem to be left out as the HD Radio and other media get industry promotional help and technical advancements. Recently, Commissioner Pai, among others has appeared to strongly endorse AM improvement.

But the commentary by Tom King seems to indicate there is little action on the many suggestions for AM improvement filed as Comments and Reply Comments in the recent FCC AM proceeding.

What has been advanced so far by the NAB and the FCC is simply not enough to stem the growing perception that AM is dying and life support is being withheld. This impression seems to be enhanced by the recent FCC comments at the NAB Fall Show.


The identification of problems facing AM stations has been going on for years.

The proliferation of Part 15 RFI in many places has reduced even higher powered stations' coverage dramatically.

Operating hours is another major issue. Daytime stations are often crippled by being off in the key drive times.

The restricted IF bandwidth of most radios is a problem.

The race by the consolidators to claim as many square miles of coverage drove a lot of ill-advised multi-tower, high powered stations, some with a usable beamwidth of less than 25, or maybe even 15 degrees.

Lack of stereo may or may not be a problem (a number of FM stations have been moving to mono).

There are other issues.


The Part 15 situation is perhaps the easiest way to help stations right now and will have the side benefit of helping other RF services. Observers saw how quickly the FCC moved to acquiesce to the bully tactics of the cellular operators when they came demanding FM stations cut radiation to -130 dBm - or even more!  Yet, the FCC has been hiding under their desks when it comes to noise generated by LED traffic lights, bad pole transformers, etc. that cause harm throughout much of the spectrum. The FCC should take the lead now in enforcing Part 15 regulations.

Daytime stations have begged for help from the FCC. The result was PSA and PSSA powers that often struggled to cover the station's parking lot. Giving Daytimers 500 Watts at 5 or 6 AM seems like a no-brainer, and allowing them to go to 6 PM in a similar mode seems reasonable. Again, the FCC has dragged its feet for years and, using the opposition from some lobbyists and lawyers as an excuse, done little. We ask, what additional harm would be caused to the AM band by the FCC moving on PSA and PSSA right now?

NRSC was a way to compensate for the bandwidth issues. Unfortunately, some stations hit the pre-emphasis so aggressively that manufacturers even tightened the bandwidth a bit and further degraded the AM listening experience. The NRSC Committee continues to meet and issue revised standards. While the Modulation Wars are mostly over, we feel any continued efforts to prevent aggressive pre-emphasis is worthwhile.

AM Stereo receivers went in the opposite direction, opening the bandwidth when the pilot was detected. Sadly, the Motorola-Kahn Wars all but doomed that mode. Many cars on the road still have AM Stereo and their owners notice and enjoy the open bandwidth they get on those stations still running AM Stereo. We have been told AM Stereo is still included in many receiver chips. Those that have the capability should be encouraged to turn on AM Stereo.

Another popular solution, especially given the way receivers are built, was to extend the FM band to Channel 6 (and maybe even Channel 5). Any AM station could move there, get a 24/7 non-directional signal that would cover their market. LPFM and other local resources would have plenty of room - and would drive sales of new (and a business to modify existing) receivers. While this might put another nail in the AM coffin, we have to remember that underserved radio communities are harmed by AM conditions, and small operators who hold AM licenses also suffer. At the least, Channel 6 should be cleared of any remaining TV broadcasters and most AM operators permitted to move there on a ten year transition period, ending with the AM Authorization not sold, but deleted (remember the Expanded Band fiasco?).

Politically this has been a non-starter so far. But, to be honest, there would be some AM improvement in the form of reduced clutter on AM by a thinning of the herd.

Another option that has been adopted by other countries is DRM. There are some issues that would have to be solved to use it in the US, but it is a non-royalty solution that works. As an example, India has just installed a large network of DRM stations which should provide a spark for the radio manufacturers. We feel stations should be allowed – even encouraged - to implement DRM as the band is thinned out.


On the other hand, the cachet of FM has caught the attention of many AM operators, especially the consolidators. FM translator sales have been on fire since the FCC permitted AM stations to own them. A 2-Watt station recently sold for over $4.6 million.

This is AM improvement?

Media Bureau Chief Peter Doyle announced at the NAB Fall Show that he envisions a special filing Window this Fall - talk about fast - to permit even more FM translators for AM stations.

This is AM improvement? Or is it investor improvement?

At least the "Step 2" is to consider trimmed skywave protections. A major political and legal mess. You can be sure the lawyers will put entire families through college while anything like this is debated and delayed.


Almost forgotten in the slow exodus from AM (even many talk formats have moved to FM - even taking the stations to monophonic transmission), is the content.

Content is a separate issue from technical improvements, but clearly the proliferation of foreign language, religious, and sports talk stations have demonstrated that many AM station owners sight is not on the AM facility, but something on FM - translators, Class A, Class B/C, etc.

This is not the place to debate format or the lack of localism on many automated stations. Suffice it to say that we listen less to AM now than at any time in our lives. Most teens know about as much about AM as they do turntables and tape decks. Much of the "excitement" that characterized AM in the 70s and 80s has turned into automated slumber formats.


If there is any honesty in the words coming out of Washington, if they really want to improve the lot of AM operators, the answer is simple:

Stop talking. Do something. Do it now.

Everyone should read the AM proceeding Comments on the EFCS if you have not already done so. Talk up the AM improvement ideas you support on the lists. And take a moment to file ex parte Comments with the Commission.

Some of Tom King's recommendations may or may not be feasible given the political/legal industry lobby's efforts. But some are spot on, and should be adopted as soon as possible. The Commissioners should simply direct staff to do it - now.

Is moving AM stations to Channel 5 or 6 AM improvement? Yes, one can honestly argue that reducing AM clutter is AM improvement. After some AMs move to Channel 6, it might help others to reduce/improve their directional antennas. And ... if there was true demand ... regional Clear Channel stations (not the company) might find a reason - and the capability - for covering large areas, instead of the local market.

AM improvement is possible. All it takes is less talk in DC, and more attention to the potential solutions now at hand.

It is not rocket science, it is plain old fashioned common sense. 

What do you think? Did we get something wrong? Share your thoughts:  You are welcome - and invited, yes, encouraged - to do so.


The Communications Act of 1934 - PICN at 80

It was on June 19, 1934 that President Roosevelt signed the Communications Act of 1934, which established the FCC.

The Communications Act of 1934 was designed to correct the mistakes of the precious two decades, which saw the Department of Commerce (DOC) and the Federal Radio Commission (FRC) failing to have the proper tools to control and guide the new technology of broadcasting - in the Public Interest, Convenience, and Necessity (PICN).

The stories of the 1920's "Free For All" legislation showed clearly that the goverment was not prepared for what happened. From the days of only two frequencies being permitted, power wars, and major disagreements over the commercialization of radio, the FCC was supposed to usher in a new age of regulation that made broadcasting a national resource.

The FCC was not perfect, of course. No government agency has ever proven thus. But, from 1934 until the late 1980s, broadcasting did serve the local communities. The Three-Year-Holding Rule and the 7-7-7 doctrine worked pretty well. There was, on most stations, a balance of news, public affairs (OK, those 3AM records from the Army and National Guard, etc), and other community public service announcements (remember "Lost Dog Alert"?) which brought listeners to every station the basic information they needed every day.


It would be naive to suggest that life and society are the same today as in 1934. Television, Cable, and the Internet - and their effect on communcation and society - were not contemplated in 1934.

That there would need to be adjustments to the Communications Act of 1934 was clear. The question would be: would the changes improve the FCC's oversight and the broadcast industry's ability to serve the public? Or would the lobbyists create something different?

Originally, the rule was one station (AM or FM) in a market per owner. Soon exceptions started to permit combo operations, etc. Nationwide, the limits for TV, for instance were three until 1944, when five were permitted. The theory was it served the Public Interest, Convenience, and Necessity to have the widest variety of ownership (voices) in the country.


In 1953, the 7-7-7 Rule was established. No company could own more than 7 AM, 7 FM, and 7 TV  stations (only five of them VHF) nor cover more than 25% of the US population. Period. The theory continued to ensure no company dominated the airwaves.

In 1970, the FCC added a cross-ownership ban for Radio and TV in the same market, grandfathered stations exempted. Then the Three Year Holding Rule was implemented to stop companies from merely trafficking licenses, but instead develop ties to the local community.

That seemed to work for a fairly long time. Most companies were of a size that the owner knew - or could know  ... or according to the FCC "should know" - what was going on at each of his/their stations. Stations worked hard to be part of a community. And format "wars" were common, bringing real  excitement to the airwaves.

(When cable came of age, the FCC proscribed cross-ownership with broadcast licenses, until a court struck down that rule.)

Then the Telecommuncations Act of 1985, among other things, nearly doubled ownership limits to 12-12-12. Station values jumped dramatically as the larger companies quickly added 5 AMs, 5 FMs, and 5 TVs.

This was the result of the Communications Act of 1934 being "updated" by lobbyists - including the NAB.

But there was more to come.


It was in the mid-80s that things got "weird."  The Cable Communications Policy Act of 1984 and 1992, and the Telecommunications Act of 1996 were a time of heavy "deregulation." In the middle was the ill-advised 80-90 proceeding.

Saying that the Act brought major changes is an understatement. National limits were dropped, multiple stations (as many as eight) were now permitted in all markets. Add to that the new CPs issued to minorities in the 80-90 and the AM clear channel breakdown effort. First the minorities quickly sold out to become millionaires. Then, in short order, over a thousand mergers in the radio industry sharply changed the landscape, leading to large "consolidators" ... including Clear Channel, the largest, with close to 1300 stations. Brokers became beyond wealthy.

In terms of operations, the First Class Radiotelephone License was dropped. Anyone could work on transmitters - even the Sales Manager. The Equipment Performance Measurements were dropped and "the marketplace" subtituted; supposedly, if the station did not sound good, loss of listeners would compel them to clean up the audio and RF chain. Enforcement efforts concentrated on tower lights, EBS (now EAS), and Public File mistakes.

Have the changes made been for the better? In 1996 there were 5100 different radio station owners, in 2003 it had already dropped to about 3800 - a 25% reduction in owners. Stations were bought for well over $100 million. That trend has continued.

In a typical medium market in the 80's, you might have found as many as 20 different companies running broadcast stations. Some were AM, some FM, some were AM/FM combos. Today, the majority of such stations might be controlled by four companies or fewer, with mostly automated jukeboxes running in nearly empty office buildings once the sales staff left for calls.

Sure, you can find some Full Service stations in many places, though they are mostly in the largest and smallest markets. 

More deregulation has continued, but is focused on the TV-Cable area in recent years.


One might argue that the changes are giving the public only what they asked for, based on ratings.

EAS improvements now give better alerts during disasters.

Have stations continued to operate as a real part of the community?

Many broadcasters will quickly point out how fast they moved during Superstorm Sandy or any of  various tornado or flooding situations to stop programming and inform the listeners of what to do and how.

The Public can often rely on broadcasters.  Many do still give attention to the PICN.

On the other hand, few rock stations have any news at all - and have not had news for years. They say their listeners do not care for news. Public Service Announcements and programs are hard to find. On the other hand, stop sets with 10 spots in a row are pretty easy to find.

And situations happen as did a few years ago, when a fire took out the transmitter that served a city with one local station. The large corporation that owned the station flew in an emergency transmitter and antenna - and promptly installed them in the adjacent larger market, so the hits and spots could play, even as the fire advanced on the small city of license.

Meanwhile, officials of the large companies take home millions of dollars in salaries and bonuses. Yet, at the same time thousands of air personalities are unemployable in the industry where they worked for most of their lives.

And lost dog reports are as rare as an honest politician.


John Oliver recently used Net Neutrality as the lauching point of a rant against the current FCC.  If you have not seen, you should take a moment and do so - unless you would hire a dingo to babysit.

While it is true that the current FCC has been and is more broadband oriented than broadcast, several Commissioners have taken it upon themselves to work with broadcasters, most notably Commissioner Pai seeking to help revitalizel AM in many small towns. Commissioner Rosenworcel has spoken out a lot about the growth of LPFM, and its attention to ultra-local affairs

It is our hope that the FCC will continue to look at the broadcast industry as a responsibility rather than a resource to exploit in the seemingly endless streams of Spectral Auctions.

We have come a long way from the Communications Act of 1934. Change has happened. Some good, some not so good.  But Broadcasting does continue to be the major source of reliable communication in the country.

That is good.

What do you think? Did we get something wrong? Share your thoughts:  You are welcome - and invited, yes, encouraged - to do so.

Rod Zeigler writes: "What I find interesting in this article is the timeline. For 50 years broadcasting played by a fairly equitable set of rules which were created on a good premise, that being Public Interest, Convenience, and Necessity. Yes, times change, but why did the basic premise change as well? Technology has advanced at a dizzying rate, but have people as well? Don't we still need the same basic information every day? Why has the premise of public service given way to private and public profit? You can still be profitable and provide good public service!

Could it have been that non-broadcast speculators saw the profits being made when radio and TV were practically a license to print money and decided to get into the game themselves? Not being broadcasters they were ill equipped to make the decisions necessary to continue the profitability. To make their bottom line better they used the Economics of Scale model, and purchased the legislation to make this happen, thinking more stations and consolidating management, would make back the profits they lost due to their mismanagement. Not being broadcasters, and not understanding that, like disasters, all radio is local, they mass merchandised a product aimed at the lowest common denominator, which added even more problems.

Now, we add to the mix a Federal agency overrun by lawyers and bureaucrats without broadcasting backgrounds who are given yearly income quota's to fill and you can see the downward spiral has come of age. This is why we find ourselves in an homogeneous industry where the same programming is heard everywhere. It is an industry where the same management style dictates cutting of expenses to make "goal" from a pie cut into too many pieces.

Any one can walk into any business and cut expenses, that takes no intelligence or imagination. Having a manager come into a business, keep control of expenses, create new income with programming that the community wants, and become profitable in the long term is what was lost with deregulation. When the broadcasters left it created a vacuum. That vacuum has been filled with people that have little or no idea of what they are doing, but have perfected the art of creating the perception of competence to their superiors.

Please do not think I believe that ALL broadcasters are of this ilk, they are not. I speak of the majority of the consolidators that have, seemingly, yearly lay-off's, multiple un-manned stations, and nationwide "me-too" programming. The local Mom & Pop's that live in their communities, while not getting rich, do look to be making it. These are the real broadcasters today, and they are the ones the Federal agencies need to allow to thrive, even though they can't buy the legislation to make it so. "


Is C4 Just What We Need - or Is It Too Explosive?

Matt Wesolowski has an idea which seems very attractive. But for some reason, the idea has gone nowhere at the FCC.

We wonder if it is the idea or the name that is the problem.


Wesolowski operates a small station, WYAB in Flora, Mississippi, just up the road from Jackson, MS, the State Capitol. As many small town operators, he tries to focus on his community, yet not only competes with signals from other markets like Jackson, but has to contend with the larger buildings that sprout up over time, buildings that require more signal for penetration.

There is another problem that plagues many Class A stations: HD neighbors (especially those grandfathered "super power" HD stations) which put out what could politely be called "interference" on their neighbor's channel. We recall seeing a study, about 10 years back, where the "interference" completely encompassed the neighbor's 60 dBu contour. Of course, the FCC determined by Policy that there was no actual interference. 

Especially in the Mid-West and West, where towns tend to be further apart and rural population thin, the ability to reach out past the traditional 12-15 kilometer (8-9 mile) contour would be of great help to bring more folks into coverage.

And, with the WalMartization of America, where entire downtowns disappear into a megastore on the fringes, small stations are desperate to get more coverage - smaller advertisers tend to buy on stations they can hear. Listeners certainly will not respond if they cannot hear.

So, Wesolowski came up with the idea to double the existing 6 kW power level to 12 kW ERP. He positioned it as a bridge to Class C stations with the designation of "C4." So far, his on-line petition has garnered over 115 signatures from existing Class A operators, a clear indication of interest.


An increase of 3 dB is not as great as "doubling the power" might seem at first glance. Even ten times the power does not increase the coverage contours as much as some might think.

Going from 5 kW to 50 kW at 100 feet, for example, only increases the 60 dBu radius from about 9.4 to 16.4 miles, the 70 dBu from 5.3 to 9.4 miles, more or less. A full 100 kW at 100 feet would only push the contour 2.5 miles further - and deliver a huge power bill - not of much use, unless the goal is to change the station to serving an adjacent, larger city. Yes, height is more important than power, but if we are talking Class A, HAAT over 100 m (328 feet) causes a reduction of power.

But some additional power definitely is better than none.

In examples on a web page devoted to showing what the extra 3 dB of signal would do, a small town station like WYRQ in Little Falls, MN, might see 1/3 more potential listeners at 12 kW. WYNN in Florence, SC, could gain 15% more potential listeners.

Either would be a welcome gain to any modest operation.


This is especially important in places where downtowns have largely "vanished." 

On the other hand, the last 15 years have seen a race to move stations closer and closer to larger markets and operate as "rimshots." Indeed the City of License has become an almost useless term for many stations where they do not have a transmitter, studio, on-air content, or, in fact, any real presence in the City of License. Aside from the hourly ID, listeners would never know - or care.

Worse, during emergencies, such as major fires, some of these stations merely continue to "play the hits" in the larger market than show any concern for their City of License.After all, you cannot lose any of the commercials.

So, would giving these stations even more power add to their "service" to the community or make them merely more attractive acquisitions?  Given the changes in the broadcast industry - and an FCC that would like to see all broadcast disappear so they can use the frequencies for broadband - does it matter?


We do feel that times have changed. Broadcasters are under extreme pressure politically, dealing with RF penetration issues, and economically. Radio is not what it was in the 1950s, and will never be so again.

Yet, the need for small stations to provide a strong, useable signal to their communities is palpable. And, in an ideal world - not the one-size-fits-all world so much preferred in DC (unless you have a lobbyist, or a Senator) - there would be simple ways to resolve this and other problems broadcasters, both AM and FM, face. The existing "one-size-fits-all mileage chart is one relic that protects too many stations well beyond their useful signal strength.

Suggestions such as using Channel 6 for all-digital stations, LPFM stations, and solutions for small AM stations seem among the simplest, but politics/lobbying has prevented any action in that direction.

After a lot of thought and consideration, we support a power increase for many current Class A stations. Going to 12 kW makes a lot of sense in a lot of areas, especially where the mileage charts have no bearing on actual reception conditions. 


However, as just indicated, we do not have confidence that any "one-size-fits-all" solution is achievable - or even desirable.

For example, we have a problem with the designation C4. The perhaps unintended allusion to the chemical explosive seems to be one explanation of why the designation is wrong. Class C stations (Class B in Region I) are designed for wide-area coverage. Class A stations are the "local" class.

Labeling a new class as Class C4 would, in our view, only ignite (yes) a race to upgrade stations to the new class and then attempt to manipulate them to even higher classes - or as new rimshots.

Consider a 6 kW station on the SW side of a small market that discovers that at 12 kW, they can move "way out" on the NE and cover not only their City of License, but the next larger market, too. How long will the local service stay local?

If we take the attitude that broadcasting is in danger of being passe, then why not eliminate all classes and Citys of License, and simply allow whatever power and location can be shown, wherever the owner wants it? This is, after all, largely what we have, in effect, today. Some prefer that outcome, which favors script kiddies and speculators over local service.

Our recommendation - should the FCC or anyone else care - would be something like an enhanced Class A (or maybe Class A12). Keeping the "A" designation would defuse some of the issues of what would turn this into another 80-90 mess which, combined with the "minority preference," did little to assist small companies, towns, or minorities - except to make some minority applicants instant millionaires (those with memories can relate how such stations were sold for big bucks even before the CP was built).


A Class A12 (or some something similar: AAA, A2?) that had some specific restrictions, such as not moving the antenna further from the center of the City of License, continued commitment to the local community, and perhaps a market size limit, would be of help to hundreds of small town stations.

As noted, one-size-fits-all is not a good plan. Permitting existing stations, at existing sites, to increase power under most conditions, is a relatively simple, quick and easy to implement plan. Additional options may be worked out in time - something that seems to be the way of things in DC - and some reasonable exceptions might be added to the basic plan.

Unfortunately, experience suggests that loopholes and special interests will exploit things, if the process is not done carefully. We hope Mr. Wesolowski and his supporters take their petition and - with appropriate adjustments - get it to become a formal Petition for Rule Making at the FCC so that it can be accomplished with alacrity and benefit to the community of small market stations.

Recently, some of the Commissioners have proven sympathetic to the plight of daytime and low power AM stations. Some sympathy to the plight of the small market stations would be more than a good idea.

What do you think? Did we get something wrong? Share your thoughts:  You are welcome - and invited, yes, encouraged - to do so.

Richard Rudman responds: I think [you are] on the right track with [your] adjustments to the so-called C4 proposal. A C4 by any other name would have the same ERP, yet not mislead licensees into thinking that there is an assured road for a "power-shackled A" with marginal or no building penetration to achieve "C-dom". My vote: A12 has a nice ring to it.

Terry Cowan responds: C4 or A12?  It is a distinction without a difference.  If a class of station with 12 KW ERP can be added to bridge the A/C3 classes why not?  After all, the only thing keeping an A from upgrading to a "C" class is spacing.  And if a channel can't be found to upgrade to a C3 or higher, having a "C4" would not be a stepping stone to C3 or higher either.
To say that class A is for small communities may have made sense 50 years ago, but today small communities (at least in the west) can't support any class.  That is why they are being moved to larger communities.
Look at retail.  There used to be many smaller stores in the small towns.  They are gone or going.  The residents of small towns prefer to drive to a larger town and shop the big-box stores.

Muchael Brown responds: If we examine the Class Distance of each station class, there is no big gap between A and C3.  I don't see the need for C4.  It's entirely true, however, that many stations - particularly the lower class stations - have many potential listeners beyond their 60dBu contours that sometimes are decimated with co, adjacent, or HD interference.  That's why I believe that we should adopt something akin to the Canadian standards, whereby all Classes except C (and probably C0), are protected to the 54dBu.  C and C0's would be protected to the 58dbu contour.  At the same time, it would be appropriate to eliminate (or at least selectively waive, as Canada is doing) all 3rd-adjacent spacing requirements.  After some eventual "repacking", this should result in fewer stations having the above problems.  3rd adjacents are not a problem at all in modern radios.  Co and 1st adjacents (and HD) are destructive.

Paul Saunders responds: Out here in the Rocky Mountains there are such things as small towns that flourish either as tourist meccas or self contained towns that need community radio. The FCC does not consider terrain when it comes to spacing. Does the FCC belong to the Flat Earth Society? LPFM stations in rural areas have to deal the same ERP problems as A class stations only more so. Like small town newspapers, small radio stations will not die but one size rules and regs do not help. Go for it Matt!

Fred Morton responds:  I think you're spot on. The designation C4 does carry a weird connotation with it. I think something like "A12" makes more sense.

Jerry Mathis responds: Re: Paul Saunders comments on Terrain considerations. The FCC one time took up this issue, and even wrote Rules and standards for considering it. Then it immediately stayed putting that Rule into effect. Perhaps now it is time to take terrain roughness into consideration when allocating FM channels. Let's face it, coverage considerations have undergone a sea change since the FM Table of Allocations was first calculated.


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EAS Testing That Crosses the Line, and Other Distractions

It has been said that having something live in your hands can be a real challenge: a live firearm, live bomb, or a live baby. It is true. Extra care is mandated - or major problems can be in the near future.

Each Spring, a number of states use Live Codes to test EAS systems. This is dressed up as a "Spring Weather Awareness Week" or a similar event. A large number of them occur in March. They usually - but not always - have "Test" in the body of the message.

We still feel using live codes in a test is a bad idea for a number of reasons.

Events of last week have demonstrated some real problems with this practice, more like a bomb than a baby. They show why the long-delayed Part 11 re-write of the EAS Rules needs to get done before the decade is out, and why the US needs the national warning strategy called for by the Partnership for Public Warning (PPW) over a decade ago.


Here is the basic problem: like radio signals, many EAS operational areas often do not stop neatly at state boundaries.

Hence, a "practice" tornado alert (TOR) for South Carolina "leaked" into North Carolina by virtue of adjacent counties on the north side of the state line that monitor signals from the south. Around the same time, what has been described as a corrupted text file may have led to some NW Indiana counties getting an unexpected TOR alert, too.

It was not the only such incident this week.

Another example: states often do not inform their neighbors about what they are doing. The result: testing with a live TOR code this week in Kentucky was said to have alarmed many across the state lines from Cincinnati to Cairo.

Furthermore, it turns out that, while many states do some promotion and public education in advance of their tests, there are stil problems. For one thing, passing tourists or new residents moving in from another state may not have heard about the test and become alarmed. This often results in needless 9-1-1 calls, but can also cause undue alarm in the general population.


Each time a Live Code "leaks" to stations across the line and/or the into cellphone realm, it potentially irritates and/or desensitizes the public to the true life-safety value of warnings.

And there is another issue: the continuing problem of "fake" alerts in advertisements. Ad agencies and young production staffs may think real EAS alert tones and protocols will bring added attention and impact to their announcement. This practice continues to alarm, mis-inform, and desensitize people to the entire EAS.

At least the FCC has finally gotten tired of the complaints about misuse and are issuing some real fines: witness this week's $1.9 million fine to Viacom, Disney, and NBCUniversal for running - on cable channels - a series of advertisments for a movie. Not only did they violate Part 11.45 with EAS tone simulations, the ad superimposed "This is not a test!" and "This is not a drill!" on the screen.

Nevertheless, as soon as these fines were announced, a cable news program ran the entire advertisement on air, complete with the tones and supers. What were they thinking?

And, amazingly, it continues: Late last week, we heard about a spot for Kingsford Charcoal, set to start on Monday, March 11th, contains EAS tones. The NAB sent out a memo to its members, but every station now needs to check out their spot load for Monday.


There are national advisory groups that have met endlessly for the past 17 years to discuss EAS and its needs.

Nevertheless, during all those years, the Rules have not really changed, whether we talk about the so-called "random" testing to merely specifying what is a "week."

We can only hope that the Commission will take positive action on the recommendations in the most recent CSRIC IV reports hopefully due out in a few months.


All-in-all it is sad that, in many places, EAS continues to be more of a irritiation and alarm than a source of warning alerts, aka the Chicken Little Syndrome.

Between these fake alerts, the endless tests that plague some areas, Live Code testing, and Weather Service "Message Flooding" in markets small and large when a real event happens, leads many listeners and viewers to routinely "tune out" EAS alerts.

Worse, generic text to speech alerts often interrupt real, live, local weathercasters and newscasters who are trying to put facts on the air. Message flooding makes that even harder.

We can - should - and must do better.


The goal of "Weather Awareness" type events - the "cover" for using Live Codes - is laudable: to help make EAS more useful to many listeners and viewers. Unfortunately, most agencies that issue EAS events do not yet make any real effort to determine propagation.

They leave it to November 2011 National EAS Tests to show what is already known: the system itself is broken. (Word has it that a CSRIC IV subgroup will make recommendations to change that situation.)

First of all, RWTs are pretty much useless as practiced. Most often today they are run without a script by an automation system. Generally they end up as the so-called duck farts run in the middle of a commercial barrage.

RMTs could be of great value - if the states and operation areas would trace and ensure the propagation is complete. This is not being routinely done now, except in a very few places. Their one real value could be to use RMT’s to assess dissemination by LP stations by aggregating logging results using the email capabilities of the new EAS decoders


Unfortunately, RWTs and RMTs seem to have value only in providing the FCC Enforcement Bureau with a simple method to fine stations that mis-program their automation and fail to send them. 

Live Code tests, such as the Tornado and Tsunami Alerts are not needed. There are other ways to ensure a real alert would be heard - and that includes states working to get all the stations in affected areas to include TOR or TSW (whatever is appropriate) in their EAS receiver filters.

Part of the problem with EAS is the continued silly situation of broadcasters feeling great pressure to run local and state EAS events while many in the emergency management community have not yet taken to heart the value of warnings as part of overall effective emergency management. The lack of appreciation by many local agencies as to what their interruptions to programming and how these alerts sound like on-the-air on radio or TV comtrbutes to what is often a sonic and informational disaster.

Then there is the monitoring/relay system. While redundant for primary sources, it does not, most cases, bother to check the other end. When it actually is done, stations are discovered with poorly programmed EAS boxes, audio outputs that do not go on the air, and other issues.


The reality is that while there have been reports and proposals, the Rules have not yet changed substantially from ideas that date back to the Emergency Broadcast System (EBS). 

We can only hope the continued reluctance in Washington, DC, to change insistence of not releasing any new rules before the entire Re-write is done will itself be done very soon. 

It really is not hard to test and verify the EAS works as needed. Why this has not been done shows a lack of leadership from the FCC and local entities.

Meanwhile, Live Code tests are problems waiting to happen. They and the RWTs as currently described in Part 11 should be eliminated immediately. RMTs used as diagnostic tools should be scheduled on a three to four week cycle, and the results investigated and tabluated. The FCC and FEMA should endeavor to help solve the issue of broadcaster and local agency cooperation. Most of this really could be put into motion quickly.

When the next EAS NPRM comes up, we hope many people will weigh in so the life-safety value of timely warnings that can really help save more lives and property are enhanced.

It should be. Lives may depend upon it. Certainly the reputation and viability of EAS do.

What do you think? Did we get something wrong? Share your thoughts:  You are welcome - and invited, yes, encouraged - to do so.


The Non-Broadcast FCC Needs to Change Its Approach

NAB President Gordon Smith stated in words what broadcasters have felt over the past four years or so. In the approximately 50 points that previous Commission Chair Julius Genachowski cited as his achievements, Smith noted "There was not a single accomplishment outside of the broadband realm. Not one." 

Only time will if the new Chairman, Tom Wheeler will continue down that path or be influenced by Commissioner Pai's efforts to help AM - and broadcasting in general.

We hope that the latter is the path taken. Broadcast has suffered through neglect, championing of the broadband policies, and by some apparently incompetent moves. For example, the "Window" mode of accepting applications for AM and FM has done little but encourage excessive speculation and filings for stations that were never intended to be built, but that blocked competitors or were sold to other speculators. The lack of enforcement - or even efforts to clarify what the FCC policies are - has led to companies "gaming the system" with silent stations broadcasting only a few minutes a year, translators being moved across states and regions, and other "tricks" that seem totally unrelated to "serving the public."

If the FCC restores - and Congress may be in the shadows on this with a Telecommunication Act rewrite under consideration - an emphasis on what broadcasting can do, including disaster information, as no other service can do - including the fragile cellular system which is more concerned with how to increase revenue from data streams than truly provide public information - it will be a real benefit to the public.

That is what the FCC is supposed to do. Not sit around pushing rules, policies, and punitive inspections that do little but keep lawyers busy (and Congress should rewrite the EEO rules as well) and prevent stations from addressing the reason for being on the air in the first place: service the public.

The Telecommunications Act of 1996 was, perhaps, one of the worst in terms of making broadcasting stations little more than a commodity, and the resulting speculation has largely fed the streaming and other modes of broadcasting aside from "Over the Air."

We hope the AM Revitalization proceeding under way will lead to some real attention to where broadcast is - and how it can utilize its strengths to grow and be more than "just another source" in the media jungle.

If you have an opinion, there is still time to let the FCC know that broadcast is still important. The "Reply Comment" period has been extended to March 20th. With over 150 Comments, the Commission might get the idea that they need to change their approach to broadcast.

And sooner rather than later.

What do you think? Did we get something wrong? Share your thoughts:  You are welcome - and invited, yes, encouraged - to do so.


Link To: Previous editorials

Thanks everyone!