[SBE] 13-249 filed comments

[a9xw at cs.com]

Before the
FEDERAL COMMUNICATIONSCOMMISSION
Washington, D. C.


In The Matter Of: 


Notice of Proposed RuleMaking  13-249
Revitalization of AMbroadcast Radio


December 7, 2013


Comments of Henry B.Ruhwiedel, individual, retired broadcaster, former SBE nationalDirector, former FCC Licensee of WOVR FM, Versailles, IN.  


ISSUE:  Degradation ofreception and coverage.  
	The public has beenmigrating to other modes, FM, satellite, recorded media in partbecause the AM spectrum has been degraded to where the high fidelitybroadcasts of before 1960, have become impossible.  There is no wayof discerning which came first, but the contemporaneous reduction inAM receiver performance in preference to FM receiver performance, theincrease in audio processing for the sake of loudness competition inpart due to format competition, the promotion of FM's inherent noiseadvantage and higher fidelity (15 kHz vs 9 KHz aural spectrum) drovemuch of the audience to FM from AM. A con-commitment of market forcesthat reduced variety in programming, consolidation of ownerships,removal of localism, simulcasting, and central source programming forthousands of co-owned stations in effort to survive the dwindlingaudience figures and thus financial stability have added to thereduction in appeal of AM radio.  A notable few stations have faredwell because of mostly localism, community involvement, that garnercommunity loyalty. I saw few because most outlets simply compete formass market share with demographic purity of age, ethnicity, or nicheinterests. 
	The FCC's effort tointroduce AM Stereo with four competing systems failed to enhance AMas a viable music source, because no one system was chosen as wasdone in FM and TV stereo. Thus few receivers took advantage of AMstereo, and the public regarded AM stereo much as the RCA video disk,an advance but unworthy of general acceptance unlike the CD and DVDor even the Phillips audio cassette still in use today after morethan 50 years. 
	The expansion of the AMband to add 1600-1700 KHz provided few new “voices” as thatportion of the band still remains largely empty except for religiousbroadcasters, the lack of receiver coverage for the frequencies, andnow the near absence of even technically relevant AM receivers.
	The Addition of pre sunriseand post sunset micro power to daytime only station aided few tomaintain an audience into the evening hours.  Stations many of whichhave less than 10 watts, and well into low single digits in realityhave nearly no local coverage from lack of field strength andinterference from sky-wave propagation from the more primary channeluser stations. It would have been more effective in many cases forthese stations to erect part 15 transmitters around their city oflicense and simulcast to them instead of 3-5 watts from an out of thecity rural location where the 1 millivolt per meter contour may notreach more than the nearest point of the city of license or thenearest cow barn. 
	The introduction of IBOCwith significantly low power levels never allowed the HD Radiocoverage to equate to the analog AM coverage, and the additionalspectrum pollution just increases the base noise floor and thedecreasing selectivity of AM receivers decreases the D/UD ratio ofreception. 
	Manufacturers have decidedit is not a value to have a good AM receiver in any radio device. Itis very difficult to even find a radio that has sensitivity andselectivity in the AM band to be useful beyond Class 1 and Class 2stations in urban areas. Reception beyond the city grade contour isproblematic  to impossible.   Anecdotal evidence of my personalpurchases of radio devices found the AM tuners in even expensiveportable and mobile units to be hardly better than a crystal diodeand oatmeal box wire coil.  One name brand unit in my home, to listento 890 KHz  WLS, receives the signal from 860 to 925 on the dial, andbest audio is when it is tuned to 903 KHz. Even then, despite thestations 50 KW and about 23 miles distance, the signal is noisy. Thecomputer in my clothes washer completely drowns out the audio. A 10KW station less than 10 miles away is barely audible. I purchased two“emergency” radio units that commonly sell for $39.  he AMreception was as bad or worse, the FM I actually measured as needingover 100 microvolts to even detect carrier and the short wave sectioncould only get 1 station at night.  Considering the AM radio is theONLY ubiquitous radio device in emergencies, with FM a distant secondthis is a sad state for emergency preparedness.  




Recommendations:


To reduce interference to AMreception is a multiple source issue. 
	BPL internet over powerlines should be banned immediately. With satellite and cable deliveryof internet and data services, there is no home in America thatcannot get service and BPL only serves to be a source of interferenceto AM and other MW transmissions. 
	Unlicensed devices:  Alldigital and computer devices should be regulated under part 15 rulesto emit no more than 5 microvolts per meter at a distance of 1 meteron any frequency from DC to 500 MHz and not more than 10 microvoltsper meter at a distance of 1 meter at any other frequency.  
	Eliminate IBOC. The signalserves hardly any useful service and pollutes the band with widesidebands that interfere with adjacent channels and on the poor AMradios being sold today, a single IBOC station can interfere withmany channels. 
	AM Mandatory radiostandards. Any radio device capable of FM broadcast reception shouldinclude AM reception. In addition, the AM and FM receivers shouldmeet a minimum of good engineering practices including an effectivenoise reducing channel width filter [9 KHz, pass band with a minimum30 dB rejection of 2nd adjacent channel) and sensitivityof a minimum 10 microvolts for 16 dB SINAD reception at allfrequencies. In addition, the receivers should have a switchable ortunable filter to reduce/eliminate one sideband to reduce/remove beatnotes from 9 KHz channel spaced stations.
	AM Transmission should belimited to 99% negative modulation and 130% positive modulation  forall modulation components summed. 
	AM stations should beallowed to use reduced carrier compatible AM, with either singlesideband audio or vestigial sideband (1.5 KHz bandwidth) operating inmonophonic service and up to 10 dB carrier suppression instereophonic service at the option of the licensee. This to reduce onchannel and adjacent channel interference, and reduce in channelcarrier interference from 9 KHz spaced channel stations with signalsreaching the US 10 KHz channel spaced stations. 
	Any radio device marketedas an “emergency” radio receiver must meet the minimum receiverstandards above, and be tunable in 1 KHz steps or continuous tuningwith a calibrated analog or digital frequency readout to permit“tuning in the blind”  to a frequency that may be vacant due tointermittent operation of a broadcast station in emergencies. AFCcircuits (automatic frequency control) must be employed to maintainstable reception under varying signal levels for all bands. AGCAutomatic gain control circuits must have a minimum range of 20 dB toavoid unnecessary volume adjustments by users. Audio output to besufficient to produce a 90 dB SPL A weighted sound level at adistance of 1 meter from the speaker, or 75 dB SPL A weighted forin-ear listening devices. A maximum audio output of 105 dB SPL fromany device. This to prevent communications from persons and otherdevices from not being heard for public safety. (ie not being able tohear an emergency vehicle siren or announcement because the localdevice is too loud).
Universalityof service.  
	With the vast majority ofstations being centralcast and unattended, with merely a EAS unit forlocal service the public is at a serious disservice in time of mostneed. I propose all markets must have 1 station that is staffedlocally 24/7. This station would be self designated and the AMstation would receive favorable preference on fee waivers,applications (except license transfer) and mandated unrated marketnews service rates to insure information availability. In additionthe designated AM station would be permitted to interrupt all othermarket stations that do not provide local news service to simulcastany level 1 or level 2 emergency information. (NWS warnings, Localregional or national governmental warnings, and declared emergencycommunications from first responders such as evacuation orders.  Onlystations that provide local live news service capable of respondingto emergency conditions would be exempt provided they also providedthe same public safety information. In markets without an AM stationthis me be performed by an FM station under the same criteria.  Thiswould specifically exclude amber alerts, watches, weekly or monthlytests. Stations would be responsible for establishing their owntechnology and service agreements to provide this universal lifesafety information. The designated station may promote and advertiseits function as the designated emergency station for its community.Text format in RDBS may be provided as an option for service to thedeaf. 
	In emergencies, any AMstation may operate with its best power/pattern at any hour toprovide emergency communications and public safety information. Thestation would announce such operation when it is not in compliancewith its license parameters.  Announced at 30 minute intervals: Thisis station WXXX AM operating under emergency condition authorizationto provide critical life safety information.” Such operation wouldbe noted in the station log and the FCC notified at first convenienttime of such operation as has been previously allowed by theCommission rules.  Content may include directed communications tospecific individuals to facilitate location, rescue or reunificationof the population. IE: Members of the XYZ church in ABC parish shouldmake their way to BCD location for rescue and transport. Rescue,shelter and reunification centers are located at  DFF GFF HFF proceedto these locations quickly and calmly. 


Eliminationof flea power AM. 
	No authorization for AMoperation with less than 100 watts TPO unless the lower powerprovides 100 microvolts service contour over the entire city oflicense. If less non daytime power can provide such coverage, powermay be reduced to that sufficient to cover the city of license.Coverage to be established by field measurements at eight diverselocations representing receiver locations in residential, businessand industrial areas and documented as verifiable field monitoringpoints equally determined as valid as directional pattern verifiablefield monitoring points.  Such operation to be with apparatus tominimize skywave radiation above 25 degrees above the horizon.Co-channel stations may not complain of distant station interferenceunless it is within their 1 millivolt per meter contour.Objectionable interference threshold shall be 20 dB SINAD D/UD to areceiver of good engineering standards. 


LowPower AM


TheCommission to permit a new service to augment the loss of any AMnight time or PSS PSR and provide additional diversity to ownership. 


Thenew service would allow any AM only that is owned by a licensee ofless than seven stations in the nation, or persons not currently alicense in the broadcast service, may propose non directional 24/7service in the band 1600-1700 KHz, with 100 watts daytime and 25watts night time. Such stations would be licensed by physical spacingand have no interference protection.  Co channel stations at minimumseparation distances of  100 miles. First adjacent separation minimumdistance of 50 miles and second adjacent station at a distance of 25miles. Preference given to the applicant with the least number ofcurrent licenses/application. Such stations may not be located within30 miles of the main post office of the top 50 markets. All notdaytime operation will reduce all skywave radiation to the minimumpossible without extraordinary means. 


Digital Onlyoperation
	Untilsuch time as digital radio is included in all receiver products soldor used in the USA for the AM band, digital only operation isprohibited. 


Content
	Consistentwith market forces no restriction is proposed upon licensee holderscurrent capacity to provide content it chooses for the audience itchoose to reach with the exception of the universal emergencytransmission listed above.  Such emergency information may not extendmore than 5 minutes in total length except for immediate life safety,nor interrupt the non designated station more often than once per 30minutes unless to provide 100% new information. Regulations forcontrol of content responsibility are not waived but good faitheffort to operate and provide only locally relevant life safetyinformation is paramount. Locally relevant means areas within thestations city of license and immediate environs within the 1millivolt per meter licensed contour. 


Diversification: 
	Anylicensee with more than 50 stations national, and more than 20% ofany market media (AM FM TV LPFM) must operate one station per marketwith local staff 24/7 provide public access to management, and meetminimum local news, weather to accumulate two hours per week of suchprogramming represented in all day parts and on all days as regularlyscheduled material. Failure to provide this minimum public serviceshall result in non renewal of all licenses held in the market. Thoseunwilling to operate in this manner may distress sale their assets inwhole or in part. 




RespectfullySubmitted:


HenryB. Ruhwiedel
5317W 133rdAve
CrownPoint, IN 46307
fax219 662 6991
e-mailA9XW at CS.COM

 
 
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