This is a response to a Radio World op ed by Larry Langford, owner of WGTO(AM), Cassopolis, MI.
This response was also published in Radio World online on May 14, 2021. The originally submitted response follows:
Those who know me know that I am a supporter of the new MA3 all-digital AM service and like Larry Langford, I am very much opposed to the MA1 hybrid system. Unfortunately, the bad experiences from MA1 has left a bad taste in people's mouths regarding IBOC digital radio in the AM broadcast spectrum. The main dilemma with MA3 of course, is the flash cut. If you flash cut to digital, you completely cut off analog listeners. This is why some of us worked on assuring that there were protections to consumers as well as protections to other impacted broadcasters by calling for a 30-day notification period before a AM station can flash cut to digital.
Right now, there are many smaller AM stations in rural and suburban areas that have been successful at getting FM translators with fairly decent coverage within their service areas. At the same time, there are many community groups in suburban, urban and deep urban areas who desire to have a nonprofit independent voice, a voice that does not compete with, but instead complements the selection of other stations on the local dial. With more listeners abandoning radio for streaming services, we shouldn't be focusing on having the same voice in more than one place, but instead, more choices and more voices.
The idea of allowing another 250-mile move opportunity for AM stations that flash cut will do absolutely nothing to help improve LPFM. If anything, it will further foreclose on opportunities for new community voices, in favor of a duplicate version of an existing voice available elsewhere. Many of these "satellators", which Larry speaks of are in more rural areas, areas that still have some LPFM availability. Therefore, moving these translators out of those areas and towards more urban and suburban areas will not do anything for LPFM growth, but will create increased interference to existing LPFM stations, especially considering that there is no proof of performance enforcement on FM translators with directional antennas and there have been many cases where the translator was built with a nondirectional or other non-compliant antenna, despite the construction permit calling for a specific directional pattern. Because of how valuable urban translators are (because of the toxic HD over analog culture that has been established), a small AM broadcaster would never be able to afford to move a translator out of an urban area, up to 250 miles for use as an AM HD crutch. Again, this does nothing to help increase opportunities for LPFM broadcasters.
If we are getting to this point of where HD receiver penetration is starting to increase, then we need to address the other major waste of duplicating spectrum that could be better used for local voices, and that is the use of an FM translator to provide "fill-in" service for a primary FM station's HD multicast stream. If the Commission, the NAB and the rest of the industry is really serious about diversity and more efficient spectrum use, then we need to remove the incentive for FM stations to use their HD capacity as nothing more than an overglorified STL for translators. If we are increasing the HD receiver penetration, not only will it increase for AM, as Larry would like to see, but it will also increase for FM. And, if that is the case, then there would be no need for more or moved translators. Instead, listeners looking for other services (including co-owned AM station streams) could simply tune to the HD2/3/4 of a full-service FM station, which can provide a better digital coverage than a 250 watt translator in most cases.
We, as an industry, both radio and television, need to better look at how the spectrum is used and make appropriate changes. We have been seeing a lot of rulemaking activity where existing VHF television stations are asking to move to UHF. Currently, TV Channel 6 has only 10 full-service stations. Of those ten, two have already asked the FCC to move to UHF due to reception issues and receiver antenna compatibility with other stations in their market. With the opportunities that ATSC3 can provide, including mobile and portable viewing, there is no room for a service that requires a larger antenna to receive (also thinking of the whole cell phone FM receiver debacle with the headphone as the antenna). The industry needs a long term plan to revitalize AM and that plan should be is to migrate stations to FM spectrum. While other countries, like Mexico have been very successful in migrating AM stations to FM, there is simply not enough room at the inn to migrate even the Class C and D AM stations into the existing 100 channels. We need to follow the lead of Japan and Brazil and start phasing in facilities on spectrum outside of the existing FM Band. This would mean at the minimum, reallocating the Channel 6 spectrum to provide 30 new FM channels or better yet, Channels 5 and 6 for 60 channels. The radios are readily available as they are marketed in Brazil and Japan. Some existing receivers could be modified with a firmware change. A lot of low band spectrum is going to waste and could be better used for other purposes. I am pretty sure some hams out there would be very appreciative to have access to Channel 2 (54~60 MHz), especially for amateur television use during sunspot cycle peaks. I know I am one of them.
The automotive and radio receiver industry needs to make HD Radio, standard equipment, not a "luxury option" like with some manufacturers. Our culture needs to embrace the HD subchannels and not use them like a crutch for analog translators, but instead, use them the best we can to provide the most choices and the most voices on the original app made for listening to audio.. radio. This way, everyone has a place on the dial, one place on the dial.
Michelle Bradley, CBT
KU3N
Founder
REC Networks
Michelle Bradley is the founder of REC Networks and a national regulatory advocate representing LPFM and other citizen's access to spectrum initiatives.
