In response to the blog written by FCC Chairman Tom Wheeler about AM revitalization, REC does agree that there needs to be an improvement in the AM service. This can be done in several ways:
- First and most importantly, re-purpose AM as a regional broadcasting service giving priority to the Class A and B stations and restoring the pre-1980 sanctity of the clear channel. Class C stations should be given an opportunity, perhaps on an auction basis to upgrade to the extended band to allow them to operate 10 kW daytime and 1 kW at night.
- Class D stations should be removed from AM altogether and placed in new spectrum between 76 and 88 MHz.
- FM translators for AM stations should only be an interim solution and in no case should a Class A or B AM station be permitted to operate a translator.
- FM translators should be made available for LPFM stations and they should be able to be moved as a minor change without regard for contour overlap between the old and new locations.
- The FCC needs to create and enforce stronger Part 15 regulations that no only protect AM spectrum but also the high frequency (3-30 MHz) bands from unnecessary interference. REC is deeply concerned that our existing Part 15 rules will not be enforced with the closing of field offices.
The FCC needs to make a decision on HD Radio. Is it, or is it not a failure? If stations operating HD need to run analog translators in order for listeners to hear the HD multicast streams despite the many years that HD Radio has been deployed, then HD is a failure. If full-service stations wish to promote HD Radio, they should not be worrying about AM translators. Instead they should be putting their AM stations on HD multicast streams. In addition, the National Association of Broadcasters needs to do a better job encouraging the Consumer Electronics Association to deploy many more affordable models of HD radios of all types on the market. The FCC is contributing to the crutch by allowing HD multicast streams on analog translators.
REC feels that there should be one more opportunity for new non-commercial LPFM stations in the FM band and the hyperlocal LPFM stations already on the air should be permitted to improve their coverage through a long overdue power increase. We also need to create new rules that encourage LPFM development, especially in rural areas. At the same time, the FCC needs to be more aware of gamesmanship that takes place in the LPFM and FM translator services. Some LPFM grants happened because the FCC was either asleep at the switch or because of policies that prevent the FCC from preventing gamesmanship.
Finally, The FCC should also be encouraging the creation of new small businesses by opening up new broadcast spectrum for commercial lower power broadcast services including those LPFM stations who wish to transform their organization and stations into commercial stations. REC still remains opposed to commercial LPFM stations in the 88-108 MHz spectrum but we will support commercial low power hyperlocal broadcasting elsewhere in the spectrum.
