Friday, December 31, 2010

FCC proposes changes to Travelers' Information Stations

The FCC is soliciting comments on proposals to change rules for Travelers' Information Stations. (TISs) These are low-powered AM stations, often in the expanded band, usually offering information about road construction and/or congestion. They may also provide non-commercial information about tourist attractions. Three organizations interested in these stations asked the FCC to broaden the scope of permissible service for these stations.

It appears some practices that are common among TISs are not particularly legal.. indeed, the NPRM notes that a Notice of Violation has been issued to TIS WQGR42 in Santa Monica, California for relaying a NOAA Weather Radio station. Also apparently not normally allowed, is broadcast of the same program on multiple TISs. (widely done by stations here in the Nashville area, though it's possible they have a FCC waiver)

The primary question being asked is what type of programming should these stations be allowed to broadcast. Some of the types proposed:

  • Relays of NOAA Weather Radio.

  • Amber Alerts.

  • Alternative emergency numbers when 911 is inoperative.

  • Homeland Security terror alert levels.

  • Public health information.

  • Civil defense information.

  • Information about 511 information services.

  • Simply, the broadcast of any information of a non-commercial nature.

  • One commenter suggested NOAA Weather Radio could be broadcast only when particular SAME codes are detected, indicating certain types of severe weather alerts exist.

    The NPRM also asks:

  • Should TIS stations be allowed at a distance from major roads?

  • Should it be permissible for the same program to be simulcast by multiple TISs?

  • Should the service be renamed the "Local Government Radio Service"?

  • Friday, December 24, 2010

    More AM call changes

    HAWA Honolulu 1500 KHKA CC from KUMU
    OKLA Midwest City 1340 KGHM CC from KEBC
    CALI Visalia 1400 KRZR CC from KEZL
    GEOR Dry Branch 1670 WPLA CC from WFSM
    GEOR Toccoa 1420 WVNG CC from WLET
    VIRG Alexandria 730 WTNT CC from WXTR
    WEST Huntington 1470 WNBL CC from WRWB
    FLOR Fort Walton Beach 1400 WFDM CC from WZFN
    NEWM Isleta 1510 KMYN CC from KABR

    Ibiquity proposes "AM RDS"

    Ibiquity (the HD Radio/IBOC folks) and the NAB have released an "AM Digital Data Service System Study Report". This report proposes a data system for AM radio similar to the RDS system available on FM.

    Read the report here.


    (hopefully the above sentence will quell any wild rumors of ADDS being the death of AM DX(grin)!)

    The ADDS proposes to provide:

    - Station Message Service.
    - Station Name (call letters) up to 8 characters.
    - Station Message up to 158 bytes. "Check us out at", something like that.

    Presumably the SMS is for information about the station itself. It can change (there are provisions for notifying the receiver the Station Message has changed) but probably not very often.

    - Program Service Data.
    - Title
    - Artist
    - Album
    - Genre
    - Content
    - Commercial

    The first four are probably familiar to anyone who's worked with CD-ripping software or MP3 files. Ibiquity proposes to broadcast the ID3 tags for a musical selection. Tags are valid up to 1,024 bytes. The proposal calls for the commercial tag to contain:

    - Price
    - Date until which the price is valid
    - URL (web address to locate the product online)
    - Type of delivery (some products, like music downloads, can be delivered online -- others may require visiting a bricks-and-mortar store)
    - Name of seller
    - Description of product
    - *picture* of product (in 1,024 bytes???)
    - Logo


    This system does NOT propose to extend the station's signal beyond its current bandwidth. If the station is already using IBOC, it will continue to occupy the bandwidth it already does. If the station is NOT using IBOC, adding ADDS will NOT widen the station's occupied bandwidth.

    Three sets of data carriers are proposed. Only the first set is obligatory; the other two sets are optional but will greatly increase the speed at which data can be transmitted. (at the expense of potential self-interference -- it is possible adding ADDS will cause the station to interfere *with itself*.)

    The obligatory set of carriers is at 181.7Hz either side of the main carrier/station's quoted frequency. Since few AM receivers have much response below 300Hz this should be fairly well rejected. These carriers will be 26dB below main carrier.

    The optional carrier sets are at twice and three times this separation -- 363.4 and 545.1Hz. These will be 40 and 45dB respectively below main carrier. This gets into territory not rejected by the receiver's filtering -- but in most cases 40dB attenuation should be enough to make them inaudible below ambient noise levels.

    With just the obligatory carrier set, a data rate of 91.5 baud should be possible. If the optional carrier sets are added, up to 1,098 baud should be possible.

    The system is designed to be compatible with IBOC.


    At this point this is simply a study. It's not (yet) part of the standard, let alone ready for any station to broadcast it, let alone for any receivers to be available.

    IMHO this is good news for the AM DXer. It is essentially "RDS for AM". Many American FM DXers (myself included) have found FM RDS indispensable for identifying stations running continuous classical music/NPR talk shows/etc... European FM DXers don't believe there are still American FM DXers who *don't* use RDS! (it seems just about every FM DXer in Europe does) It does run the risk of generating additional self-interference, but that's not going to make things any worse for us.

    Monday, December 20, 2010

    AM call changes

    The following stations have changed callsigns recently:

    FLOR Jacksonville 600 WBOB CC from WBWL
    OHIO Niles 1540 WYCL CC from WRTK
    NEVA Mesquite 1250 KACE CC for NS
    IDAH Wendell 1340 KXSL CC for NS
    FLOR Leesburg 1410 WQBQ CC from WRHB
    IDAH Middleton 1400 KXIV CC for NS
    NEWM Isleta 1510 KMYN CC from KABR
    GEOR Rossville 980 WDYN CC from WUUS

    Congress proposes relaxing LPFM restrictions

    H.R. 6533, the “Local Community Radio Act of 2010”, has passed both Houses of Congress and has been sent to President Obama for his signature. Since it is highly unlikely Obama will veto the bill, it will be law by the time you read this.

    When the LPFM service was created, the FCC initially proposed to allow low-power stations on the 2nd-adjacent (separated by 0.4MHz) and 3rd-adjacent (separated by 0.6MHz) channels to local full-power stations. After considerable lobbying by the National Association of Broadcasters, the FCC dropped 2nd-adjacent channels, but they refused to change their mind on 3rd-adjacents.

    After further lobbying, Congress did it for them – passing, in 2001, a law requiring the FCC to place 3rd-adjacent channels off limits. As you might guess, this restriction greatly limited the number of possible LPFM stations. H.R. 6533's primary purpose is to undo the 2001 Act.

    Going over the bill point-by-point: (and remembering that I'm a TV engineer, not a lawyer!)

    Section 1: simply establishes the “Local Community Radio Act of 2010” name, so people don't have to call it “HR6533”.

    Section 2: Repeals the restriction on 3rd-adjacent channels.

    Section 3: Orders the FCC to eliminate minimum distance separation requirements for 3rd-adjacent LPFMs. (Section 2 repeals the requirement that the FCC must create these restrictions, but allows the FCC to choose to keep the restrictions. Section 3 orders the FCC to not keep the restrictions.)

    Section 3 also prohibits the FCC from further reducing the separation requirements for 1st and 2nd-adjacent operation. However.. it allows the Commission to waive 2nd-adjacent restrictions if applicants use terrain-sensitive methods (Longley-Rice) to establish no interference will result. Stations that receive such a waiver must suspend operation immediately if the FCC notifies them of an interference complaint.

    Section 4: Prohibits the FCC from relaxing distance separations from stations (including FM translators) which broadcast a radio reading service on an analog subcarrier. In practice, few markets have more than one such station, and they're generally in the non-commercial band where there are few LPFMs.

    Section 5: Requires that LPFMs, FM translators, and FM booster stations remain equal in status. In other words, a new LPFM cannot bump an existing translator – and a new translator cannot bump an existing LPFM. The Commission is also required to maintain all three of these services as secondary to full-power stations.

    Section 6: Requires the FCC to address the potential for LPFM interference to 3rd-adjacent signals at the input of FM translators.

    Section 7: For 3rd-adjacent operations.. LPFM stations are required to provide the same interference protection to full-power stations that FM translators are required to provide. LPFMs authorized on 3rd adjacents must, for their first year of operation, periodically broadcast announcements inviting listeners receiving interference to full-power stations to report such interference. LPFMs must relay any such complaints to the FCC and any affected full-power stations within 48 hours and must cooperate in addressing such interference.

    LPFMs on 3rd adjacents “...shall be required...” to address interference complaints within the protected contour of the full-power station, and “...shall be encouraged...” to address all other interference complaints.

    In certain circumstances*, 1st, 2nd, 3rd-adjacent, and co-channel LPFMs must protect full-power stations from interference outside those stations' protected contours, to the same extent that FM translators must do so. Protection is not required in areas far enough from the full-power station that a LPFM could be authorized there on the same frequency.

    *”Certain circumstances” means the full-power station is licensed to a community in New Jersey. The Act doesn't put it that way – it says “...significantly populated States with more than 3,000,000 population and a population density greater than 1,000 people per one square mile land area,...” New Jersey and Rhode Island are the only states with more than 1,000 people per square mile, and Rhode Island has only a few more than 1,000,000 residents.

    The FCC is required to accept complaints at any distance from a 3rd-adjacent station, and to accept complaints of interference to mobile reception. It doesn't say what the Commission must do with such complaints...

    Section 8: Requires the FCC to conduct study on the economic impact of LPFM on full-power commercial FM radio. (in my humble opinion the cost of the study will exceed LPFM's economic impact on commercial FM radio...) The Act does not require any action be taken on the basis of this study.

    What does it mean?

    LPFM interests would have liked to see more. They'd rather not have to battle with thousands of out-of-state translators for channels; they'd like to have hard-and-fast distance separation requirements beyond which, interference complaints would not be accepted.

    But with the NAB so bent out of shape over LPFM, I think you can reasonably assume H.R. 6533 was the best bill LPFM interests would get.

    I think the FCC will first address LPFMs that may currently be silent after losing their frequencies to new/modified full-power stations. Some of these stations may be approaching the one-year silence deadline, after which their licenses will be canceled.

    Next, I think the FCC will address stations that are operating, but on less-than-optimum frequencies. The LPFM here in Nashville is currently operating under waiver on 2nd-adjacent frequency 107.1. The operation is legal but the LPFM suffers considerable interference from WUHU-107.1 in Kentucky. 103.9 and 94.9 are much clearer frequencies here. I suspect the LPFM will file for one of these frequencies, and I believe the FCC will consider such applications before they consider any for completely new LPFM stations.

    Only then will the Commission consider applications for completely new LPFMs.

    Friday, December 03, 2010

    AM station major change requested

    Jeffersontown, Kentucky: 1200KHz:
    WGRK requests move from 1540 Greensburg.
    Power from 1,000 watts daytime only (500 watts critical hours)
    Site from 37-15-34N/85-30-57W


    5,000 watts daytime only (2500 watts critical hours)
    38-18-58N/85-42-13, but critical hours 38-11-04/85-29-57.

    This is a move of 119km (74 miles) (for the main site) into the Louisville metropolitan area.
    The critical hours and daytime sites are 23km (14 miles) apart.

    If granted this would be the only station I know of to use different sites daytime and critical hours.

    FCC proposal on TV spectrum refarming

    edited by w9wi 2010-12-03 1041 to add the title I forgot the first time!)

    OK, I've had some time to read the FCC proposals on further refarming of TV spectrum. The way I read it (don't guarantee I've got it right)

    The link:

    The highlights:

    - No specific channels are targeted for refarming. They propose to make all UHF channels co-primary between TV and new land mobile services. Any channel surrendered by a TV station would be available for land mobile. Land mobile would protect existing TV facilities, but new TV stations would protect land mobile.

    - Stations would be encouraged to voluntarily share their channel with another station(s). Nobody would be required to channel-share. Stations that volunteer would receive a cut of the revenue when surrendered channels are auctioned.

    - FCC envisions two HD streams could be broadcast over a single channel. More than two SD streams could be transmitted. They mention some stations fear sharing would result in poor HD picture quality; an inability to add subchannels; and/or the inability to implement mobile DTV.

    1.Channel splits would not necessarily be 50/50. Stations might agree to some other split.

    2.Stations would be individually responsible for things such as EAS, indecency, children's educational programming, etc..

    3.The FCC does NOT propose to allow the addition of new stations, not currently authorized, to a shared channel.

    4.They ask about sharing between commercial and non-commercial stations. Should a non-commercial station, on a channel reserved for non-commercial operation, be allowed to offer half of its channel to a commercial station?

    5.They also ask whether LPTVs should be allowed to share channels, either with each other (IMHO they already are!) or with full power stations.
    (the idea of sharing a channel between a LPTV and a full-power station brings up some interesting issues. To the best of my knowledge it is not possible to split an ATSC channel among more than one transmitter – if two or more stations share a channel, they must share the same transmitter. It is not possible to split the power levels either. You can't operate WIIW-LP's half of channel 14 at 15kw while operating WHTN-TV's half at 500kw. So if a LPTV shares with a full-power (FP) station, either the LPTV becomes a FP station or the FP station limits its power to LP levels...

    Not sure what the FCC is thinking here.

    At one point they write “...we do not envision that channel sharing, from a technological perspective would entail a fixed split of the six-megahertz channel into two three-megahertz blocks.” It is simply not possible to split a six-megahertz channel into two three-megahertz blocks if you expect an ATSC receiver to decode either block! Then again, at another point in the document, they do suggest they understand how the channel could be split...)

    6.The Commission is insistent that no station volunteering to share a channel would lose any must-carry rights on cable/satellite. They're also insistent that no new must-carry rights be created.

    - The FCC understands there are serious problems with VHF. They wish to discourage stations from moving from VHF to UHF.

    - To that end, they have determined that VHF reception on indoor antennas is a problem.

    - Both an outside engineering firm and the FCC's own staff measured a variety of available indoor antennas. They found the gain on UHF channels ranged from -6dBd to +21dBd. On VHF-high, only 30% of antennas tested had more than 0dBd of gain; some were as low as -25dBd. They didn't even bother to test these antennas on VHF-low! (many of them were marked on the package as not working on VHF-low.)

    - The FCC considered VHF power increases of up to ten times. (which could allow as much as 1600kw ERP on VHF-high. I believe there may be an existing analog station in Kuwait operating at this kind of power level, but with a VERY directional antenna.)

    - Engineers felt a power increase won't make much difference. They suggest a reduction of spurious emissions from consumer devices is necessary.

    - The FCC said, quote:“While it would be desirable to reduce that noise, the rules limiting spurious emissions from unintentional radiators have been crafted to provide protection of licensed services while allowing production of economically viable devices.”

    - In other words, they're willing to allow consumer electronic devices to interfere with OTA TV reception in order to keep device prices low. (though realistically, imposing new limits on spurious radiation would do nothing about devices already in the field)

    - FCC proposes to increase power anyway. In Zone I, a four-fold power increase would be permitted for VHF stations. (from 10kw maximum to 40kw on VHF-low, from 30kw to 120kw on VHF-high.) No change is proposed from the 45/160kw figures in Zones II and III.

    - There will be no change in interference protection requirements. Which in practice probably means few if any power increases will be possible...

    - They also propose to impose mandatory antenna performance requirements. The All Channel Receiver Act (which required TVs to receive UHF from 1964 on) gives them the authority.

    - Compliance would be required with ANSI/CEA standard 2032-A, “Indoor TV Receiving Antenna Performance Standard”. This establishes a minimum gain of -12dBd for VHF low, -8dBd for all higher channels. Among other things, it also establishes overload susceptibility standards for amplified antennas.


    - Many stations will not be interested in spectrum sharing.

    - Some smaller stations will be interested. For example, I can see Sinclair merging their Milwaukee stations WVTV and WCGV into a single station, comprising two program streams on the RF channel 18 transmitter. Or, Nashville-area stations WJFB (two SD home-shopping streams) and WHTN (two SD religious streams) merging into a single transmitter, transmitting four SD streams on RF channel 44.

    - I can also see this happening in smaller markets. Maybe in Fort Wayne, WISE-TV (RF-18, NBC) merging with WPTA-TV (RF-24, ABC) into a single transmitter, transmitting two HD streams on RF channel 18.

    - The technological attempts to encourage stations to stay on VHF are pointless. Engineers have already indicated power increases won't help. (and those increases are limited to a fraction of the country, and will probably be nearly impossible to implement due to interference concerns)

    - The antenna performance requirements are a very good idea. Unfortunately, they're too late. Millions of viewers have already purchased antennas that simply do not work on VHF.

    - PSIP remapping will ensure any spectrum sharing will be invisible to viewers. (beyond the need to rescan) WHTN and WJFB may both be transmitting on RF channel 44, but they'll continue to be channels 39-1 and 66-1 respectively as far as viewers are concerned.

    - I think we'll hear more about LPTV before this proceeding is complete. I don't think they thought out that paragraph very well.


    Doug Smith W9WI
    Pleasant View, TN EM66