In case you thought the rule making on computer moment method modeling for AM proofs had been put in the finito file, you may have another think coming. Cohen, Dippell and Everist (CDE), one of the oldest broadcast engineering firms around, has sought partial reconsideration.
Not that the folks at CDE appear to have much problem with the basic idea of moment method computer modeling for handling cumbersome directional antenna proofs. To the contrary, their petition simply seeks some practical guidance relative to precisely what the Commission will be looking for in such proofs. For example, while the new rules list what must be included in the model description in order to derive the parameters, the rules do not specify what information must be provided with the proof when it’s filed with the Commission. CDE reasonably asks that the Commission provide a tad more guidance so that applicants preparing such showings for submission will not be forced to guess at what the Commission wants to see.
CDE also raises what it refers to as the “moral hazard” issue. This is where things get interesting.
CDE is concerned that “unfettered computer modeling” could lead to “creative approaches by some industry management to specify a site change of an existing directional antenna array to a less appropriate (and much less valuable) piece of land”. And such alternate sites might be “less desirable in terms of existing reradiating objects.” For example, an applicant could propose a site under power lines, or in a ravine, or in the middle of an “inhospitable industrial park” – any of which might be unacceptable under the pre-moment method modeling system. And yet, with some digital legerdemain, such sites “could be made to work, and monitoring point field strength values explained away”, and the site might be approved even though the antenna pattern would most likely not afford the originally specified protections.
CDE urges the Commission to take steps to “impose some form of restraint on this possible practice.” While it offers no detailed proposals, CDE does mention the fact that, back in the 1960s, the Commission required the submission of information about the “environment” of the proposed transmitter site, including a description of the “general character” of the area, heights of building and other structures in the vicinity, and the like.
Increasing the types of information to be submitted as part of a directional proof is, of course, seemingly inconsistent with the goal of streamlining that process. But CDE may have a point here. Too much streamlining could open the door to – um, how can we say this delicately? – applications which, were they mortgages, might be deemed “subprime”. It would not be desirable to unleash on the AM universe a bunch of directional operations whose signals have not been effectively checked.
Ideally, now that CDE has raised this issue, the Commission may address it effectively. If you have any thoughts on this, you’ll have 15 days from Federal Register publication concerning the CDE petition to oppose it (or otherwise comment on it).