With AM industry debilitated by numerous factors, the Commission is looking to treat some obvious symptoms.

Amplitude Modulation radio (AM to its friends) is old and by all accounts pretty sick . . . so the FCC’s wheeling in the crash cart, gelling up the defibrillator paddles and hoping to shock the patient back to vitality. Will it be enough? Will it be in time? 


Back in September, then-Acting FCC Chairwoman Mignon Clyburn announced that the Commission was considering a package of reforms to bolster the survival prospects of AM stations. And now, not quite two months later, the Notice of Proposed Rule Making in the new “Revitalization of the AM Radio Service” docket (we’ll call it the Revitalization NPRM) has been released. 

The FCC’s goal is to help AM licensees remain economically viable. Besides soliciting comments on these specific proposals, the FCC invites any other ideas for improving the quality of AM service.

Anyone paying the slightest attention to the radio industry already knows that AM has faced 30 or more years of struggle to hang on to a meaningful market share. Those of us who are a little long in the tooth (one metric: we were around when the Beatles’ White Album first came out . . . on something called “vinyl”) recall when FM was the poor stepsister of radio broadcasting. AM dominated the dial. 

But by the 1970s the erosion had begun. Listeners were looking for better sound. FM had it.  AM, not so much. By the mid-1980s, AM radio represented 30 percent of the nation’s radio listening hours. By 2010, it was down to 17 percent. Among younger demographics, the percentages were in the single digits.

Physics, construction techniques and electronic gadgetry have all added to AM’s woes.

Thanks to the laws of physics, AM signals bounce off the ionosphere at night. (The ionosphere conveniently thins out during the day thanks to the sun’s radiation, allowing AM signals to streak out into space and not bother anybody down here on earth; but when the sun goes down, the signals bounce back down.) The bounce, or “skip”, sends the reflected signal far afield of the transmitter, so that bounced AM signal can (a) be heard by distant listeners and (b) interfere with signals where the bounced signal ends up. For that reason, only a limited number of AM stations can operate with any appreciable power at night. Most AMs are left with little or no nighttime power and are unable to cover their market areas at night or, in many cases, during critical pre-dawn morning hours.

Meanwhile, the use of steel frame reinforcement and/or aluminum siding is ubiquitous in modern construction. Those types of materials somewhat impede AM signals.

Possibly most importantly, AM signals are particularly susceptible to interference from electronic devices – so the proliferation of computers, television sets, power lines, fluorescent lights and other RF generators that have been a boon in many ways are nothing but a bane to AM radio. 

Against this background come the FCC’s proposals intended to give AM stations a fighting chance of survival. 

AM-Only FM Translator Filing WindowThis is the proposal that has drawn the most huzzahs because it may present a realistic opportunity for cash-strapped AM operators to get FM translators. Ironically, it’s not so much an “AM Revitalization” plan as an “Escape to FM” alternative.

Since roughly 2009, AM stations have been allowed to rebroadcast their programming on FM translators whose 60 dBu contours are within the smaller of the AM station’s daytime 2.0 mv/m contour or a 25-miles radius from the AM station’s transmitter site. At first the FCC allowed only then-existing translators to be used for AM rebroadcasting. That left AM licensees to scrounge around for translators that were both for sale and located (or could be moved to) near enough to the AM station to be rebroadcast. In 2012, the FCC relaxed the rule a little, allowing AM stations also to use the new translators coming on line with the grant of a flock of long-pending Auction 83 applications. 

But two basic problems emerged: (a) often translators were available only from third parties at premium prices; and (b) translators tended not to be located where the AM stations could use them, thus requiring relocation. The process of moving a translator to a useable location typically is complex, time-consuming and expensive.  

The solution?  An FM translator window for AM stations only. In the Revitalization NPRM the Commission is proposing a one-time-only filing window during which only AM broadcasters would be allowed to apply for one and only one FM translator per AM station. The translator would have to operate in the non-reserved band and be located in compliance with existing requirements (i.e., the translator’s 60 dBu contour would have to fit within the smaller of the AM’s 2.0 mV/m contour or a 25-mile radius of the AM site).   It would be used solely to rebroadcast the AM station designated by the AM-licensee applicant. To ensure that that last limitation would be honored, the translator would be “permanently linked to the AM primary station acquiring it.”

These obviously stringent limitations are designed to avoid the “land rush” crush of zillions of translator applications that occurred with the last translator window for all comers in 2003. The Commission has tentatively concluded that the imposition of such eligibility criteria will pass muster under the longstanding Ashbacker test.

And those limitations could get more stringent. The Revitalization NPRM asks whether applicant eligibility should be restricted to allow only Class C and Class D AM stations or “stand alone” AM stations to file. No mention is made whether an AM licensee that already has one or more FM translators would be allowed to file for an additional translator.

If an AM-only window were to be opened, the Commission would consider eliminating the availability of “Mattoon waivers”. Those waivers, which technically remain available (at least for the time being), permit the avoidance of certain procedural rules in the processing of applications to relocate translators so they can be used to rebroadcast AM stations. Mattoon waivers can speed up such relocations considerably.

The FCC also is soliciting comments on whether an AM-only FM translator window will affect – for good or ill – full-power FM stations, small businesses, businesses owned by minority groups and women, other FM translator licensees and LPFM broadcasters.

Daytime Community Coverage. The FCC’s rules require an AM station to put a 5.0 mV/m contour over its entire community of license during daytime hours. That tends to limit, severely, AM stations’ ability to relocate and improve their facilities, since AM stations – especially ones with multi-tower directional antenna systems – require a lot of land for their transmission systems.   For years the FCC has let AM stations slide by if they put a 5.0 mV/m daytime contour over at least 80% of the area or population of their communities of license, a relaxation which has helped some. 

Since 2009, the Minority Media Telecommunications Council (MMTC) has been pushing for even further relaxation. MMTC argues that, even under the relaxed city-coverage standard, AM stations often still can’t change sites or make improvements. That inability forces AM licensees to undertake “protracted waiver proceedings” which can strain the resources of both the applicant and the FCC. MMTC proposes that, like NCE stations, each AM station should be required only to put a city grade signal (5.0 mV/m in the case of AMs) over 50% of its community of license.  

In the Revitalization NPRM, the FCC acknowledges that finding sites suitable for AM antennas is increasingly difficult and expensive. And the FCC is willing to consider some relaxation of the coverage requirement – but not to the full extent of MMTC’s proposal. 

The Revitalization NPRM proposes to allow a licensed AM station seeking to modify its facilities without changing its community of license to cover only 50% of either the area or population of its community of license. That should open up additional potentially useable sites that aren’t available given the current regulatory constraints. 

However, because of the importance of community coverage, an applicant for a new AM station or for a change in community of license would still be expected to specify a site that complies with the current daytime community coverage requirement (i.e., 100% coverage of the community with a 5.0 mV/m contour). 

The Revitalization NPRM solicits input on the likely effect of the proposed change, and also whether the relaxation should be extended to include new or change-of-community applications. The Commission is particularly interested in hearing from broadcasters about the anticipated costs and benefits of the proposed change: would the change materially help licensees (and if so, which ones), or would it lead to delivery of “sub-standard signal quality” to significant portions of communities of license?

Nighttime Community Coverage. As we previously mentioned, because of the transmission characteristics of AM signals, AM stations more often than not must operate with reduced power at night. But AM stations are still subject to nighttime community coverage requirements similar to the daytime coverage standards described above. (The precise limits are complicated; suffice it to say, as the Revitalization NPRM cogently summarizes, AM stations must “serve the bulk of their community of license at night”.)

Because of the reduced nighttime power limits, the nighttime community coverage requirement makes the quest for suitable sites for nighttime transmission systems even harder than is the case with daytime coverage requirements. Acknowledging this, the Commission is now contemplating the complete abandonment of nighttime coverage limits for licensed stations. If that proposal were to be adopted, such stations would not be required to cover any portion of their community of license at night. 

Applicants for new stations or changes of community would still have to demonstrate some community coverage – either 50% of the population or 50% of the area of the proposed community of license during nighttime hours with a 5.0 mV/m contour or a nighttime interference-free contour, whichever value is higher. But that would still be a significant relaxation of existing limits.

This aspect of the Revitalization NPRM – particularly the notion of totally tossing the nighttime coverage requirement – is radical, as the Commission seems to recognize. It asks a range of questions about what effects – good or bad – such changes would have on the AM industry and on the listening public. The FCC is also looking for any alternative suggestions anybody might have. (Along these lines, the Commission itself suggests that it might be a good idea to impose at least some minimum nighttime coverage standards on stations are the only radio service licensed, or which provide the only nighttime service, to the community.)

Death to the “Ratchet Rule”. The “Ratchet Rule” is a truly arcane requirement imposed on Class A or Class B AM stations seeking to modify their facilities. The Ratchet Rule for Dummies: Such stations must demonstrate that the net results of the proposed modifications will be a reduction in the amount of skywave interference caused to certain other AM stations. (For a more detailed, but probably less comprehensible, discussion of the nitty-gritty of the Ratchet Rule, check out our earlier post on the subject.)

Back in 2009, the revered engineering firms of duTreil, Lundin & Rackley (DLR) and Hatfield & Dawson (H&D) asked the FCC to ditch the rule because it discouraged or impeded stations trying to alleviate nighttime coverage difficulties due to noise and man-made interference. Eight parties filed comments in support of their petition; nobody opposed it.

The FCC now tentatively has agreed that the Ratchet Rule should go and seeks comments on whether that’s really a good idea.

Implementation of MDCL Without Prior Approval.  Modulation Dependant Carrier Level (MDCL for short) control technologies or algorithms have been developed to allow AM stations to reduce power consumption while maintaining audio quality and station coverage. (Feel free to refer back to our previous post on the topic for a quick refresher course on MDCL.)

Since September, 2011, the Media Bureau has been granting permanent waiver requests (30 in all so far) and experimental authorizations (16 to date) permitting use of MDCL techniques. Word back from these MDCL pioneers is all good: significant power cost savings and little or no perceptible effects on signal coverage or quality.

Accordingly, the FCC now is proposing to let AM licensees use MDCL technology without prior FCC authority, provided they notify the Commission within 10 days that MDCL control technology is being employed. There are a couple of minor catches: first, MDCL controlled stations would have to be able to reach full licenses power at some audio input level or when the MDCL control technology is disabled; second, they would have to disable the MDCL system when field strength measurements are taken.        

Currently, domestic AM transmitter manufacturers (Harris and Nautel) offer MDCL control technologies. Additional MDCL options – transmitters and external adapters – are apparently in development by others. The Commission asks how it should deal with the anticipated expansion of available hardware in terms both of how the technology may permissibly be deployed and what information MDCL-equipped stations should report to the FCC.

In 2011, the jury was still out as to whether simultaneous use of both MDCL and a hybrid HD system would cause increased out-of-band emissions and/or suffer reduced signal quality of its HD stream. But the Commission hasn’t received any complaints about stations operating that way, so it tentatively plans to permit all AM stations – even those with hybrid digital facilities – to implement MDCL control technologies without prior authority. 

AM Antenna Efficiency Standards. The FCC’s “minimum efficiency” standards require each applicant for new or modified AM facilities either (a) to meet minimum height requirements which vary by frequency (the lower the frequency, the taller the tower) or (b) to meet specified field strength requirements. 

Arguing that the minimum efficiency standards make it tough to find suitable AM transmitter sites – particularly for lower frequency stations that need taller antennas – MMTC proposed that the FCC adopt a “minimum radiation” standard instead. According to MMTC, that change would allow stations to use very short antennas and “enjoy more flexibility in site selection, including rooftop installations.” 

The FCC expresses some bewilderment about this component of MMTC’s proposal, which the FCC says is “unclear as to both the exact problems that MMTC perceives with our current regulations, the specifics of the rule or rules it proposes to eliminate or replace, and why that solution is preferable.” Nevertheless, in the revitalization spirit, the Commission will consider reducing the minimum effective field strength values. That would offer AM broadcasters some relief by enabling them to propose shorter antennas. 

Specifically, the FCC seeks comment on whether it should reduce minimum field strength values by roughly 25%. The welcome mat is also out for comments on pretty much any technical and/or policy considerations relating to minimum antenna efficiency. For instance, would lower efficiency transmission systems face potential interference or stability problems?  Are the FCC’s existing methods sufficient to assess the performance of very short antennas? Would such antennas produce excess heat that would harm the transmission system? Would the RF radiation rules need to be revised to cover very short antennas? And if you can think of any other antenna efficiency-related questions, feel free to answer those as well.

The Revitalization NPRM proposes a lot of remedies to better the condition of the AM radio patient. But it does not solicit comment on some of the more radical ideas MMTC and others have floated – the heart transplant options, if you will – such as giving each AM station a digital channel in the band presently assigned to TV Channel 5 and 6, or switching the AM band to digital-only operation. Instead, the extensive changes proposed in the Revitalization NPRM are all aimed at helping the financial viability of the AM service rather than altering the technical quality of the signal it can deliver to the listening public. Indeed, a number of the Commission’s questions reflect concern that some of the proposals could lead to less or worse service. 

But the AM service is somewhat like a geriatric patient, subject to a variety of infirmities that simply may not be remediable, certainly not in the short term. In such cases the care-giver should do whatever it can and hope for the best. Here, the FCC is clearly looking to stabilize AM radio’s financial heartbeat as an essential first step to preserving the patient.

The deadlines for comments and reply comments have not yet been set. Check back here for updates.