On October 21, 2015 the FCC adopted a First Report and Order (First R&O), Further Notice of Proposed Rule Making (FNPRM), and Notice of Inquiry (NOI) in the matter of Revitalization of the AM Service, MM Docket No. 13-249. The text has been published. Don Everist, AFCCE’s FCC Liaison, has prepared a helpful preliminary overview of FCC actions and proposals, showing how they align with views as stated in AFCCE comments and reply comments submitted in the Docket in early 2014.
The First R&O initiates a process whereby AM licensees and permittees may file FM translator modification applications in 2016, and applications for new FM translators by auction in 2017. It also relaxes daytime and nighttime community coverage standards, eliminates the “ratchet rule,” allows wider use of Modulation Dependent Carrier Level control technologies, and reduces AM antenna efficiency standards by 25 percent.
The FNPRM proposes modifying AM protection standards, revising the rule on siting of FM cross-service fill-in translators, modifying partial proof of performance rules, modifying rules for Method of Moments proofs, and requiring surrender of licenses by dual expanded band / standard band licensees.
The NOI seeks comment on issues related to opening the Expanded Band to further development. Comment is also sought on possibly modifying the main studio rule.
If you think AFCCE should seek reconsideration of the First R&O, or should take a position in the FNPRM or NOI, please let us know your specific suggestions as soon as possible, ideally including draft filing text. You can do so as comments to this post for others to see. Or, you can send your comments to Steve Crowley, AFCCE’s Engineering Rules and Standards Committee chairman, at firstname.lastname@example.org. Please submit comments on the First R&O by November 20, 2015, and comments on the FNPRM and NOI by December 4, 2015. If you have any questions, please contact Steve.
I suggest that the AFCCE take a position on the incendiary FCC proposal of further encroaching upon protections afforded to clear channel AM stations.
While the AM broadcast band has many technical deficiencies for radio reception, there is one reception attribute that sets it apart. That one attribute is long-distance radio reception, particularly at night. We should be very hesitant to give up that one fundamental attribute of the AM band in favor of minor increases in local coverage.
The AFCCE can speak to the signal propagation characteristics of the AM band that uniquely enable long-distance reception, the heritage of clear channel AM stations, and the irreplaceable radio service in vast areas of our nation that will be lost if current protections to clear channel AM stations are reduced.
This message got to me simply as an item from your NAB address, so please send it onward.
1. I do not think there is any need for a Petition for Recon of the R&O. There is one matter that requires correction or possibly clarification, and I will describe it and send it out when I have a cogent explanation prepared. I will prepare that for filing by our firm but it can certainly be brought up by anyone else who wants to.
2. I see from Don’s nice summary that nothing in the NPRM was opposed by AFCCE in the initial rulemaking stages, although there are items on which AFCCE did not take a position. I will strongly object to any AFCCE position other than neutrality or support of the Commission proposals.
3. I also support many of the changes described in the first item in the NOI, and I may offer my firm’s comments as suggestions for comments by AFCCE, but I believe the second one is not an engineering matter and (although I think the main studio rules should be unchanged or tightened up because they are so often violated in spirit if not fact) therefore it would be inappropriate for AFCCE to take a position.
And thanks again to Don for codifying the previous AFCCE positions.