An Open Letter To FCC Commissioner Ajit Pai
Dear Commissioner:
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As a child, I was thrilled with AM radio. The stations and air personalities in my hometown got me so excited about radio that I am now celebrating my 45th year in this great industry. I loved radio, and I loved that I could listen to distant signals at night to hear stations in faraway places.
At the time, my radio stations were on the AM dial. But it wasn't long before I became enamored with FM, which could offer better audio fidelity (in stereo!). I soon discovered that it wasn't AM radio I had been in love with, nor was it FM radio. It was just great radio. But as my generation grew up, so did FM, and it eventually took over the majority of listening on the dial.
Today's modern radio stations are having to compete with lots of digital alternatives, and today's youth don't have to try to tune in distant signals at night. Just about any any radio station in the world is just an app and a few clicks away. AM was invented for a time when there were no better technologies.
You have mentioned the need to improve the AM situation and made it part of your mission at the FCC. I'd like to encourage you to take this further and faster.
Though there are plenty of successful AM stations around the country, the recent abandonment of AM by Radio Disney is just one more reason to make AM radio's needs a higher priority. Disney's research indicated that AM wasn't where their listeners were coming from. Frankly, it was no secret in the industry that their initial plan to reach kids and moms on AM was flawed because young moms are primarily FM listeners.
AM listening appears to be hanging on with baby boomers, who may be more accepting of the sound and reception issues that come with it, but aging listenership will make the survival of AM an even bigger issue. AM has become the home of Talk radio, Sports radio, and many specialty formats that were created to aid its survival. Just the same, AM needs help.
When I was a young radio DJ, I worked for a number of stations. One was a daytimer, where we were required to shut down at sundown. Other stations I worked for reduced power in the evening and could no longer be heard by parts of their audience. Though I always understood the whole interference issue, it always seemed odd to me that some stations, some signals, were granted privileges others were not.
At this risk of irritating my successful FM station readers, who have their own survival and financial issues with a difficult economy and what some might say is an oversaturated radio dial, I think it's time to find an innovative solution to create more equality among broadcast station owners. No one can afford an inferior signal today.
In an ideal world, all signals would be on a single band -- FM -- and all would be equal in power and signal coverage. We are living in an age where technology is making new, formerly unimaginable things possible, but we're not yet able to accomplish that ideal. HD Radio is helping FM to some extent, but interference issues keep AM from working nearly as well.
Yes, I do understand that there are not enough frequencies available to move every AM to FM. But what if there were very smart technology that could make that possible? Is anyone working on such a concept?
Respectfully, the signals of AM and even FM stations were designed for a different time. Stations originally slated for smaller cities are now unable to serve the entire community, which has grown around them and expanded miles outside the signal area. In the interest of safety and radio's role in communicating in an emergency, these antiquated allocations are no longer valid in most cities radio serves.
While addressing the options on this AM problem, may I suggest you review an alternative that not only gives AM better (and hopefully equal) coverage, but allows all FMs to provide equal coverage in their markets. Though creating such a giant jigsaw puzzle is a tall order, the problem will only worsen as our population centers grow and radio's coverage can no longer serve them. This is the time the FCC needs to address the whole picture for proper and equal community coverage for all signals.
I know the commission is considering offering FM translators to AM stations. It's a start, but frankly, it's not a great alternative because they will still be disadvantaged compared to higher-powered, full-coverage signals. Consumers aren't likely to understand why one FM fades out while they're still in the market and another doesn't. Translators aren't the long-term solution radio needs.
And some AM owners, especially the big gun signals, probably wouldn't want to give up that position (though most would like to be on FM as well). Some suggest that part of the FM dial should be dedicated to must-carry simulcasts of all AMs, but that is obviously fraught with technical issues and political challenges.
I can almost hear some of you saying, "But Internet radio solves all these problems!" Yes, Internet radio does put everyone on a level technological playing field. But as of now, it's not the right playing field for broadcasters, who need to serve the entire local market -- including those who may not have Internet service, or who can't run up their data bills with streaming audio. And, crucially, without an over-the-air signal, radio stations would not be able to serve their communities during emergencies.
Many FCC leaders have come and gone in my 45 years in radio. Some left a legacy, while others did not. Your legacy, Commissioner Pai, could be as the man who saved AM broadcasters and gave consumers a better experience.
Though you're surrounded by loads of very smart people at the commission, I'd like to propose you conduct a symposium on this issue. Gather all the smartest people in radio technology, the manufacturers, the NAB team, and the broadcasters who are affected. Explore new technologies and broadcaster needs, and see what the outsiders can bring to the table. For instance, I know of one unproven technology that claims to make AM signals better and eliminate the interference issues, allowing AM to do better in an HD Radio environment. Chances are there are lots of smart people with lots of smart solutions that did not exist even a few years ago.
I understand that addressing this issue of AM-FM equality seriously may be not be popular politically. Many people may not want a solution, and they certainly don't want more competition. But at the end of the day, this has to be about consumers and the best experience for them. The market will work its way through every challenge.
Could you start with a call for ideas, needs, and solutions, go through them, and invite people to participate in an "AM Radio Day" at the FCC to discuss issues and propose ideas? Though this is bigger than a one-day symposium, it's a starting point.
My fear, honestly, is that government will push a solution that may not be helpful in the long run -- like FM translators. By opening this up to a true dialogue among broadcasters, tech experts, and brilliant minds who understand new technologies, you could affect true change that benefits consumers and broadcasters.
No matter what direction you choose, I encourage you to listen to the broadcasters and provide a solution that gives them the ability to fully succeed.
Eric Rhoads
I’ve read with interest your various laments about the state of radio broadcasting.
For many, many years I’ve heard mostly the same thing from radio broadcasters. We need to tell our story better, we need to do more of the consultant sell, we need to have better sales training, we need a PR campaign, we need to do more marketing, we need to talk to our customers, etc. And one of my real over-used favorites from radio folks is one that you trotted out and that is that “perception is reality.” There is always the feeling that “we need to change the perceptions about radio.” Maybe so, but I’m not convinced.
In recent years, radio broadcasters have discovered “digital,” whatever that means. Now, they are surprised that their “digital” assets are growing and their traditional OTA service revenue is declining. What a surprise!!!!!
I think about radio’s “problems” a little differently. To me, it is about the transmission system and spectrum, about limited bandwidth and limited services that can be offered in that bandwidth and a very outdated analog technology that is occupying that bandwidth.
The entire AM band is only about 1.25 MHz and the entire FM band occupies 20 MHz. To put this into perspective, in NYC, Verizon alone has over 40 MHz of spectrum just for LTE versus 20 MHz for all of the FM stations to share. In NYC, one company (Verizon) controls twice as much spectrum as all of the radio stations in NYC. Verizon also has other spectrum for 3G and other wireless technologies.
Terrestrial radio is limited to only a handful of sound-based services (voice and music). In that sense, radio was the same in 1930 as it is now. We can talk about technical improvements such as FM and solid state transmitters and improved sound and less interference but these are all quite trivial in today’s world. Less interference is even arguable.
I don’t have a specific answer, but it seems to me that radio has the following quite significant technical and physical obstacles to overcome.
1. In today’s world of wireless technologies it is about spectrum and bandwidth within that spectrum and whether your technology is digital or analog. Do you know of any analog wireless technologies today that are wildly successful?
Radio has neither enough spectrum nor enough bandwidth within that
spectrum. Radio is not digital; it is primarily analog with a digital transmission system grafted onto it that is not very robust or helpful because it is limited by bandwidth.
Back in the 1990’s when digital audio broadcasting (DAB) was first introduced, there was a small push in the US to get more spectrum for radio broadcasting that could support true digital transmission. There was an attempt to get L-band spectrum and later S-band spectrum. S-band spectrum is where satellite radio broadcasts today. There were also some that thought about laying claim to TV broadcast spectrum that would be relinquished as the TV broadcasters converted to digital transmission and HDTV. It became pretty clear that the owners of radio broadcast stations and companies in the early 1990’s (when digital was really in its infancy) did not want more spectrum or bandwidth. I’m not totally convinced that these owners even knew what they were fighting against. But, to them, more spectrum meant more competition or better competition. There has always been the argument to fight against AM radio broadcasters having more bandwidth or better sound because that would make AM more equivalent to FM. Radio broadcasters in the 1990’s fought against digital transmission for their own vested interests. As a result, today, both AM and FM are stuck with an old analog system and there certainly will not be any new spectrum for radio broadcasting. Satellite radio got the last bit of spectrum for radio broadcasting.
Several major group broadcasters were heavily engaged in trashing digital transmission because they feared that it would devalue their existing investments in analog stations. Sometimes these group broadcasters would say they did not need digital or that consumers did not want digital, etc. At other times they had real smear campaigns about getting spectrum. One of my favorite mistruths here was that S-band spectrum would not support mobile reception if the vehicle was going 60 MPH or faster. I wonder if the Sirius engineers worry about that today.
Radio broadcasters did eventually adopt a sort-of digital transmission system. The digital signal rides along with the analog and from what I read they do not coexist very well. It has taken years for there to be any receiver penetration and many radio broadcasters do not speak kindly about in-band, on channel digital broadcasting.
In adopting IBOC, the radio broadcasters miss the entire point about digital broadcasting. Digital is not about digital audio (that is expected; necessary but insufficient); digital is about the additional services that can be provided while at the same time providing high quality audio. Again, with enough spectrum and bandwidth, radio broadcasters could be streaming video over their digital channels, just like wireless carriers do today. Wireless carriers can stream video, provide graphics and text and sound and photos, and phone calls and the system can support millions of applications. And the wireless carriers can do these amazing things because they have spectrum, bandwidth and digital transmission. Radio has almost no spectrum (at the very least, limited spectrum), extremely limited bandwidth and a terrible and wildly outdated transmission system. It is no surprise to me that my phone/phablet is more important to me than any radio.
2. Radio signals are sent to dumb devices or receivers (as opposed to intelligent devices). These radio receiving devices have become more intelligent over the years, BUT not to the benefit of radio broadcasters because radio broadcasters could not send any intelligent information (beyond their analog service) to the intelligent device. So, the dumb terminals became more intelligent and added on other digital services, but AM and FM radio are still about the same on these new devices as they were on the devices from the 1960’s. The radio receiver to receive AM/FM is a dumb terminal with extremely limited intelligence.
For example, on Disney’s 20-odd AM stations, what could Disney send on the channel beyond sound, voice, some music, some sound effects? There is nothing else in the channel. There is no easy way to capture (or record or manipulate) what is being broadcast. By contrast, in the digital domain of the web or even of digital satellite, other intelligent information can be placed into the channel along with the primary service.
Radio is a very limited medium in today’s world. It is no surprise to me that my computer, my phone/phablet are way important to me than is my dumb terminal receiver for receiving AM/FM broadcasts.
3. Radio has few technology pushers. The engineers are all gone or at least the ones that think out of the box. A good radio engineer today is one who can keep the station on the air, do some slick audio editing, keep the Internet connection working for the computers in the station and knows how to use an iPhone. No right engineer in their modern mind would think about working on radio with limited services and limited spectrum and limited bandwidth that is received by dumb devices.
4. There is no technical innovation in radio broadcasting. Again, we don’t have to look very far to see dramatic innovation in others using the “radio spectrum.” Let’s compare radio broadcasting to wireless carriers. Analog cell phone service was launched a little over 30 years ago (in about 1982). That is what carriers call the first generation of wireless. In this analog service about the only thing that you could do was to make or receive voice calls and even some of those calls were not very good. It was a major leap, but it was only voice.
Wireless has evolved from the first generation to the fourth generation (and wireless engineers are talking about 5G,or the fifth generation of wireless that will be here about 2020) and today voice is given away by most carriers IF you have a data plan. So, during the time that radio has been struggling, wireless has introduced texting, email, Internet access, streaming video, many, many devices and applications. Several new industries have been established while radio broadcasters contemplated the next PR campaign for radio or sales and marketing campaigns.
Wireless carriers went from an analog service in 1982 and sustained that service and eventually turned that service off and turned on three generations of wireless, created new opportunities for technology companies and engineers and new businesses. Meanwhile radio has been watching on the sideline.
Radio is over-sold and over-marketed by mostly c-level students; there are no engineers in radio thinking about the next generation of radio and if there are any engineers working on the next generation of radio, they are more likely to be thinking about a more useful delivery system such as the Internet.
5. Radio broadcasters think it is about programming and personalities and local, etc. These three things and other radio attributes are not unique to radio and they are not patentable technologies or services. These attributes are easily done by digital services that are much more interesting and diverse than radio broadcasting (analog or HD).
6. A final comment about AM radio. In general, AM radio hurts FM radio but this is largely immaterial in today’s world. AM radio is not likely to be “saved.” The entire bandwidth of the AM service is only about one-tenth of the size of a cellular channel or less (depending upon which cellular service you are talking about). One thing that could perhaps extend AM’s life is to remove about half of the stations from the air, but this won’t happen and there is no real reason to do it since AM radio suffers from extremely limited spectrum and no channel bandwidth that can support interesting services.
I don’t follow the discussions in radio broadcasting much anymore because it is mostly the same that I heard in the 1980’s and 1990’s. So, I could be wrong here, but I just do not see anyone talking about the spectrum/bandwidth issues for radio broadcasting. Why do you think wireless carriers want more spectrum? Are they stupid? More spectrum makes them more money by supporting more subscribers but mostly it is because that new spectrum can support more services and a greater variety of services. It is really, really strange to me that Verizon and AT&T are using advanced LTE (in the broadcast mode) to “broadcast” content on the same spectrum that television broadcasters relinquished. Broadcasters, whether radio or TV, just do not see the benefits of more spectrum and bandwidth, but they complain about other competitors taking their cheese.
Posted by: John Abel | September 04, 2014 at 11:17 AM
Jack Mullaney and the Broadcast Maximization Commitee proposed to open Channels 5 and 6 a few years ago.
He even allocated all AM's to the FM Band.
Read here:
http://www.ccbroadcasters.com/TV%20Channel%205-6%20Radio%20Proposal.pdf
Posted by: Robert Reid | September 02, 2014 at 04:09 PM
I feel the AM Translator WIndow proposed by the FCC will AM's in smaller markets, but not larger ones.
In larger markets, the big corporations are buying or leasing translators and making them Fill-Ins for their Class C stations, and airing their HD Channels on them. It's an ownership cap loophole that should be closed.
In our market Clear Channel has 2 Additional Formats on 2 Translators (Leased), and recently purchased four more translators in the area. The 4 translators they purchased are on adjacent frequencies, so they will most likely shut off 3 of them to create one large Fill-In Translator which will cover a great deal of the market. That would give Clear Channel 7 FM frequencies in the market. Cox is also cashing in on the relaxed translator rules and picked up one of their own as well. Both companies are already at their ownership limits for FM's. They have different formats originating from HD Channels on each Translator.
Then there are the LPFM's from this most recent Filing Window. I am all about localism and support the LPFM movement to create diversity on the FM Dial. However, in larger markets, between translators and LPFM's, just about every available frequency is taken.
Where does that leave an AM that is fighting to survive in Markets 1-50?
There is nothing left for them to apply for in most if not all those markets, especially on the East Coast.
Allowing HD Channels to transmit on Translators is an issue that needs to be addressed before the FCC opens up any AM Translator Window. Otherwise, it's a weak attempt to "Save" AM Radio in areas where small, independent AM operators are struggling to keep their stations on the air, while larger companies gobble up every single channel and format to grab every single advertising dollar.
Posted by: Robert Reid | September 02, 2014 at 03:45 PM
The greatest new equalizer for AM stations in the world of FM station domination is the fill-in FM translators for AM stations, but they are not on a level playing field with those of FM stations. If the FM station owns the translator, the translator must not extend the theoretical 60 dbu countour (local market coverage) of the FM station, typically up to 57 miles from the transmitter for a class C FM station; 17 miles for a class A FM station. If the translator is owned by a separate party, the translator coverage area can extend beyond the station countour without limitation, and can be daisy chained to additional translators extending coverage to additional areas beyond the contour of the station. However, for an AM station, the contour of the translator cannot extend beyond 25 miles of the AM tower(s) regardless of the class of the station, and regardless of the ownership of the translator, and no daisy chaining is permitted for any reason where additional translators can extend the coverage beyond the 25 mile radius of the the tower(s). If these FM translators for AM stations are to equalize the influence of the AM stations, the rules for their translators need to be that same as for those for FM stations. There is no logical non-polical reason why they are not. We need to petition the FCC to amend the rules accordingly as soon as possible if AM stations are to survive.
Posted by: Carl Watkins | August 30, 2014 at 02:15 AM
Eric, such a band exists that you describe - FM quality, all signals are of equal coverage, etc. It's called DAB (or DAB+) and it's on in a good deal of Europe and in key cities in Australia. However, that train left the station in the US and at the time (mid 1990's) we did not have the spectrum since we had to allocate a 2nd TV channel to all the TV stations in preparation for the DTV conversion. As everyone knows, IBOC became the digital standard in the US.
Posted by: Hal Kneller | August 28, 2014 at 06:28 PM
My compliments for an excellent call to action. Here is a suggestion, since we know the current AM situation is unsustainable for all but 50kw clear channel operators, primarily Wall Street funded corporations, the rest of us should pressure the FCC to clean out the NCE end of the band. Its wasted spectrum. The original concept of religious and educational now includes anything but price and item spots. It's no longer non-commercial or educational. It's overcrowded with pirates and stations operating over power. Legitimate operators can easily move to available commercial band channels. Those NCE operators along with broadcast engineers and AM operators can decide who is a legitimate operator. The industry should decide, not the government.
Bob Travis
Posted by: Bob Travis | August 28, 2014 at 06:12 PM
Broadcast radio has been slowly poisoning itself for the past couple of decades. Since the mid-nineties to the present, the industry has morphed from an information and entertainment medium with adaptive local market content to an investment model that insists on a one-size-fits-all plug-n-play formulaic nightmare. Now that a generation has grown up without local radio in any substantive form, the party is over and it is not coming back. No amount of digital gobbledy-gook gimmickry will reverse the trend. It just plainly isn't relevant to younger generations
If the only thing keeping streaming systems from taking over completely is the unfriendlyness of cellular wireless data plans (at the moment), then it is safe to say that the marketplace will sort it all out. But sadly, more focus groups and symposia will not cure what appears to be a suicidal patient.
Posted by: John Higdon | August 28, 2014 at 05:43 PM
I'm with you, Eric. Most of what has been proposed and/or put into place are band-aids. I, too, grew up with AM in the late 50s - early 60s in suburban Detroit. AM was KING! WXYZ, WKNR, CKLW (a bit later), WJR, even little WYXI in Ypsilanti. AM's best days are behind us now, sad to say. It still has some life left, but there are no technical efforts available that will return it to its former glory. Yes, you could make it all digital, but who will buy the radios? You can relocate the AM stations to another band, make it FM/digital, but who will buy the radios? It brings me no comfort to say that AM as we know it will (maybe even should) reach a point where a 'sundown' date should be set and adhered to....and we move on.
Posted by: Bill Harris | August 28, 2014 at 05:20 PM
The logical solution would be to open channel 5 and 6 to FM. The radios are out there--I have several Grundig Traveler portables that get this band (used for FM in Japan, for example.
Unfortunately--will never happen. Commission wants to jam all the TV stations back into VHF so the Congress can sell off UHF to the Cell folks; TV folks will sue & the mess will be tied up in the courts forever.
Posted by: Tom Taggart | August 28, 2014 at 05:17 PM