Commentary: LPAM, TIS, Part 15 AM & 02-380
With Calvary and MX LPFMs... we have bigger fish than LPAM right now.
There has been some discussion around the radio activist community on various subjects that impact the AM broadcast band. These include a Low Power AM (LPAM) service, extending the Travelers Information Service to organizations and asking for power increases for Part 15 AM stations during the current 02-380 Notice of Inquiry.
First let's discuss Travelers Information Service stations. TIS stations are currently available to Part 90 licensees that qualify as a 'local government' or a Park District. TIS stations operate either with antennas or on leaky coax systems. TIS licensees are currently prohibited from broadcasting the specific names of establishments such as hotels and restaurants. The only exception is that at transportation terminals such as airports, they can state the carrier name ("United is at Terminal 2"). Back in 1975, broadcasters opposed the original concepts of TIS because they were afraid of lost revenues because travel related establishments will just depend on TIS for publicity. This is what generated these rules about establishment names. Some were even concerned that TIS stations could be abused by politicians.
A concept similar to what some organizations are proposing for TIS was already tried back in 1975. RM-2704 would have called for use of TIS facilties by "Community Access Non-commercial stations for locally produced public affairs, musical, dramatic and cultural programming". This concept was flatly denied by the FCC. However to be fair, there were only 2 frequencies (530 and 1610) assigned to the service.
REC feels that expanding existing TIS rules is the wrong approach to achieving a Low Power AM service.
For more information on what was going through the minds of the FCC back in 1977 when TIS was created see this URL: http://www.fcc.gov/fcc-bin/assemble?docno=770620.
Could LPAM Be A Reality?
We think it could be. During 99-25, we had proposed that LPAM be used as an overflow spectrum for areas where FM stations were not available. However in order to have any chance to see a LPAM service, we first have to eliminate In-Band On Channel (IBOC) on AM. The AM band is already pretty crowded however we can squeeze AM stations in some areas.
What about Part 15?
REC is concerned about power increases for Part 15 stations in the AM broadcast band. We also remind those who are considering increasing power on Part 15 AM that once you increase a service that is authorized by rule and not license, you also open the door for all of the entrepeneurs who will start selling Part 15 devices to different commercial enterprises. With the higher powers, Part 15 devices such as radio billboards will be more prominent and therefore defeat the purpose of using Part 15 for community broadcasting. Some have also discussed commenting to allow expanded powers for Part 15 in the AM and FM bands during the 02-380 NOI. REC can not support this. Any changes to radio broadcast spectrum is outside the scope of this NOI and will be denied.
What else can be done?
REC is looking at several options. We are supportive of using Longwave for short range broadcasting. The radios are redily available from Europe. We are asking in the 02-380 NOI to expand existing Part 15 FM rules to also include 76-88 MHz (Ch. 5 & 6). First this will finally allow Part 15 FM operations on 87.9, a channel that is currently restricted by the "TV Part 15 rules". The rest of the 76-88 band is available on Japanese FM receivers that can be easily imported here. This will lead to an eventual expansion of the licensed FM and LPFM broadcast services into Channel 6 spectrum.
REC is also supporting efforts looking at a National Community Speech Radio Service (NCSRS) using underutilized Broadcast Auxilliary channels in the 26 MHz band.
We currently have bigger fish to fry right now. We have DAB ruining the rural AM broadcast service, we have translator owners trying to get into metro areas on non-reserved band channels under the guise of "underservice". We have the FCC jumping the gun on allowing Wi-Fi devices on TV spectrum while we are in the middle of the DTV transition.
For now, we need to wait for the results on the LPFM third adjacent channel testing and then we need the FCC to finally declare the MX groups on LPFM. Let's get these issues straightened before we tackle LPAM.