REC Networks has filed comments in the Further Notice of Proposed Rulemaking in MB Docket 13-249, the AM Revitalization docket.
In our comments, we stated our objections to the Commission's proposal to eliminate nighttime "sky wave" protections for clear-channel Class A AM stations stating that the nighttime service is a national resource but at the same time, called on Class A station owners to better program their stations to attract a nighttime audience. Despite the many options for listeners, nighttime AM radio remains the only service available free of charge that does not require constant re-tuning and can reach into areas where there is insufficent AM and FM services.
REC supports the ability for AM stations, especially Class C and D stations to be permitted to place translator protected contours outside the 2 mV/m contour of their AM stations but in no case more than 25 miles. We are opposing any attempt to place a service contour more than 25 miles from the AM station except in the cases of the AM city of license actually being more than 25 miles away, the translator is to serve an inhabited island with no commercial FM services or if the AM station is in the state of Alaska. In those rare cases, we consider translator placement anywhere within the 2 mV/m contour as being in the public interest.
REC feels that the 25 AM stations that have kept both their standard band (540-1600) and their expanded band (1610-1700) licenses despite the past calls to surrender one or the other should be required to surrender their expanded band license. Under our reasoning, we feel that due to changes in AM band due to other stations going off the air, changing nighttime facilities and the reduction of Cuban interference over the years, the standard band stations are not experiencing the same interference issues they did in the 1990s. REC does feel that the recovered spectrum be made available to existing licensees for migration with no more than a 30 day overlap of old and new facilities. Frequencies should be made available through three auctions. Auction 1 for 1620, 1650 and 1680; Auction 2 for 1630, 1660 and 1690; and Auction 3 for 1640, 1670 and 1700. Also as a part of the revitalization of the Expanded AM band, REC has called for the establishment of a 30 and 100 watt Low Power AM service and a slight power increase for intentional radiators under Part 15 of the rules in the spectrum 1605-1715 kHz. REC opposes any form of digital radio (including DRM) inside the 525-1705 kHz spectrum.
REC does support both the expansion of the FM broadcast band to include 76-88 MHz (TV channels 5 and 6) and the migration of Class C and D AM stations into this spectrum. REC also supports consideration of creating a new domestic broadcasting band at 11 meters (25.600~26.480 MHz) using Digitial Radio Mondiale. DRM in this spectrum is already being trialed in Europe.
Comments are due by close of business today, March 21, 2016.