RM-11836: All-digital AM should be the "final solution"
REC has filed comments in response to Bryan Broadcasting Corporation's Petition for Rulemaking to allow AM broadcast stations to voluntarily discontinue all AM analog broadcasting and convert to the HD Radio MA3 mode. MA3 is an all-digital operation. Two variants of MA3 will allow AM stations to operate in a 20 kHz wide channel where secondary and teritary sidebands more than 5 kHz from the center frequency are either reduced by 15 kHz or they are completely suppressed. The MA3 mode is a far departure from the "hybrid" MA1 mode which involves the use of a 30 kHz wide channel. In the past, the MA1 hybrid digital mode on AM, especially at night, has resulted in substantial first and second adjacent interference to analog AM stations forcing many stations to turn off the digital mode and leaving a bad taste in the mouths of AM listeners and radio enthusiasts across the nation. MA3 mode uses a narrower channel and therefore reduces the chances of digital to analog interference.
Currently, WWFD(AM) in Frederick, MD is operating in MA3 mode under special temporary authority.
In comments, REC supports the basic concept of operation in MA3 mode recognizing the growing market penetration of HD radios, especially in the competitive mobile environment. MA3 digital operation holds substantial promise to combat issues related to noise and interference from unintentional radiators such as flat screen TVs, computer switching power supplies and CFL light bulbs. REC considers MA3 as the true AM "revitalization".
With that, REC sees MA3 as a "final solution" for AM stations in the revitalization effort. Over the past decade, AM stations have been permitted to operate FM translators in order to provide a "crutch" to deal with the new noise that has been generated in the band by evolving technology. As MA3 seeks to defeat the noise issue, it holds a promise to provide AM stations with a quality and facility that is superior to their secondary FM translator operation. Therefore, in comments, REC calls for an eventual sunset in FM translator operations by AM stations choosing to adopt MA3. While this conversion is risky to broadcasters as the penetration of HD AM receivers on the market and on the dashboard does not represent a majority of radio listeners nationwide, it will be up to the broadcaster to determine if their market is ready for HD. This move may prompt more consumer electronics manufacturers to increase choices for HD Radio receivers.
In comments, consistent with REC's position that MA3 is a "final solution" for AM broadcast stations. We are calling for a requirement that once an AM station converts to MA3, that there is a period of time (our current position is 5 years) in which AM stations may continue to operate simultaneously with their FM translator and after such time, the FM translator may no longer be permitted to carry the AM station. REC proposes for AM stations that obtained FM translators in Auctions 99 (2017) and 100 (2018) that those FM translator licenses be converted to 5-year non-renewable licenses and that after 5 years, those FM translator licenses are cancelled and spectrum is returned for potential use by local community-based LPFM stations.
Also in comments, REC raises concerns that stations converting prematurely to MA3 may cause serious public interest and community coverage issues in areas where the station represents the only full-service radio broadcast station for a particular community of license or the only AM broadcast station for a particular county. Not only does this deny the public radio service in some "white" and "grey" areas of our nation but it also impedes the local delivery of Emergency Alert System information, especially to those who may have an AM-only radio in an emergency kit.
"Overall, our nation is not ready for an all-digital adoption and stations need to really consider the risks of switching early to MA3. Their listener demographic must be ready and most importantly, the general public must be ready." says Michelle Bradley, founder of REC Networks.
Comments can be filed up to May 13, 2019 in the Commission's Electronic Comment Filing System under proceeding RM-11836.
Also check out Scott Fybush's Top of the Tower Podcast #35 with updates from the experimental MA3 operation at WWFD.