REC to FCC: All Digital-AM must take listeners and EAS into consideration

Calling the technology "new and geeky", REC Networks questioned the practicality of all-digital (MA3) HD Radio for AM strations.  In Comments, REC expressed general concerns regarding all of the "band-aid" concepts that have come since then Commissioner Ajit Pai started his campaign to revitalize the AM broadcast band including the reconcentration of cross-service AM translators, which are causing substantial interference to LPFM stations and providing no method of relief due to the disparity between the LPFM and FM translator service rules, despite being "equal in status" in accordance with the Local Community Radio Act.

REC made the following points:

  • AM radio has fallen victim to emerging and evolving technologies which have resulted in increased noise floors in the medium frequency spectrum where AM broadacst resides suggesting that the only stations that could cut through most of the noise are the 50 kW Class A and B AM stations.
  • Analog AM radios are in emergency kits and in many cases, people may not listen to AM radio except during an emergency, especially in light of some areas that have lackluster coverage from local FM stations, especially in the wake of the elimination of the main studio rule.
  • AM broadcast stations that play a role in a state Emergency Alert System (EAS) plan from a local primary (LP1/LP2) up to a primary entry point (PEP) could cause a serious downstream effect on the EAS, especially if the AM station is the LP1/LP2.  AM LP1/LP2 stations switching to all digital will result in LPFM stations, small mom and pop commercial broadcasters, small NCE stations and low power TV (LPTV) stations to have to purchase new HD capable AM receiving equipment, thus another expense on these stations, especially after many had to pay Sage and other EAS manufacturers for firmware updates.
  • Unlike "hybrid" AM and FM digital, the conversion to MA3 all-digital is a "flash cut" and once cut over, a legacy AM receiver will no longer be able to hear the station. 
  • As broadcast licensees are public trustees, they have to be accountable to the public.  REC opposes the ability for AM stations to convert to digital without prior FCC authority and then just file a digital notification.  Instead, REC supports the filing of a Form 301 or other form to request a construction permit to convert to all-digital operation.  Such an application must be put on public notice and over the air public announcements need to be made.  Members of the community should be allowed to file a pleading in respect to an application to flash-cut an AM station to digital.  
  • The highest-powered AM stations (such as 50 kW Class A and B stations) are a part of our national infrastructure and are vital to regional emergency information and national security.  These stations should not be permitted to convert to MA3 all-digital at this time.

REC Networks continues to support the migration of most AM stations to an extended FM broadcast band which either replaces all channel 5 and 6 TV stations or an alternate plan that allows full-service TV stations on channel 5 and 6 to continue operating but permit new 6 and 25 kW FM primary facilities everywhere else in the country.  Currently in the USA, there are 10 TV stations on channel 6 and 20 on channel 5.  LPTV stations are secondary in nature and would be displaced by primary services.   Radios that receive the 76~108 MHz spectrum are currently being widely manufactured for the Japanese market and can be easily adapted for American use.

REC ran an allocation simulation and was able to place over 3,000 AM stations on FM channels with channel 5/6 protections and over 3,500 without any TV protections.

 Reply Comments in MB Docket 19-311 are due on Monday, April 6, 2020.