NERW Extra: Our AM Improvement Filing

Every couple of decades, the FCC decides it’s time to do something about the state of AM radio. This is one of those times, and today’s the deadline for comments in the Commission’s Proceeding #13-249, the Notice of Proposed Rulemaking on AM Improvement.

If you have strong opinions about the state of AM radio – and we do! – you can’t complain if you don’t speak out when the opportunity presents itself. NERW editor Scott Fybush’s comments are presented below (they’re purely my own). Agree? Disagree? Comment below, come talk about it on the RadioInsight Community. and let the FCC know, too! Here’s an express link to file comments on 13-249, and because of the storm that’s shut down the FCC today, it’s a pretty good bet comments will end up being accepted through the end of the day on Wednesday.

AM improvement comments by fybush

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Comments

  1. aaronread says

    Why not take it a step further with FM translators? With Class C AM’s, everyone is listening to the FM translator within a year anyways. Let the operator shut down the AM and run FM-only. Let’s clean up the band a little and reduce the noise floor at night, shall we?

    Call it a permanent STA to remain silent. Keep the license on the books so nobody else can try and horn a new station on that spot. Also so you don’t have to create a new Class for FM translators that don’t have a primary to translate. Mark the license with an “S” before the call letters, much like how they mark deleted licenses with a “D” (as in “DWXYZ”). Also prevents anyone else from “stealing” the call letters for the station, since the translators still have the W212AA nomenclature.

    • aaronread says

      Oh duh. I should’ve read the ENTIRE document you posted before commenting, shouldn’t I? :)

  2. aaronread says

    FWIW, I wonder if it makes more sense to allow AM applicants to file a maximum of five (maybe three?) applications per AM facility for new “linked” FM Translators, but with the requirement that the applicant pick only ONE and withdraw the rest. Withdrawal must be done within 30 calendar days of the entirely of the window’s applications being posted to the CDBS; failure to do so results in ALL applications for that facility being immediately dismissed.

    This gives applicants some flexibility in “trying for” at least a few of their “best shots” and will make the post-window MX resolution process a little easier, too. I know a few LPFM applicants in 2013′s window that realistically could have applied for multiple frequencies in and around Providence, but all of them felt compelled to all file for the same frequency and thus created one giant MX group. If they’d been able to apply for a couple different locations/frequencies, they could’ve more quickly become singletons.

  3. says

    Scott,
    I read your comments to the FCC. Very concise. I can’t add anything to it as you really nailed all of the particulars. A very nice job.

    Gary Walters

  4. saul nowitz says

    AS I LOOK AT IT/ AM AND FM BANDS ARE GOING DOWN THE CRAPPER. ON AM YOU HAVE A TOWER OF BABLE. NO LOCAL PROGRAMING. THE RADIO STATIONS CHUCKED THERE MUSIC LIBRARYS. LIKE A BOOK BURNING. YOU HAVE A CENTRAL BROADCASTER WITH NO CONCEPT OF THE LOCAL AREA. OLD IN FCC HISTORY IT WAS ONE STATION TO THE MARKET. NOW IT IS THE WHOLE MARKET. THE GREED FACTOR. US RADIO WAS NOT SESIGNED FOR THIS. IN A AM MARKET YOU HAVE SEVERAL NEWS, SPORTS STATIONS. PLUS OTHER OTHER STUFF. I REMEMBER 40 YEARS AGO, YOU HAD STATIONS BROADCASTING SEVERAL FORMATS. NOW YOU STATIONS ALL UNDER ONE ROOF. THE FAULT IS WITH THE DE-REGULATION THAT STARTED SOME YEARS BACK. NOW WITH ALL THAT YOU HAVE BORDOM. ALL THE LOCAL OUTLETS ARE OWNED BY ONE PERSON. I THINK SOME SHOULD TRY TO DO SOMETHING LIKE WHEN FM WAS BACK IN THE 60,S IT WAS CALLED THE FREEDON BAND. NOW MAYBE THE AM BAND SHOULD BE THE SAME AND SOME UP WITH NEW IDEAS. IF YOU KICK ASS WITH NEW CONCEPTS THE AM BAND WILL SAVE IT,S SELF. THE COMPUTERS HAVE TAKEN OVER WITH SOULESS PROGRAMING. HISTORY HAS TO REPEAT IT,S SELF.

  5. says

    Scott your article is very well articulated. My concern is the FM translators which are being approved and causing interference and loss of coverage areas with established non-profit LPFM stations. This is resulting in loss of listenership, local content, and donations which are all components with maintaining an LPFM.

  6. Dominick Camisa says

    Very well written . Though I have never worked in radio,(43 years in the TV industry ) I know what happens to local small am stations around my area .
    It’s about time the FCC ( yes I do hold a FIRST CLASS TICKET) gets with the program.
    Scott, keep up the great work.

  7. says

    Scott,
    Very well written and thought out. However, if you look at the evidence you provide here -you’ll realize that there is every reason in the world to ditch AM broadcasting totally and migrate ALL AM stations to FM -thereby making the playing field much more level. TV did it years ago with “all band” receivers- and now with cable you there’s no reason to even think of transmitter height/power/pattern. Like you I started in AM radio. What used to be a regional service is now worldwide thanks to the internet, so the concern would be for local broadcasting. FM has always been a local service. In most markets there are at most FIVE usable AM stations to cover the market vs.3-5 times as many FM signals. Computer logic these days should be able to find usable frequencies in most every market and allow AM stations to go “FM” with competitive signals, vs. the spotty coverage provided by “translators”. AM technology has been trashed beyond repair and aside from “HD” FM, the band is still very viable. TV was able to migrate to digital technology thanks to it’s advancements. Radio, the audio medium, has little more to offer. AM is noisy, expensive, requires a large footprint (real estate) and has outlived its usefulness. If AM stations wish to remain competitive, they must be allowed to compete with “Radio”, not AM vs. FM. That means one band, with all stations. Many of us used to listen to WLS, WABC, WNBC, KMOX and others while sitting in our homes in Rochester. Now you can get ‘em on your cell phone, computer or other online app. There’s no need for a 50KW AM station anymore. On FM, they can be required to cover the market or relinquish their license. The attrition of these stations can only help a business facing more competition than ever. I had a manager tell me in 1980 how crazy it was to play music on AM. I stayed with music stations for five more years with great success. Now, nearly 30 years later, and much discussion on “saving” AM radio the issue is more of saving broadcasters. What are we waiting for?