Comments to FCC Show Broad Support for Voluntary, Digital AM Transition

Broadcasters and device manufacturers widely support an FCC proposal to allow AM radio stations to voluntarily go all-digital, in comments posted in docket 19-311 by Monday night’s deadline. New rules should involve “a straightforward procedure for stations to notify the Commission of a change to all-digital operations and, likewise, a notification of reversion to analog or hybrid operations,” said Bryan Broadcasting, the originator of the petition that spawned the NPRM. Hubbard and others praised all-digital AM. The company operates such a station under experimental license (see 1911200056).

Most agreed on how rules should be implemented, including on technical standards and notification requirements. NPR worried how all-digital stations might affect existing analog ones. The Society of Broadcast Engineers cautioned that all-digital AM isn’t enough to fix the ambient noise problem afflicting the band. “It is a quite reasonable method of treating the symptoms, but it does not combat the disease, which is worsening,” SBE said. CTA pronounced radio listeners “ready” for the change: “CTA’s internal market research also indicates that HD Radio receives will remain a popular feature of new vehicles.”

Digital in the band will improve audio quality, allow inclusion of supplementary information such as artist identification, and will use spectrum more efficiently, said Xperi. Hubbard found power requirements of operating all-digital AM to be similar to the analog version. “Digital broadcasting is generally less vulnerable to interference and provides improved audio fidelity and a wider audio bandwidth,” NAB said. Since it could help make AM stations more viable, “this proceeding is particularly important to diverse communities and small towns” with such outlets, said the California and Missouri Broadcasters Associations.

The SBE praised the proceeding, saying the FCC also should seek to regulate unlicensed devices to reduce ambient noise. “AM Revitalization, in SBE’s view, is not entirely a deregulatory exercise,” the group said. “Some existing regulations should be better enforced, and some new regulations will be required in order to improve ambient noise conditions in the existing AM band.” The “only source of regulatory reform” that has “a meaningful chance to positively affect the noise floor over time” are rules affecting “manufacturers and importers and dealers,” SBE said.

Make going digital easy, asked most commenters. “The regulatory procedure for transitioning to AM all-digital should be as simple and efficient as the current notification procedure for hybrid AM digital operations,” wrote individual AM licensees. “Any decision by an AM station to operate in an all-digital mode” should be “discretionary and reversible,” they said.

Several addressed questions raised in the proceeding about the cost of converting to all-digital and whether the new tech is viable since it can be received only by HD radios. The transition could cost broadcasters in both the fees for converting and through the loss of listeners without the proper receivers, commenters said.

The FCC “should step in and require radio receiver manufacturers to include HD reception capabilities on every new radio sold in the United States,” said the Puerto Rico Broadcasters Association. “Without such an all-HD receiver rule there may never be sufficient HD radio receivers available to make the broadcasters’ shift to full HD radio transmission worthwhile and cost-effective.”

“Strike the right balance” by allowing the new tech while “protecting against harmful interference to analog AM services,” said NPR. Monitor progress and effects of deployment, periodically disclose the number of stations that have shifted and the interference complaints they generate, and seek comment one or two years down the line on the effects of all-digital deployment.

Hubbard reported that its experimental station received no interference complaints from other stations. It's among several commenters arguing the FCC should allow all-digital stations to broadcast at night. “Current policies and procedures for preventing interference by hybrid signals should equally suffice for all-digital AM operations,” said NAB.

Nearly every commenter said the FCC should adopt the NRSC-5-D technical standard as the official one for all digital stations. It's “a mature standard that already serves as the de facto standard for both hybrid and all-digital transmissions in the United States,” said Xperi. Dolby Labs suggested alternatives such as Digital Radio Mondiale: “Consider whether a truly global and competitive standard such as DRM should instead be adopted.”