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News Archive: April 2010

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4/29/10 - More Miscellaneous News of Note [link to this story]

About a week and a half left until dissertation-research formally concludes. Then a short break after which it's time to organize the ~800 pages of notes collected from FCC dockets, trade publications, and related materials into formal prose. In the meantime:

Pirate Radio: Pally-pal Paul Riismandel wrote two excellent articles this week for Radio Survivor on unlicensed broadcasting. The first looks at a spate of FCC enforcement actions in Massachusetts, and especially around the Boston area.

Paul finds that Caribbean and Hispanic pirates dominate the scene, much like in south Florida and the NYC metro area, and concludes that "While LPFM provided a very needed avenue for many different populations and communities to obtain broadcast licenses, the service is not and will not be enough to make up for the lack of diversity on the majority of the radio dial. While the FCC may have hoped LPFM would hold back the tide of pirate radio, a decade later there’s no evidence that happened."

The Boston field office's work does not appear to reflect a nationwide campaign against unlicensed broadcasting; methinks they just finally proliferated enough in that particular region that the Boston field office had to make some show of "force." (The Enforcement Action Database, by the way, is in stasis momentarily for the above-mentioned reason, but will update again, hopefully by the summer.)

Paul's second story relates news of a pending pirate radio crackdown in Spain, which boasts more than 3,000 unlicensed stations. Reminds one of the scene in the Netherlands 'round the turn of the century. The U.K. scene is still booming, especially in London, as evidenced by a recent mini-documentary (underwritten by a footwear company) which makes the U.S. scene look primitive in comparison.

On more historical notes, I just finished reading The Making of the Atomic Bomb (again) and noted this gem for the first time: "A low-power radio station began broadcasting to [Los Alamos] residents on Christmas Eve, 1943, drawing on several fine collections of classical records, including [Robert] Oppenheimer's; the few New Mexicans beyond the Hill who could receive the station's signals were puzzled that announcers never introduced live performers by their last names. The "Otto" who occasionally played classical piano selections was Otto Frisch."

Meanwhile another friend, Ben Kobb, points to a new documentary on clandestine radio stations; more specifically, on that elusive sub-genre, the numbers station. The trailer looks pretty enticing.

HD Radio: Sometimes it can be fun to play with numbers: a Google Trends chart comparing searches on various forms of digital radio does not portend well for iBiquity. Then again, seeing has how the company is being kept alive primarily by sporadic venture capital infusions - 10 years into its corporate history - does not portend well, either.

Culture Jamming: Introducing TrustoCorp, "dedicated to highlighting the hypocrisy and hilarity of human behavior through sarcasm and satire." The Corp got busy on the droplift-style rebranding front in the NYC area this spring. We need more of this than ever today.

4/21/10 - LPFM: Thanks For The Memories? [link to this story]

Much was made last year of the Local Community Radio Act's passage in the House of Representatives. But since then, no news: what's going on?

As you may have heard, most of the telecom-policy wonk-world is all agog with the FCC's promulgation of a National Broadband Plan. Some have felt, since Chairman Julius Jenachowski took the helm of the agency, that he'd be much more focused on "new" media than "old." This seems to be playing itself out to some degree.

However, to its credit, the FCC's hands are tied until Congress approves the Local Community Radio Act. This may be a bit more challenging than first thought; one report says a provision has been added to the Senate's version of the bill which would repeal (see bill version #2) the "Rosa Parks provision" of current LPFM rules - giving unlicensed broadcasters a shot at legitimacy provided they voluntarily cease their electronic civil disobedience.

The trade publication Radio World cites this as proof "about the level to which some pro-LPFM groups have the ears of lawmakers." One might wish: pro-LPFM groups, because of their reformist goals, must publicly swear off condoning electronic civil disobedience; the fact that the Senate's considering bringing former radio pirates into the fold is more likely due to the FCC's impotence in stopping the promulgation of such stations.

While the Local Community Radio Act is now technically on-deck in the Senate's voting calendar, the disparate (and potentially controversial) language of the two bills may delay rectification in conference committee, which will delay getting the bill to President Obama's desk, which will ultimately delay the FCC's implementation of new statutory authority with regard to LPFM.

Even if all goes "well," I fear this may be a fight won 10 years too late. The primary reason: the promulgation of HD Radio. This technology not only effectively doubles the spectral footprint of every radio station currently on the air, but requires LPFM stations to accept new interference from FM-HD digital sidebands. Most critically, it was legalized at almost exactly the same time as the FCC was wrestling with its LPFM rulemaking.

The most poignant writing on this conundrum comes buried in a memorandum written by J.H. Snider, which was inexplicably filed as an attachment to ex-parte comments tendered in 2006 by the Alliance for Better Campaigns and New America Foundation in the FCC's digital radio rulemaking. Snider provided LPFM allies with incredible fodder to resist HD Radio through its potential destructiveness to LPFM. And he rightfully blames the "public interest" constituency in D.C. for missing this important development in radio spectrum policy:

Central to the political genius of the radio broadcasting lobbyists was their understanding of the limitations of the press and public interest community. They understood that the press and public interest community were both uninterested in technical details and technically illiterate. They were confident that they wouldn’t read the details and, if they did, wouldn’t understand their significance. This allowed broadcasters to provide a cover story (which might be called the “IBOC cover story”) that was a fundamental distortion of reality but would be accepted as reality.

Radio broadcast lobbyists also had a measure of luck, perhaps far more than they could have dreamed when they started lobbying for the digital radio transition in the early 1990s, about the same time that the broadcast digital TV transition got under way. During the period in the late 1990s and early 2000s when the key digital radio decisions were being made, the public interest community, and the press they educated, were focused on the low power FM debate. LPFM only required a tiny fraction of the FM spectrum whereas IBOC used up huge amounts of it. But low power FM was nevertheless a great issue for the grassroots driven public interest community because everyone understood FM, many individuals and organizations throughout America wanted to be their own FM broadcasters, and the time horizon for implementing LPFM suggested the closest thing you can get to immediate gratification in a spectrum policy proceeding. In the end, IBOC would get more than 95% of the white space between the FM channels but virtually no one in the public interest community would link the issues and alert the press.

And that is why I say, "thanks for the memories": by the time LPFM reaches a stage of relative "expansion," incumbent spectrum-occupants will have already sucked up enough space on the dial through digital means so as to make a second-coming of LPFM even less dramatic (and materially meaningful) than its debut. I still support and respect the efforts of LPFM advocates trying to make the Local Community Radio Act law; I just don't see much strategic value in this particular fight anymore.

4/12/10 - Miscellaneous News of Note [link to this story]

I'm deep in the terminal-phase of my dissertation research - writing to begin next month. In lieu of snarky analysis this week, I give you a plethora of updates on stories covered here recently:

ACTA: The full text of the Anti-Counterfeiting Trade Agreement has finally been published publicly. This has pissed off some notable Harvard law professors - not because the document's public, but for the draconian measures it contains to "protect" intellectual property. Said professors are raring to go to court to challenge ACTA, if implemented.

Network Neutrality: Lots could be said about the recent D.C. Circuit Court decision striking down the FCC's authority to regulate how broadband Internet service providers manage their networks. It's caused quite a furor in D.C., but to get the real low-down on what the implications of the court's decision really means, read this analysis from Harold Feld and this mea culpa from Marvin Ammori, one of the attorneys who actually argued against Comcast at the case's primary hearing.

Short version: while this is a setback for the FCC, it doesn't signal the end of regulation against data discrimination; there are other options with which to make the government an actionable regulator on this issue.

HD Radio: I got a nice e-mail recently from a collective of public radio listeners from five cities around the country announcing the creation of a new site, Keeping the Public in Public Radio, that's devoted to covering the machinations of NPR from multiple angles, one of which is the network's infatuation with HD Radio. They posit that many NPR-member stations are undergoing radical reductions in their local on-air staff in order to maintain their investment in this questionable technology.

I can sympathize. Our local public radio stations recently laid off their entire weather staff and have replaced much of the programming on its AM and FM outlets with "canned content" and simulcasting. joins a short list of ad-hoc individuals and groups conducting ongoing critical coverage of HD Radio. Welcome to the fracas, compadres.

4/3/10 - AM-HD Undergoes Radical Redesign [link to this story]

Judging from the demonstrations at the National Association of Broadcaster’s convention, the system seems to deliver as promised and offers enormous potential for FM and AM stations....The systems are just emerging from the R&D stages and still need fine-tuning before real-world implementation is possible....Once a recommendation is made, the Federal Communications Commission then has to decide how to implement technical parameters for a DAB system. So the industry is still a few years away from a wholesale DAB implementation - but not that many.
Radio World Editorial, "A Little DAB'll Do Ya," May 17, 1995, p. 5.)

With little fanfare and less than two weeks before the National Association of Broadcasters' Broadcast Engineering Conference in Las Vegas, iBiquity Digital Corporation (the proprietors of HD Radio) announced a radical redesign of its hybrid analog/digital AM-HD waveform.

To be discussed in detail at the conference itself, which on Sunday, April 11 will spend half its sessions focused on HD Radio implementation more generally, iBiquity's "v4.3 Exciter MPS Framework" makes several notable changes to the AM-HD signal structure.

Most obviously (as seen at right, click for a larger and more detailed image), entire portions of the hybrid analog/digital signal that were sharing bandwidth have been removed. The upper half of the image, which represents iBiquity's current AM-HD hybrid waveform, shows "secondary" and "tertiary" digital data imposed upon the same bandwidth as occupied by the analog AM signal (that you and I can actually hear). In the real world, this "underlying" digital data causes hiss or white-noise artifacts that are noticeable within an analog AM signal.

To compensate for this problem, many AM-HD enabled stations actually decreased the bandwidth allocated to the analog portion of their signal in order to improve the quality and/or robustness of the digital one. This has angered more than a few analog AM radio broadcasters and listeners, who do not like the idea of a preexisting, legacy service being degraded for an unproven technology.

To correct this problem, as illustrated in the lower half of the image, iBiquity has simply removed the secondary and tertiary digital data signals from the AM-HD waveform. Under the old regime, a hybrid analog/digital AM-HD radio signal could transmit as much as 48 kilobits per second of digital data; it's not clear just how much that paltry capacity has been cut by this move.

iBiquity itself seems to be touting cross-purposes of this "improvement." On the one hand, it claims one of the major goals of this revision was to increase the fidelity of existing analog AM signals. This would suggest that it's not just listener, but intra-industry pushback from the effects of AM-HD on analog AM radio that have caused iBiquity to sacrifice digital capacity, fidelity, and/or robustness to restore the analog listening experience. On the other hand, iBiquity claims that this new configuration will add new choices on how to tweak the digital audio quality specific to a station's format, and adds "AM HD Radio data support," whose details are unknown. It is difficult to see how these particular "advancements" work with what is now essentially one-third of the useable bandwidth reserved for a station's analog signal.

Ultimately, the most fundamental change is the one not there - an overall net reduction in the spectral footprint of AM-HD radio signals. This makes it clear that iBiquity and its proponents remain unconcerned about the destructive nature of AM-HD signals at night, when skywave interference becomes a real problem. This redesign is about improving the listener experience within the daytime, or groundwave, listening area of AM radio stations.

It, in effect, signals iBiquity and its proponents' firm intention to gradually phase out the notion of long-range listening on the AM band as we've known it, and "localize" the coverage area of all AM radio stations. Apologies to those of you who live in rural areas with no stations of your own, who rely on "distant" stations as a primary means of radio listenership: you're out of luck. This is no conspiracy - you simply don't exist anymore:

[T]he fact is that wide-area nighttime skywave service, while a fascinating propagation phenomena and very much a part of radio's historic past, is largely irrelevant in today's world. The number of persons deriving radio service via skywave propagation is tiny. Most persons under the age of 40 do not even know that this propagation mode exists, let alone listen to it. The need for a medium wave wide area skywave service in the U.S. has largely passed....Skywave signals will suffer somewhat greater interference then currently is the case and will have their availability decreased as noted in the iBiquity submissions. This is, by far, the most significant compromise attendant to 24-hour AM digital operation. However, the upside of high fidelity -- robust digital service in the stations' groundwave service area -- is worth the attendant deterioration of the skywave service component inasmuch as the vast majority of these stations' listeners and advertisers are within the groundwave service areas. For AM to have a future, it must transition to digital. To transition fully to digital will require this necessary compromise.
(Reply Comments of iBiquity investor Greater Media, Inc., MM 99-325, July 30, 2004, p. 4-5.)