Preliminary AM Revitalization Comments Roundup

With the first round of public comment on the FCC’s AM revitalization initiative due next week, it’s not a bad time to sample the feedback that’s come in so far: just about 65 comments in total.
There are some general points of consensus across most commenters. The strongest involves the increase of interference across the entire AM dial. Much of this comes from improperly-shielded consumer electronics, lighting fixtures, and power lines, which can wreak absolute havoc on AM reception in localized areas. The FCC has the authority to require that all such devices meet standards to reduce harmful emissions—but the huge influx of cheap sh*t from overseas is far, far more than the FCC can handle without a substantial increase in enforcement resources.
Another point of consensus is that the FCC should require AM radio receivers to work at a certain level of quality. Another side-effect of the influx of cheap electronic componentry means that the sensitivity and fidelity of modern AM receivers (especially in automobiles) is actually worse than they were, say, two decades ago. There is regulatory precedent for the FCC to consider and adopt minimum AM receiver-standards, but the power of the consumer electronics industry in D.C. will strongly resist any such notion.
Unsurprisingly, there is also strong support for the FCC to open a special filing window for AM broadcasters to acquire "supplemental" FM translators: groups ranging from the National Religious Broadcasters to the Prometheus Radio Project support the concept. But how many FM translators might be made available, and who should be first in line to apply? These questions will most likely constitute the majority of the dialogue as the proceeding continues.
However, not all broadcasters feel that giving FM translators to AM stations is a panacea. Curtis W. Flick thinks further abuse of the translator rules is likely; there is already "a track record of certain licensees neglecting their AM facility maintenance in favor of their FM outlet. Some AM stations have been off the air for extended periods…while blissfully providing FM programming to their translator in blatant defiance of FCC rules….Whether these translators are permanently locked to an AM license is irrelevant. There is no good way to do a bad thing."
Several commenters have suggested that the FCC expand the FM dial down to 76 MHz and use that spectrum to site any new FM translators for AM stations. Mark Heller thinks the AM dial should be expanded, too—from 1700 to 1790 KHz—to encourage investment in new AM stations.
Sentiments run strong against the adoption of the all-digital AM-HD mode. Commenters note HD Radio’s penchant for causing interference to existing stations, its floundering in the receiver marketplace, and the "undue financial burden" that HD adoption would put on small AM broadcasters; Brian J. Henry notes that the cost of digital adoption "can in certain cases exceed the current market value of smaller market AM broadcast stations."
Although the Broadcast Warning Working Group suggests it is "time for an honest and rigorous revisiting of [HD] for AM," they are one of only a handful of commenters who advocate for the technology’s abandonment. Brian and Karla Winnekins, the owners of WRDN-AM in Durand, Wisconsin, think the time is ripe to experiment with other digital broadcast technologies, such as Digital Radio Mondiale. Meanwhile, Frederick R. Vobbe thinks putting HD-AM and -FM on spectrum adjacent to the current FM dial may be the most expedient way to inject life into radio’s digital malaise.
Out of all of the comments tendered so far, though, Nickolaus Leggett’s initial filing is my favorite: ambitious and pragmatic rolled into one. On the one hand, Leggett—one of the founding petitioners of the LPFM service—would like to see the FCC look into establishing an LPAM station-class, and is preparing to petition the FCC to consider a local shortwave broadcast service. On the other hand, he would also like the FCC to grant existing AM stations greater regulatory flexibility to customize their transmission and antenna infrastructures, and suggests that the federal government might subsidize AM stations as communicators of last-resort by hardening them against natural and man-made disasters.
It is customary for the big dogs in these proceedings (the NAB, NPR, and a variety of broadcast conglomerates and trade associations) to file on the last day of a comment-window, and these are the comments that the FCC will weigh most favorably as it sets the agenda for any concrete AM revitalization projects. Those filings will also mark the start of what is hopefully a more feisty reply-comment period, which closes on February 18.