INSTITUTE OF ELECTRICAL &
SOCIETY OF BROADCAST ENGINEERS
SBE SENIOR MEMBER
BROADCAST TECHNOLOGY SOCIETY
FCC PETITION FOR RULEMAKING
TO AMEND TITLE 47 C.F.R., PART 73 TO AUTHORIZE AM RADIO STATIONS TO INCREASE THEIR
DAYTIME TRANSMITTING POWER TO OFFSET SERVICE LOSSES DUE TO INCREASED INTERFERENCE
April 10, 2010: Petition for Rulemaking (copy below) filed via U.S.P.S. Express Mail with the Secretary of the FCC.
April 13, 2010: Petition received by both the Secretary and Audio Services Division of the FCC.
April - July, 2010: Articles addressing this Petition are released in radio trade magazines and other publications.
May 28, 2010: Letter received from William T. Lake, Chief of the Media Bureau, Federal Communications Commission.
To all interested parties,
Below is an online copy of the Petition for Rulemaking which I prepared, submitted and filed with the
Federal Communications Commission (FCC) on April 13, 2010. Please contact your
consulting radio engineer / broadcast engineering firm or me if you want to discuss this matter.
You can email me at firstname.lastname@example.org with your comments or questions.
Thanks for your interest.
COPY OF PETITION:
Before the Federal Communications Commission (FCC), Washington, DC 20554
In The Matter of
Petition to Amend Title 47 of the
Code of Federal Regulations (C.F.R.), Part 73
to Authorize Daytime Power Increases for AM
Standard Broadcast Stations to Offset Coverage
Losses Due to Increased Interference From BPL,
Digital and Electronic Devices
PETITION FOR RULEMAKING
The purpose of this Petition is to request implementation of a solution that
significantly addresses digital, Broadband over Power Lines (BPL) and other electronic
interference problems to the reception of AM Standard Broadcast Radio, improves
overall AM radio service and secures the future service provided by AM stations.
EXPLANATION and REQUEST
AM Standard Broadcast Radio service has suffered serious degradation of coverage
over recent decades due to increased interference from new technologies. The
development and use Broadband over Power Lines (BPL), computers and other digital
computing devices, the common use of energy efficient fluorescent lighting with
integrated solid state switching circuitry and virtually all other electronic devices have all
increased the sum amount of electromagnetic interference to the reception of AM radio
to the point of near uselessness in many areas were AM stations once provided
adequate service to the general public.
The primary factor limiting reception of AM Standard Broadcast Radio during daytime
hours is no longer interference between stations, but interference from electronic
devices and power lines. Typically, co-channel and adjacent channel interference are
no longer the limiting factors to interference-free reception during daytime hours.
The Commission established service contours and interference protection ratios at an
earlier time when interference from existing electrical equipment was minimal and
interference from digital electronics did not exist. At that time, the protected contours
and the interference ratios made sense. Unfortunately, they were calculated without
available foresight of the future digital technological revolution.
The current protected daytime service areas for AM stations are generally out to the 0.5
mV/m contour for all Classes of AM stations with exception of Domestic Class A
AM stations which are protected to 0.1 mV/m contour. In reality, very few radios are
capable of satisfactory reception at these lower signal levels because of the
overwhelming degree of electronic and digital interference. What we currently have are
AM broadcast stations adequately protecting each other in the AM radio band, but these
same stations are not receiving protection from the intense electromagnetic interference
from unintentional sources making the current protected service contours of AM
broadcast stations of minimal value. Accordingly, defining adequate rural service out to
the 0.5 mV/m protected contour needs to be rethought in light of the fact that the
sources of electromagnetic interference are part of our current lifestyle and will only get
worse. In my evaluation, the only solution to this matter is to permit virtually every AM
station in the United States the option of participating in a substantial across the board
daytime power increase. Increasing power during daytime hours would solidify the
daytime coverage of all participating stations and would NOT change the interference
ratios between these same participating stations. I recommend that a ten-fold (10dB)
transmitter power increase be adopted. If this can not be achieved, alternately, power increases of
four-fold (6dB) could be adopted and still be significant. Ultimately, anything less than a
doubling of power (3db) would be insignificant.
Adoption of a ten-fold transmiter power increase would solidify AM radio, penetrate virtually every
remote area, break through all but the worst interference and fill most AM radio dials
with numerous selections of strong stations instead of limited or no choices lost in static.
A ten-fold power increase would also greatly expand the coverage of all participating
AM stations and solidify coverage of all stations within their current service areas. None
of the participating stations would lose coverage as co-channel and adjacent channel
stations that elect to maximize transmitter power would NOT see any change in their interference
ratios, but all participating stations would dramatically improve overall coverage by
improving their ratios between the desired radio signals and the undesired electronic
interference. I believe that the AM band as a whole would deliver more usable stations
to every AM radio dial across the United States under this proposal.
I request that if the Commission adopts this proposal, that a six month grace period be
established to allow stations that elect to participate in a power increase the time
necessary to install upgrades and that only a written letter be required from participating
stations specifying the degree of power increase (any level up to the maximum adopted
and permitted) along with the actual date of implementation.
All future interference calculations could be made utilizing the previous lower power
levels of all stations, simplifying future allocation issues. I request that a five year
window be granted for all stations to participate in the power upgrade, after which time,
stations will be locked at the actual power level of operation. Certain stations within the
border areas of Canada, Mexico and possibly in just a few other cases, with other
countries where a salt water interference path to foreign stations exists, would have
additional interference concerns to foreign stations, but nonetheless, the grand majority
of listeners to domestic AM broadcast stations will benefit by this request if adopted.
The few stations in the border areas with required daytime protection to foreign stations
could benefit by opting to use of a directional antenna pattern or a change in the
existing daytime antenna pattern, or alternately possibly use a partial power increase.
To simplify matters, I initially request that only daytime power increases be proposed
due to interfering nighttime interference restraints with foreign broadcasters. Nighttime
interference to stations in Canada, Mexico and other foreign nations could be
considered at a later date unless the Commission can resolve these issues in a timely
manner with each of these countries.
AM radio service will further decline without serious intervention to remedy the
interference issue as the ratio of the unintentional interference to AM radio will only
increase further with each new technology.
Higher powered operation will also deliver improved AM radio service to remote areas
that are not adequately served due to variables such as distance or mountainous
terrain. I realize that there are details that will need to be addressed before
implementation, but more importantly, this Petition should open discussion on this
concept. Nonetheless, the time to get the static out of AM radio is past due. We have
watched the AM service degrade due to the increase in interference for too long. We
must return AM radio service to comparable and usable coverage levels of the past.
A statement of my interests in this Petition is required. I, Richard Arsenault am a
former AM Standard Broadcast radio station proprietor, am currently a Broadcast Radio
Consultant and am an avid listener of AM radio. I'm fully aware of the problems with
AM radio and I find it increasingly difficult to enjoy listenable interference free radio in
the home, office or on the road from most AM broadcast radio stations, even within their
protected daytime service areas. I have NO current broadcast ownership interests.
I believe that this Petition serves the public interest in that it further facilitates better
distribution of broadcast service by AM Standard Broadcast radio stations supporting
the Commissions goals of competition, diversity and success of broadcast licensees.
Dated: April 10, 2010
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