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I hope this helps…this is from RADIO WORLD..
Could Low-Power Morph to AM?
by Naina Narayana Chernoff
WASHINGTON Low-power advocates are now eyeing the AM band.
The concept of putting low-power stations on AM was proposed earlier to the FCC in the late 1990s. Now, low-power advocates are again calling on the commission to establish a new commercial service in the expanded portion of the AM band.
FCC staff declined to address the petition’s specifics. They are reviewing a petition for rulemaking for a proposed LPAM service submitted by engineer Fred Baumgartner.
Baumgartner is a former broadcast engineer who serves as director of engineering at the Comcast Media Center in Littleton, Colo. He filed his petition privately – not on behalf of Comcast – for a commercial low-power AM service in a docket created to solicit comments for the FCC’s Localism Task Force.
The proposed service, he said, could offer an option for increasing local broadcasting outlets and another way for communities to get on the air without huge expense.
Prospective broadcasters, he feels, would not have to undergo an involved technical application process or pay for the studies of consulting engineers, because protections against full-power broadcasters would already be instituted.
His proposal calls for a specified maximum antenna system size and type-accepted transmitters with integral limits on out-of-band emissions, frequency and power-level.
“For LPFM, the biggest limitation for the community is paying for the engineering work up front.” LPAM, he said, “wouldn’t require a study by applicants and it would be simple and straightforward.”
NAB, which had protested the creation of the LPFM service because of projected interference, said it is reviewing the petition for LPAM. A spokesman said the organization would monitor the FCC’s Localism Task Force actions on the petition.
Nicholas Leggett, who filed a petition advocating a low-power AM service in the late 1990s following the earliest LPAM petition by attorney Christopher DiPaola, said the current political environment seems more open to a petition such as Baumgartner’s.
“Because of the furor over the ownership issues, LPFM got a kick in the pants. It became a counterweight,” Leggett said. “That furor is a real motivator to look at low-power, localized broadcast systems.” But consulting engineer Ron Rackley said adding new stations on the AM band would not help alleviate the problem of shrinking local broadcast outlets. “Creating a service where interference could be caused hundreds of miles away…that’s not localism,” said Rackley, a consulting engineer at DuTreil, Lundin and Rackley, Inc. “There’s a degradation of the signal in the AM band already. Creating a service like this would move the expanded band that way.”
The petition represents a compromise by several unnamed interest groups, engineers and individuals who offered input on the proposal, according to Baumgartner.
He is proposing a service in the AM band between 1610 and 1700 kHz, an area he and his fellow contributors believe would support a secondary service with a minimum of interference to existing and proposed full-power stations. The petition suggests that the FCC sets power levels at 30 and 100 watts, with a maximum tower height of 40 feet for both.
Baumgartner’s petition also suggests that proposed LPAM licensees be allowed on the air between eight hours minimum and up to 85 hours a week maximum, a proposal aimed at encouraging time-sharing by community groups. To further encourage local broadcasting, LPAM stations would be required to be staffed live by an operator 60 percent of the time, similar to a requirement for LPFM licensees.
But unlike LPFM, the plan for LPAM would allow for such broadcasters to support their operations by selling airtime and permitting underwriting.
“Small communities have no financially reasonable way to do this otherwise,” Baumgartner said. “It’s not something that they’ll get rich doing.”
Some community broadcast activists, including William Walker, proprietor of WILW(AM) Radio in WaKeeney, Kan., support the commercial aspect of the petition. He believes some supporters will balk at the suggestion because of the non-profit nature of community radio.
“What they fail to realize is that if we put up stations that reach small areas with mom-and-pop businesses that can’t afford to advertise on full-power stations, they might be able to afford it,” he said. “The more you favor non-commercial, the more you’re supporting the Wal-Marts of the world.”
Walker encouraged others to submit comments supporting Baumgartner’s proposal.
Many have responded, including some members of the Amherst Alliance, an advocacy group for media reform and low-power radio. In December, an affiliate group made up of some alliance members and community radio supporters that calls itself the LPAM Team filed comments with the FCC supporting the Baumgartner petition. The filing also offered suggestions to improve the proposed service.
Don Schellhardt said the affiliate group’s comments aim to enhance the service, not to negate the work of those who worked on the Baumgartner petition.
“It was understood from the beginning that not everyone agreed on all the parts,” he said. “We’d be willing to take it as it is, but we’d like to make some improvements.”
The LPAM Team would like to change two major parts of the petition: the limited airtime restrictions and the minimum percentage of manned airtime.
The group wants to remove the proposed 85-hour limit, Schellhardt said, to give licensees as much air time as possible to develop a financial base in which they can sell ad time. Time-sharing, he said, should only be used in situations where there are two applicants competing for the same frequency, similar to the LPFM application process.
The 60 percent ceiling on manned airtime, according to the affiliate group’s filing, should be eliminated as well because it would be onerous on station volunteers. If necessary, the group said, restrictions similar to the LPFM service could be instituted. The FCC requires LPFM broadcasters to produce at least eight hours per day of local programming.
The affiliate group also recommended to change LPAM from a secondary to a primary service to avoid displacement by full-power AM stations attempting to change frequencies and future long-distance AM translators. Schellhardt believes the rule is needed particularly in crowded urban markets such as Detroit and Boston, where few frequencies might be available.
“The idea of having two or three guaranteed spots in major urban areas is reasonable,” he said. “Otherwise, the chances of keeping a low-power frequency if a full-power station wants to move is low.”
Microradio advocates made a similar suggestion during the LPFM proceedings but were denied.
The LPAM Team also proposed that the FCC consider allowing higher power levels – up to 200 watts – for stations in rural areas and larger mileage separations for areas of lower ground conductivity, which is used predict the propagation of AM signals.
The Baumgartner petition suggests that 100-watt licenses be assigned only in areas where 20,000 or fewer people live within a five-mile radius of the transmitter. Schellhardt’s group said its analysis indicates that there are enough open frequencies to double the number without creating additional interference.
The mileage separation of 225 miles for 100-watt stations could be reduced by reevaluating the average ground conductivity in the continental United States, the team stated. The Baumgartner petition assumes a ground conductivity reading of 30, which is found in large areas of Kansas, Oklahoma, North Dakota and Texas and small isolated pockets of South Dakota, Nebraska, Utah, Minnesota, Missouri, Iowa, Louisiana and California. The national average level falls between 4 to 8.
Among the other recommendations by the team is for LPAM to be formally declared as a service that broadcasts at 5 watts or more to avoid the inadvertent creation of a licensing requirement for Part 15 systems. The team also unanimously requests that the FCC create a formal agency framework for resolving any LPAM-to-LPAM interference disputes.
I GOT THIS FROM THE LPAM SITE..