 Unspinning
the LPFM Threat
By Guy Wire
Everyone saw this coming. The NAB, aka the National Association
of Existing Broadcasters, came out with guns blazing against LPFM
upon the first inkling that thousands of new FM stations could be
shoehorned into the existing FM band. Many more stations could have
been part of the LPFM rollout, especially in the coveted large population
centers if relaxing third-adjacent-channel spacing restrictions
had been adopted.
After strong-arming congress and the FCC with its own studies showing
potential widespread interference from third adjacents, the NAB
succeeded in curtailing the potential for the new LPFM service when
it was finally launched in 2000. Would you expect anything less
from one of the country's most powerful trade associations, protecting
the interests of the status quo?
About 300 new LPFM stations are now on the air, with another 700
CPs granted. LPFMs have made little impact on the industry so far.
Practically all of them are licensed by local government, educational,
religious and other community groups with narrowcast programming
appealing to tiny audiences. But the ongoing efforts to expand LPFM
opportunities by lobby groups like the Media Access Project may
finally be paying off.
FLAWED BUT REASONABLE
Enter "the Mitre Report," an FCC-commissioned study to
decide whether LPFM stations on third adjacents serving the same
area would actually cause real or significant interference. While
the methodology contained flaws and offered only limited field measurements
and/or evaluation of real world scenarios, the conclusions were
predictable and reasonable.
The commission agrees and has now reversed itself in proposing
to drop the third-adjacent restriction for LPFM. Look for legislation
to be introduced in the coming weeks and eventually adopted to enable
more LPFM assignments in the future.
I originally defended the NAB position in a column back in 2000
about LPFM.
Almost nobody opposed the original LPFM concept that envisioned
a valuable new broadcasting service for small, underserved communities
that would enable a local community group to build an affordable
FM station that served their public interests and welfare. But,
I argued, with an already congested FM band in most population centers,
plus the apparent need to protect the FM guard-band allocation scheme
for HD, why make the congestion and interference potential even
worse for both existing broadcasters and the audiences they are
trying hard to serve? Especially when the most vocal LPFM advocates
wanting these stations seemed to be commercial radio misanthropes,
pirates, ex-pirates and radio owner wannabees, mostly with eclectic,
radical and self-serving agendas. LPFM ownership rules thankfully
locked out that crowd.
As things have turned out, the LPFM CPs granted so far have gone
to small governmental or educational community-based groups, who
want very much to provide a public service on the radio in their
local areas.
PROCEEDING CAREFULLY
I'm beginning to think this service deserves a real chance to succeed.
After all, providing an opportunity for responsible voices to be
heard that represent diverse and underserved interests in our society
is still an embedded principle of American democracy. But the commission
will have to continue doing a careful job qualifying and granting
CPs to legitimate and local applicants.
My biggest lingering fear about LPFM is rules compliance and enforcement.
With shrinking FCC field operations budgets, it will be mostly up
to existing broadcasters to shepherd and police their little LPFM
brothers on the band. The urge to run higher power than authorized
or excessive modulation for better coverage could prove tempting.
On balance, a greater good can be served here over the risk of
small pockets of increased potential interference. But the only
way LPFM could do a better job fulfilling its original mandate in
population centers is by relaxing the third adjacent protections.
The widespread use of modern receivers makes this feasible.
TO LEAD OR MISLEAD
Did the NAB intentionally mislead congress and the FCC about the
potential for interference if third-adjacent protection was dropped?
It's almost like asking did the Bush administration intentionally
mislead congress and the country about WMDs in Iraq before the war.
There certainly was evidence of the previous use of WMDs in specific
isolated cases. And it can be shown that interference may affect
some existing stations in limited areas near new third -adjacent
stations in specific isolated cases.
Predicting real interference in the crowded spectrum of FM broadcasting
is not all that difficult nowadays with computer modeling tools,
coupled with real world simulation testing and evaluation. Unfortunately
the FCC now says it doesn't have the budget to do any more field
testing. But the exercise is both science and art. Common sense
and historical perspective are needed here to unspin this controversy.
BETTER TECHNOLOGY PAVES THE WAY
The FCC adopted its basic channel allocation spacing plan for the
FM service back in 1964. The state of the art in both transmission
and receiver technology was primitive compared to performance capabilities
we have today. Improvements have grown by quantum leaps.
Better receiver front-end designs with improved selectivity and
overload immunity coupled with digital synthesizers, tighter IF
bandwidths and noise reducing decoders have allowed thousands of
stations on second- and third-adjacent channels to serve common
areas.
It doesn't take a radio engineer to realize that most populated
areas are home to many second- and third-adjacent stations that
have been serving the public for a long time with only minimal complaints
of interference. While most of these signals are low power, coming
from translators and boosters, many in the congested areas of the
northeast, Chicago and L.A. are full-power operations.
THE CROWDED REAL WORLD
Grandfathered short-spaced stations everywhere have been serving
large audiences all these years with the blessing of the NAB and
the commission. There are even some stations on first-adjacent channels
that serve overlapping areas in extended metro areas. If existing
stations continue to thrive in this environment, it's not unreasonable
to expect that new LPFM third-adjacent stations should be able to
coexist peacefully.
Relaxing the third-adjacent restriction will hardly turn the coverage
of full-powered stations into Swiss cheese, as a few opponents have
suggested. Adding a few hundred additional LPFM channels for larger
population centers will be a small blip on the allocations radar
screen for a band nearly fully populated already in many markets.
If LPFM had been proposed 40 years ago along with relaxation of
third-adjacent protection, it would have been a laughable non-starter.
Most FM radios didn't even have AFC locking back then. With fragile
front-ends and IFs broad as barn doors, allowing for plenty of protective
channel spacing was important to allow the fledgling FM service
to attract and hold listeners.
TRUTH ALWAYS WINS
It's not too hard to see how LPFM antagonists at the NAB and the
FCC found a friendly ally in the spacing rules when they went looking
for technical justifications to thwart the adoption of relaxing
the third adjacent into law. What they neglected to understand fully
or convey to non-technical congressmen voting on the issue was that
the aging rules do not address or allow for present practices or
the evolution of better technology.
As much as the NAB and those who still oppose LPFM expansion want
to pick apart the Mitre report as flawed or incomplete, they cannot
escape the reality that the FM band already supports thousands of
less than fully spaced stations that cover common areas and serve
their listeners quite well. Sorry, Eddie. The genie you've been
protecting all along for your friends is already out of the bottle.
Everyone can see it.
There is one other no-spin truth about LPFM that will actually
benefit existing broadcasters. As it grows and develops, LPFM can
serve as a fertile training ground for up-and-coming broadcasters
who now have a very hard time breaking into the business. Where
will the next Rush Limbaugh, who might be a teenager today find
an entrance into our industry?
Some argue that with so many cookie-cutter voice-tracked and satellite
fed automated stations, radio is snuffing out its ability to employ
and train new and aspiring talent. LPFM can help to counteract that
trend and will serve as a natural onramp to the big leagues.
Guy Wire is the pseudonym for a veteran broadcast engineer with major-market radio credentials. His opinions are his own and do not necessarily reflect those of Radio World. RW welcomes other points of view.
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