REC Networks / REC ネットワーク Michelle (“Michi”) Bradley J1 Radio/J1 ラジオ 太田道子 11541 Riverton Wharf Rd Founder of REC/Director of J1 Radio Mardela Springs, MD 21837 REC 代表取締役 +1 202 621-2355 J1 ラジオ ディレクター http://www.recnet.com [email protected] http://www.J1FM.tokyo CHANNEL LOADING SIMULATIONS FOR “WIDE-FM” (76.1~87.9 MHz) AS A LONG- TERM SOLUTION FOR MIGRATING LOCAL AM BROADCAST STATIONS WHILE MAINTAINING A CRITICAL NATIONAL AM INFRASTRUCTURE. March 9, 2020 TABLE OF CONTENTS Introduction 2 Classes of Service 2 Allocation Reference Points 2 Protection of TV Broadcast Stations 2 Low Power TV Stations 2 Foreign TV Stations 2 Protection of FM Facilities 3 Protection Between Wide-FM Facilities 3 Assignment of Channels in the Border Areas 3 Assignment of FM Broadcast Band Channels (92.1~107.9 MHz) 3 Reserved Band 3 Priority of Assignment 4 Listing of AM stations by call letters and their study allocations 5 Table of Allotments – Scenario 1 (Protecting Full-Service Ch. 5 & 6) 83 Metro Dialscapes – Scenario 1 122 Table of Allotments – Scenario 2 (No TV Channel 5 & 6 protections) 159 Metro Dialscapes – Scenario 2 206 TV stations considered in this study 256 Critical Nighttime Infrastructure 258 1 2 INTRODUCTION This study was created as a part of REC Networks’ comments in MB Docket 19-311 which examines a “long term” solution for the survival of local AM radio licensees that are facing continued AM band degradation as a result of evolving technologies and evolving consumer attitudes in respect to AM radio. In this document, we run two different allocation studies, one that takes existing full-service TV channel 5 & 6 stations into consideration and one that does not. This is to demonstrate that, compared to the use of this spectrum for LPTV (and in the second study, LPTV and DTV) is a much more efficient use. CLASSES OF SERVICE For this study, we create two classes of FM stations: W1 6 kW at 100 meters HAAT with a 28 km 60 dBu service contour. Comparable with FM Class A. Class W1 will be assigned to all eligible AM stations that operate a daytime power of 1 kW or less. Class W1 will also be assigned to stations operating more than 1 kW if a previous round of the study shows that there are no 25 kW (W2) channels available. This would include stations that are between 250~288 km from a protected Channel 5 or 6 TV station in the first scenario. W2 25 kW at 100 meters HAAT with a 39 km 60 dBu service contour. Comparable with FM class C3. Class W2 will be assigned to eligible AM stations that operate a daytime power of more than 1 kW but less than 50 kW. FM “Zones” are not used in this concept. W2 stations are always protected to the 60 dBu service contour regardless of geographic location. ALLOCATION REFERENCE POINTS Reference points that are used for the new facilities are based on an allotment reference coordinate, normally the coordinates shown in the U.S. Census Bureau’s Gazetteer and therefore, they do not reflect the proposed station’s actual transmitter site. Locations of existing FM and TV broadcast stations are based on their actual transmitter location. PROTECTION OF TV BROADCAST STATIONS In the first scenario, we attempt to load each station but still providing the following protections to existing FM and full-service DTV channel 5 and 6 stations. • Class W1 stations will protect DTV stations by a minimum of 250 kilometers. • Class W2 stations will protect DTV stations by a minimum of 288 kilometers. These distances were calculated by using the class standard distance of the FM station’s 34 dBu F[50, 10] interfering contour with the DTV station’s 28 dBu F[50, 90] noise-limited service contour. We acknowledge that this is a massive overprotection and as demonstrated by the “franken-FM” LPTV stations, operation closer to a co-channel DTV station may be possible but for the sake of overprotection, we will use these distances in the study. LOW POWER TV STATIONS There are over 100 Low Power TV (LPTV) stations operating in this spectrum, some digital and some analog. LPTV stations are secondary and they were applied for and granted under the full knowledge that their service is secondary and would be subject to displacement. Neither scenario protects any LPTV stations. FOREIGN TV STATIONS REC has identified 29 full-service TV stations in Canada. Only a few are in the border area. These TV stations will be protected in this report in a manner similar to U.S. full-service DTV stations. Low Power stations are secondary, and no protection is being offered in the first 3 scenario. There are currently no TV channel 5 or 6 stations in Mexico that would have any impact on this report. Canada TV data is provided by Industry Canada and Mexico data is provided by IFT and are both effective as of February, 2020. PROTECTION OF FM FACILITIES For full-service FM stations in the USA, Canada and Mexico, these facilities will be protected using the same distance separations outlined in §73.207 of the rules using the following comparable service classes: Wide FM class FCC FM class Canada FM class Mexico FM class W1 A B1 AA W2 C3 B1 B1 LPFM and FM translator stations, being secondary services are not protected in this study. We do note though that since commercial band FM channels were only assigned in rural areas, the impacts to LPFM stations will be minimal. PROTECTION BETWEEN WIDE-FM FACILITIES Class W1 and W2 stations will protect each other similar to the §73.207 protections for Class A and C3 stations except that third-adjacent channel protection is not prescribed. Relation Co-channel First-adj Second-adj Third-adj IF W1 to W1 115 72 31 none 10 W1 to W2 142 89 42 none 12 W2 to W1 142 89 42 none 12 W2 to W2 153 99 43 none 14 ASSIGNMENT OF CHANNELS IN THE BORDER AREAS In order to assure that Mexico and Canada can have opportunities for new Wide-FM stations within their jurisdictions, the program will block out 30 of the 60 channels in areas where reference coordinates are within 150 kilometers of the border. Under spectrum sharing: 79.1~81.9 (156~170) and 85.1~87.9 (186~199) are available to the USA. 76.1~78.9 (141~155) and 82.1~84.9 (171~185) are available to Mexico and Canada. ASSIGNMENT OF FM BROADCAST BAND CHANNELS (92.1~107.9 MHz) For each AM facility evaluated, the program will first attempt to assign the channel in the commercial FM broadcast band. The study managed to assign 127 such facilities in the first scenario (with TV protections) and 56 in the second scenario. All AM stations in Guam and the Northern Marianas were given FM broadcast band channels. RESERVED BAND No assignments were made in the reserved band (88.1~91.9). 4 PRIORITY OF ASSIGNMENT For both scenarios, channels were allocated to AM facilities in the following rounds: Round 1 New class All Class C AM stations by ascending order of daytime power W1 facilities and then by descending order of population in the allotment community. Round 2 New class Class D stations that have a daytime power of 1 kW or less. W1 facilities Ordered by daytime power, then by nighttime power and then by descending population in the allotment community. Round 3 New class Class D stations that have a daytime power exceeding 1 kW and W2 facilities a nighttime power of less than (but not equal to) 5 kW. Ordered by daytime power, then by nighttime power and then by descending population in the allotment community. Round 4 New Class Class D stations that exceed 1kW daytime power that were W1 facilities unable to find a W2 channel in Round 3. Ordered by daytime power, then by nighttime power and then by descending population in the allotment community. Round 5 New Class Class B stations that have a daytime power of 1 kW or less. W1 facilities Ordered by daytime power, then by nighttime power and then by descending population in the allotment community. Round 6 New Class Class B stations that a daytime power exceeding 1 kW and a W2 facilities nighttime power of less than (but not equal to) 5 kW. Ordered by daytime power, then by nighttime power and then by descending population in the allotment community. Round 7 New Class Class B stations that exceed 1kW daytime power that were W1 facilities unable to find a W2 channel in Round 6. Ordered by daytime power, then by nighttime power and then by descending population in the allotment community. Round 8 New class Class B stations that exceed or are equal to 5 kW daytime power W2 facilities and a nighttime power of less than (but not equal to ) 10 kW. Ordered by daytime power, then by nighttime power and then by descending population in the allotment community. Round 9 New class Class B stations that have a nighttime power of at least 10 kW W2 facilities but less than (and not equal to) 50 kW. Ordered by daytime power, then by nighttime power and then by descending population in the allotment community. Channel selection was determined by calculating the distance to the closest wide-FM allotment on co-channel and then assigning the channel with the closest (but properly spaced) wide-FM allotment. A more efficient method of assignment could allow more allotments to be placed into the band.