•r DOCI<ET FILE COPY ORIGINAL ' REPLY COMMENTS REGARDING the FCC MEDIA BUREAU'S PROPOSAL FOR AM RADIO IMPROVEMENT 13-249 from Bob Bittner Recewed. & \"spected,, P 0 Box 308 - Bath, ME 04530 tii\R 2 5 2014 I, ~f9UgW1tillJ1~WafJi corporations, own WJIB (740 AM, Cambridge, MA), WJTO {730 AM, Bath, ME), W252BT (98.3 FM, Freeport. ME) and WFAU (1280 AM, Gardiner, ME). From the immense amount of listener letters I receive, audiences of those stations are very enthusiastic about my AM stations. On all four stations, I program "adult standards" music. The audience is basically senior citizens.... which maRes a point: Older folm are familiar with AM radio. AM is their old friend. Generally not so for middle-aged and younger folm. There will be a time when those who still love and favor AM radio will be gone. I am pleased that the Commission is concerned about the condition of AM radio broadcasting. Instead of citing exact examples of the trials & tribulations of the AM spectrum, and instead of citing examples of community-minded AM stations, I would li~ to get right to my suggestions to bring AM radio bad? to its former vibrant luster. I believe any and/or all of these below points will create a financially-sound environment for AM stations. The tone of my suggestions encourages ~ping the AM band analog and ~ping the AM band being receivable on USA residents' currently-owned radios, or allowing the migration of AM stations to TV channels 5 and 6 (76 to 88 mHz). Least attractive is allowing or requiring in-band IBOC digital, which has proven to be a disaster for AM radio. 1 - BRING BACK AM-STEREO: While stations are currently permitted to broadcast in AM stereo, the Commission should use its power to require all radio manufacturers to sell radios capable to receive AM stereo. It sounded fantastic! 2- ESTABLISH MOREJ$TRICT RADIO-MANUFACTURING STANDARDS: AM's biggest problem is the abundance of cheap radios in the field, where manufacturers paid little or no attention to the quality of the AM portion. AM sounds quite excellent on a receiver that far exceeds todays' standards, which still does not cost much to manufacture. 3 -ALLOW MANV AM STATIONS TO INCREASE DAYTIME POWER: with relaxation of the field intensity rules (except for those who would interfere with Canadian, Mexican or Bahamian clear channel frequencies). so~ Class A stations generally need not a power increase. However, Class B, C & D stat.ions generally do, in order to lessen man-made environmental noise. If all 8, C & D stations (20~ and under) were allowed to do such at the same time, interference would not be an issue. I do not see any reason why any station couldn't have a power of about 2,500 watts. For example, if all Class C's on 1230, 1240, 1340, 1400, 1450, 1490 were allowed to have 2,500 watts, they would cover their COL's much better. With such stations presently having 1,000 watts, and many being only 55 miles apart, there ARE areas in between them that receive hash for a signal, and with granting them 2,500 watts would create hash in the same areas. So what's the difference? - I am not suggesting a ~o . ct Goi)i~ rec'd__tlti f Llzt ABCDE - blanRE!t power increase for B, C & D stations, but rather a revision of the interference standards (for all AM stations). I suggest something along the lines of: Co-Channel: 0 .1 to 1.0 mv/m; First Adjacent 1.0 to 1.0 mv/m; Second Adjacent; 5.0 to 25.0 mv/m; Third Adjacent 25.0 to so mv/m. There's should also be a 'half-way' type wattage limit for any station or a territory cap, so as to prevent one faster-moving station from invading ALL of the space between other stations involved, giving the other stations the same opportunity to increase power to that midway point 4-ALLOW MANV AM STATIONS TO INCREASE NIGHTTIME POWER: There is no reason any more for "daytimers" being greatly limited or non-existent at night Except for Canadian, Mexican & Bahamian clear channel frequencies, I would suggest that all daytimers be allowed at least 250 watts at night, along with perhaps 1,000 watts from 5 AM to sunrise and also 1,000 watts from sunset to 90 minutes after sunset; again based upon more lenient interference standards. Those stations on the above-mentioned foreign frequencies could perhaps be granted lower power than the 250/1,000 watts mentioned, If there is any wiggle­ room in treaties. 5-ALLOW ALL AM's TO MATCH THEIR CURRENTLY-LICENSED FIELD INTENSITV LIMITS: Many, if not most AM stations have ground systems which are broRE!n, corroded or just plain missing; the latter from copper theft. And in some cases, real estate upon which the ground system is located has been sub-divided or under new ownership, where repairing the ground radials are not possible, or at least not possible budgetwise. IF SECTIONS 3 and 4 ABOVE ARE NOT TO THE COMMISSION'S LIKING, then perhaps this section s would be. I propose that all AM stations have the option to increase their power to the point of their licensed filed intensity limits. For example, If a station's signal is measured at 0.2 mv/m on the 0 .5 mv/m contour, then a power increase grant could be given to the station so that the actual signal reads o.s mv/m at that location. "That location" is plural.... I suggest that if a station wants to increase it's ailing signal, it should submit to the Commission eight (8) symmetrical readings on each of the 25.0, the 2.5 and the 0.5 contours, for a total of 24 readings, and then taRe the average of all readings to base a calculated power-increase upon. (Over water areas excepted). In the case of directional stations; that, plus the monitor points specified in the license. This way, no technical studies need be done, and no treaties need to be re-negotiated, and no current interference rules need to be adjusted. 6-ALLOW AM'S TO REDUCE NIGHTTIME POWER AND GO NON-DIRECTIONAL- Many Oass B stations have failing old directional arrays, where it is not at all cost-effective to repair such. In many cases, reducing night power from 5,000 watts directional to soo to 2,500 watts non-directional, would actually improve the signal in the COL A more lenient adjustment to the field intensity limits would allow this, and not cause any noticeable difference in interference to other stations. 7 - ADJUST REGULA TORY FEES: When such fees were introduced in 1993, they were minimal. Now, they have increased more than 400%, significantly higher than the cost of living. Bact? in 1993, the FCC was handed a suggested chart based upon station class and population served, and the Commission adopted it This has many many flaws. First. there is no increase in fees for stations that serve larger than 3,000,000 people. The fee for a station serving 3,000,001 people is the same as a station serving 10,000,000 people. This was done to t?eep the largest 2 stations from paying their fair shore. Furthermore, all fees are s~ in favor of larger stations, punishing the smaller stations. While at first glance the chart may LOOK fair, it isn't. For example, SOI:?w WBZ (Boston) was charged approximately $9,000.00 in 2013. 250-watt daytimer WJIB (5 watts at night) paid about $5,400.00. WBZ's gross income was approximately $30,000,000.00. The most that WJIB would be able to bill would be about $800,000.00, and only if it were to bro~r out all hours. Therefore WBZ rna~ 37.5 times as much as what little WJIB could possibly rna~. but WBZ pays only 1.8 times as much as WJIB. That's 37.S x versus 1.8x. - My suggestion is to totally eliminate the chart for AM & FM broadcast stations and charge the same percentage of each station's income, so that the Commission would still collect the same amount of money to fund itself, but also doing it fairly. This is how it has been done with stations paying music royalties to ASCAP and BMI for most of the past 50 years..... why not with regulatory fees? This would be a great boost for a vast majority of AM stations. A reduction of financial expenses will greatly help AM stations to spend more on anything that would improve community service. (OK, some owners would just poe~ the difference, but many wouldn't). 8 - ANTENNA HEIGHT AND GROUND SYSTEM REQUIREMENTS: Current requirements should be loosened to allow shorter towers, and shorter (perhaps shorter and an option of additional radials) ground systems. In a perfect world, where there are no Environmental Impact Statements, NIMBV's, Zoning Boards, etc, it is admirable to set strict standards. But in today's world, and with some AM's losing their tower sites, it is nearly impossible, financially, to construct new AM towers for existing stations or maintain existing land-gobbling multi-tower arrays, causing stations to go dam. I am not suggesting AM's being allowed to have towers the small size of Travelers Information Stations (TIS), but rather somewhere in between. An AM station's existence is more important than strict technical rules. 9- REPEAL THE ONE-VEAR LAW: The Telecommunications Act of 1996, enacted by Congress, was for the most part, a disaster for local radio.