BEFORE THE Federal Communications Commission WASHINGTON, DC 20554

In the Matter of ) ) All-Digital AM Broadcasting ) MB Docket No. 19-311 ) ) Revitalization of the AM Radio Service ) MB Docket No. 13-249 ) ) )

To: The Commission

COMMENTS OF THE CRAWFORD BROADCASTING COMPANY

Crawford Broadcasting Company (“Crawford”) and its affiliates are licensees of 15 AM commercial broadcast stations1, all but two of which currently operate in the hybrid analog/digital mode. As such, we have great interest in the Notice of Proposed Rulemaking to permit all AM stations to broadcast an all-digital signal using the HD Radio in-band on-channel (IBOC) mode known as MA3 on a voluntary basis (“Notice”), and we offer the following comments in support of this petition.

I. Benefits of All-Digital AM Transmissions

It has been well established for more than a decade of operation by many of our stations in the MA1 hybrid digital mode that AM stations stand to gain a great deal from digital operation. Greatly improved audio quality is at the forefront, with audio bandwidth comparable to FM broadcasts, stereo audio and receiver display of title/artist or program title information. When a receiver locks in the digital mode to one of our stations, particularly one playing music, as the receiver blends from analog to digital, the contrast is dramatic. The highs and lows of the audio open up, the stereo image widens out, and the noise that seems to be ever present on almost any AM frequency disappears. Listeners experiencing this effect for the first time are quite often amazed at how good an AM broadcast can sound in this mode.

All that being said, the limitations of the hybrid mode are significant, and we have become well acquainted with them over the past 15+ years of such operation. From a listener perspective, the low power of the digital carriers in the hybrid mode makes them susceptible to interference, particularly from noise, and receivers frequently transition between digital and analog in noise- prone and/or weak-signal areas. At best, this is perceived as a narrowing of the audio response and stereo image; at worst, even with perfectly time-aligned analog and digital audio, if the bit-

1 Crawford AM affiliates include KBRT, Costa Mesa, CA; KNSN, San Diego, CA; KCBC, Manteca, CA; KKPZ, Portland, OR; KLZ/KLDC, Denver, CO; KLTT, Commerce City, CO; KLVZ, Brighton, CO; WDCX/WDCZ, Buffalo, NY; WYDE/WXJC, Birmingham, AL; WCHB, Royal Oak, MI; WMUZ, Taylor, MI; and WRDT, Monroe, MI.

error rate is significantly high, it can result in a time-shifting of the audio during the blend process, which is an irritation to most listeners. Further, during lightning season when convective weather activity is present, even the strongest signals experience an almost continual transition into and out of digital.

In terms of spectrum, the hybrid mode has the potential for interference to stations on adjacent channels. We have found that even though emissions are confined to remain well within the mask defined by 47 C.F.R. §73.44, they still have the potential to cause interference to spectrum neighbors, which is a significant problem.

This same issue, namely the spectrum bandwidth required for hybrid mode HD Radio transmissions, places significant demands on AM antennas and transmission systems. In the process of implementing hybrid mode digital transmissions on many of our AM stations, we had to make significant modifications to our phasing and coupling systems. At the very least, we had to either make modifications to matching networks or construct and install phase rotation networks to provide for proper load orientation. In many cases we had to optimize the entire transmission system to equip it to pass the hybrid HD Radio signal. This represents a significant expense in many cases and is an impediment to conversion for many licensees.

All-digital operation alleviates many of these issues. All the power transmitted is used for the digital carriers instead of a small fraction. As such, a much more robust RF signal-to-noise ratio is produced which in turn results in much more robust digital demodulation. There is no transition from analog to digital, and as such there is no need to maintain any kind of analog audio diversity delay to produce time alignment of demodulated analog and digital signals. Presumably the higher digital power also provides a much greater immunity to static discharges.

Spectrally, the all-digital mode, for which the emissions are confined to within ± 5 kHz of the center frequency, has much less potential for interference to spectrum neighbors. Even if the secondary and tertiary carriers are transmitted, the occupied spectrum is within ± 10 kHz of the center frequency.

This occupied bandwidth also places greatly reduced demands on the transmission system. Since virtually all AM transmission systems are equipped to pass analog audio transmissions with sidebands extending to ± 5 kHz from carrier, those systems should pass the MA3 primary digital carriers without issue, although some load orientation optimization may be required in some cases. This effectively removes a big technical and economic impediment to digital conversion for many licensees.

In short, the MA3 all-digital mode provides all the benefits of the MA1 hybrid mode without the negatives and difficulties, making the demodulated audio comparable in many ways to FM.

II. Costs of Conversion

It has been many years since Crawford has done any de novo IBOC conversions; those conversions, for the most part, took place during the initial wave of conversions in the early 2000s immediately after the Commission authorized such transmissions. As such, we have little recent experience with such conversions and the costs associated therewith.

However, we have in recent years made equipment upgrades, replacing existing first- and second- generation HD Radio generation equipment with current-generation equipment. Assuming that the associated transmitter is a fairly late model and “HD ready,” this equipment upgrade does

2 represent most of the cost associated with conversion, exclusive of STL, audio processor and monitoring equipment upgrades that may be necessary in some installations.

We find that these costs, which are less than $20,000 in most cases, are not a big impediment to conversion for many licensees, but we recognize that for many others this represents a small fortune. If other upgrades must also be made, such as transmitter replacement, STL upgrade and audio processor replacement, the costs can be prohibitive for stations that operate on thin margins to begin with. Add to that the cost of licensing by Xperi and the situation can be even worse.

It is our conclusion, then, that the issue of conversion costs is highly dependent on each station’s (or licensee’s) individual situation, which is a big argument in favor of making the transition to the all-digital mode completely voluntary.

III. Auxiliary Data

Our observation in recent years has been that listeners have come to expect radio display of song or program title/artist, and that stations whose transmissions do not include such information are at a competitive disadvantage. For FM stations, such metadata transmission can be provided in the analog domain by RBDS, or in the digital domain by embedded program service data (PSD) streams. AM stations operating in a strictly analog mode have no means of transmitting metadata to receivers.

Both MA1 and MA3 mode digital transmissions do have the capacity to convey metadata to receivers, although it has been our experience that metadata conveyance can be hit-or-miss in less than optimum conditions, such as in areas of interference, noise or during convective activity. Still, we would consider such a vital component of AM digital operation.

We recognize that other uses can be made of auxiliary data streams within the MA3 framework, but we do not consider those to be primary. The exception would be EAS and other emergency alerts, for which we already employ some of the auxiliary data features of the MA1 digital mode for our hybrid-mode digital AM stations.

IV. Nighttime All-Digital Operation

We believe that for all-digital operation to succeed at all, it must be permitted both day and night. While we realize that there is increased potential for interference through skywave propagation at night, because MA3 emissions are confined to the bandwidth of the analog signal, we do not believe that such transmissions will produce increased nighttime interference. The nature of the interference may change – the interfering signal from a station transmitting in the analog mode will have identifiable audio, while the interfering signal from the same station transmitting in the MA3 mode will tend to sound like noise. We do not believe this is a significant distinction or impediment.

In terms of coverage, it was well established in the WWFD all-digital tests that the nighttime all- digital coverage extended to the nighttime interference-free (NIF) contour. We believe that this would be sufficient in many cases. We also believe that the nighttime all-digital coverage of many stations will extend well beyond the NIF contour, depending on the nature of the nighttime interference. We believe that the only way to establish this is to authorize nighttime all-digital transmissions and gather data from stations over time.

3 V. Power Limits and NRSC-5 Adoption

We agree that the allowed operating power limits for AM stations as set forth in §73.21 of the FCC’s rules should apply to the unmodulated audio carrier signal for stations that have converted to all-digital operation. We also agree that the HD Radio Emissions Mask, shown in Figure 11 of the NRSC-5-D Standard, should determine the allowable power for the digital sidebands.

We do not, however, support incorporation of the NRSC-5 mask into the Rules as yet. As noted, it has not yet been determined whether real-world digital stations would be able to comply with this mask. We believe that the emission mask specified in §73.44, which would in any event remain in force, would protect other stations on adjacent channels, both analog and digital, from interference.

We do not believe that the Commission should wait to approve all-digital operation until the issue of NRSC-5 MA3-mode mask compliance can be established. §73.44(c) contains the provision that: “Should harmful interference be caused to the reception of other broadcast or non-broadcast stations by out of band emissions, the licensee may be directed to achieve a greater degree of attenuation than specified in paragraphs (a) and (b) of this section.” This provision can, if necessary, be employed on a case-by-case basis to require a modified emission mask, should harmful interference be produced by an all-digital station.

We do not otherwise object to adoption of the NRSC-5 Digital Standard for all digital stations, hybrid as well as all-digital.

VI. Carrier Frequency Tolerance Standard

Crawford does not object to a 1 Hz carrier frequency tolerance for AM stations as a means of improving all-digital reception. In fact, Crawford currently strives to maintain its carrier frequencies within a 1 Hz tolerance as a means of reducing beat note interference to and from co- channel stations, particularly at night.

It has been our experience that current-generation AM transmitter equipment has no trouble meeting such a requirement. That being said, older AM transmitter equipment may have significant issues maintaining such a tight frequency tolerance, and we believe that some provision should be made for stations still employing such older equipment and unable to upgrade for economic reasons. We would suggest a compliance deadline well into the future or a sundown date as a means of dealing with this issue, which would provide licensees with a very reasonable period of time in which to achieve compliance, either by replacement/upgrade of transmitter equipment or the installation of external signal-generating equipment that will meet the tighter tolerance.

VII. Conclusion

In summary, Crawford believes, based on its own lengthy experience with hybrid-mode AM digital transmissions, that the all-digital mode has much to offer AM broadcasters. In addition to greatly improved audio fidelity, stereo image and metadata display, it has been proven to offer a high degree of noise immunity. To listeners with HD Radio capable receivers, this would to a great extent level the playing field with FM analog and digital broadcasts, doing much to remove the disparity between AM and FM signals from the listener’s perspective.

4 The decision to convert to all-digital operation is highly individual and depends on each station or licensee’s financial situation and the overall situation with the station, including transmission equipment complement, programming, competitive position, duplicated programming on an FM (translator or otherwise) signal, and HD Radio receiver penetration in a particular market. As such, we believe that all-digital operation should be voluntary and completely at the discretion of the licensee.

All-digital operation should be permitted both day and night. Emissions should be within the §73.44 mask but should comply as closely as possible with the NRSC-5 all-digital AM mask. Power limits of the unmodulated carrier should be governed by §73.21, and digital carrier power levels should be set by the Figure 11 of the NRSC-5 Digital Standard. The frequency tolerance for all AM stations should be tightened to 1 Hz, with an appropriate amount of time permitted for achieving compliance.

Respectfully submitted, CRAWFORD BROADCASTING COMPANY

W. Cris Alexander, CPBE, AMD, DRB Director of Engineering 2821 S. Parker Road, Suite 1205 Aurora, CO 80014

January 27, 2020

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