Despite the fact that these AM bandwidth allocations were never intended to accomodate the use of digital broadcast signals, IBOC takes advantage ofthis allocated spectrum space in order to saddle an AM carrier with continuously modulated sidebands across a +1- 15 kHz bandwidth, carrying the station's digital data streams on the first- and second-adjacent channels -- which can hardly be described as "In-Band, On-Channel". The results ofthis kind ofjury-rigged system have become well-known and well-documented. The moc sidebands completely destroy reception ofthe first-adjacent channels across a station's entire coverage area, and fill the second-adjacent channels with a constant interference which can also cause reception ofneighboring stations to be seriously impaired. And with the sideband linearity problems that many directional AM antenna arrays exhibit, additional receiver-induced interference can greatly harm reception of channels up to 40 kHz away from an IBOC station's carrier frequency -- as listeners ofIBOC stations such as 710 WOR have experienced at distances even beyond the station's 0.5 mV1m coverage area. Now, as if these problems associated with the daytime use ofIBOC aren't great enough, nighttime use ofIBOC is being considered for approval as well -- despite the fact that it is well-documented to cause destructive interference, even beyond the borders ofthe USA into neighboring countries, whose stations will also suffer from this interference. The justification for this appears to be based solely upon the testing of a handful ofstations, as received on a handful ofradios, in a handful of locations. But when we are dealing with thousands ofstations, millions of listeners, and billions of receivers, is a handful really enough? The FCC must not allow IBGC to be implemented on the AM broadcast band. I've listened to numerous test stations running the lBGC system and they cause serious interference to first and second adjacent channels especially at night. Example: WSAI AM 1530 from Cincinnati obliterates WWKB AM 1520 in Buffalo at night even if you are only ten to 15 miles west of their directional signal. AM 850 in st. Louis wipes out WHAS AM 840 from Louisville throughout most of Illinois and Indiana where otherwise in many of these places you could listen to WHAS both day and night. lBoe will render most lower power AM stations as useless while only the highest powered stations will be able to get decent coverage. I also support the Amherst Alliance filings on IBoe. L- Before the FEDERAL COMMUNICATIONS COMMISSION Washington D.C. 20554 In the Matter ofAmendment ofPart 73 ofthe ) Commission's Rules to Permit ) Docket Number: MM 99-325 The Introduction of Digital Audio ) Reply Comments Broadcasting in the AM and ) FM Broadcast Service ) Frederick R. Vobbe 706 Mackenzie Drive Lima OH 45805-1835 I, Frederick R. Vobbe, am a qualified broadcast and communications engineer with thirty-six years of service in the broadcast industry. I am a licensed and practicing amateur radio operator, radio/TV/electronics experimenter, and radio listener. My professional duties include Vice President and ChiefOperator ofan NTSC and DTV television stations, Communications Officer for the Allen County Office ofHomeland Security, Chairman ofthe Lima/Allen County E.A.S. district, and Chairman ofour state amateur repeater coordination body. I have also published a monthly magazine on tape for blind radio enthusiasts continuously since 1985, and jointly operate a web site and various E-mail lists on the topic ofradio/TV technology and listener support. Along with my positions in engineering I have also been employed as Operations Manager of several radio stations, and have served as an advisor to broadcast stations acting in fields ofprogram and finance. Interference Issues NRSC Mask Many ofthose commenting stated that moc transmissions meet the NRSC mask set forth in the FCC rules. The NRSC mask was designed for analog transmissions, not digital. The NRSC mask is acceptable for analog program content with random and varying analog audio peaks. However, digital transmissions fill the entire mask area. To compare an Page 1 analog transmission inside an NRSC mask with a digital transmission inside the mask is like saying that 1 cubic feet ofaluminum (analog) weighs the same as I cubic feet of lead (lBOC) because they are both the same height, width, and depth. Digital transmissions do not conform to the same characteristics as analog transmissions. While the analog will fill the mask at various points in time, the digital mask fills the entire area immediately. A good test ofthis would be to take a 500 ms sample ofan analog transmission, then digital transmission. You will note that digital transmission is denser, and fills the bandwidth. While the analog fills random points depending on program density and levels of modulation. The non-engineer should look at digital as a 16-ounce glass filled with water. Think of analog as that same glass but filled with large ice cubes and water. When you pour the water into a beaker calibrated to ounces, the "digital" water would give you 16-ounces of liquid. But the "analog" water would yield significantly less liquid, until such a time as the ice all melted. When measurements have been made on digital RF signals they have allowed the "ice to melt" in the analog world, waited till they have had enough random peaks ofmodulation to display in the mask. Then they have measured the digital, (which fills up almost instantaneously), and emphatically state that the two signals are alike. This is simply a misrepresentation. Receivers The larger majority ofAM receivers do not have the sophisticated band pass capabilities to reject signals in excess of 5 kilohertz. For example, in a stock GE "Superradio lII" portable radio, the receiver normally captures transmitted signals 5 to 8 kilohertz either side ofcarrier. Under analog conditions this is acceptable. Ofthe sixteen radios that 1 own, both in dash car radios and portables each have similar characteristics. None ofthe radios 1own possess a method in which to exclude the lBOC signal and leave an unaffected analog signal. Although a radio station may employ the NRSC mask, 1do not know ofany large number ofreceivers that employ such a mask as part ofthe normal circuitry. There are radios that employ high quality band filtering yet these receivers are the exception rather than the norm Page 2 ~.,.----------------- .._ .. --._------------_._-_.. -----_._-_.. for the average citizen. Since there is not a filtering at the receiver stage, although stations employ a NRSC mask, the end user will still receive interference in the form ofconstant digital hash. Exemptions to Interference I am concerned when the Commission starts to apply "exemptions" to real interference issues from moc. The Commission may be drawn into serious legal questions in the future. Ifthe Commission agrees with the idea that moc interference is acceptable in the scope of furthering technology, the Commission would logically, and without challenge, have to accept interference from ... • Broadband over Power Lines. • Devices and transmitters in excess ofthe limits specified in CFR 47, Part 15 • Low Power AM stations. • International broadcaster interference. In each ofthe above example I could easily show a benefit to citizens ofthe United States. But the Commission needs to ask it's self, does the need for cool technology outweigh what is a reasonable interference criteria? In short, once the Commission allows the argument that interference is acceptable, then the Commission would be hard pressed to restrict other forms of interference without giving the appearance oftipping the scales. The Commission needs to take the stand that NO INTERFERENCE is the standard. Any implementation of IBOC transmissions must adhere to this criteria without question. It is the only fair that everyone operate and live by the same rules. Page 3 ------ ----- Second Adjacent Interference Much has been said about I" adjacent interference. That is, a station operating on 710 kilohertz interferes with stations on 700 kilohertz and no kilohertz. In comments I wrote earlier, I noted I" adjacent interference while driving toward Chicago, Illinois, during very severe weather. My radio was a stock GM radio in a ZOOI Buick Century. I could not hear the weather reports given on WGN-nO at the time due to the IBOC transmissions ofWOR-710. Prior to this event, and dating back to the mid-1970s, this was never a problem. However, there are also cases of interference to the Znd adjacent. Znd adjacent moc was documented in the original test reports produced by iBiquity. Unfortunately, anyone reading those reports, and the NRSC, who were responsible for evaluating them, glossed over the interference issues. Out offour test receivers, three showed moderate to severe impairment to reception when subjected to Znd adjacent moc at 0 dB DIU. The only receiver that was not significantly affected was a Delphi car radio. Oddly, it was the Delphi car radio iBiquity chose to use in their interference studies. Is this is a fair representation? The Delphi radio, although a decent radio for most consumer applications, is not the average radio used by the American public. Using the radio with the best possible rejection, and not introducing the radios used by the larger majority ofthe public is a misleading test. The susceptibility to adjacent channel interference depends on the receiver's IF filter characteristics. A receiver with relatively good I" adjacent rejection is not likely affected by I" adjacent IBOC. Receivers without a good I" adjacent rejection will be affected because it appears as co-channel noise. The larger majority ofAM receivers in the United States today have poor to very poor I" adjacent rejection. These receivers are affected by analog interference, and adding IBOC creates an in tolerable situation.