Group Comments on the Conversion of the Analog FM Band to IBOC (In Band on Channel) Digital Broadcasting, RM 9395, Docket 99-325



Click Here To Read The Full Text Of RM 9395.

This comment on IBOC has been compiled based on other filings, especially those of REC Networks, and discussions with others including WRFR and the Prometheus Project. Both WRFR and the Prometheus Project have filed their own comments. The Committee for Democratic Communication (CDC) is not considering filing their own comments, but have signed on here. You may also wish to visit the WRFR IBOC Page for impressive technical arguments that go beyond the scope of this simple document.

The comments below are worded and organized to make a complex and technical issue as understandable as possible. IBOC is a direct threat to Low Power FM and the future of free FM radio and will contribute to further consolidation of ownership on the FM band. Moreover, it will cost consumers billions of dollars and deprive the public of billions of dollars in revenue from auctioning off a new Digital Audio Broadcasting (DAB) Band. The need for this service and the technology developed for IBOC is seriously in question.

Rather than a filing that focuses solely of LPFM related problems with IBOC, this document seeks to take a more general approach while still dealing with LPFM issues.

It is imperative that the Low Power Radio Movement and proponents of National Media Reform file reply comments on this issue or sign onto a comment's supplement before the quickly approaching Reply Comment deadline of February 22, 2000. Which comment you sign doesn't matter. If you only agree with one or two sections, copy and paste them and file your own, write your own, just do something! We need to show the media lobby and federal regulators that we intend to have a voice in national media policy.

Click here to go directly to the FCC Electronic Comment Filing System to file your own reply comments. The RM is 9395 and Docket is 99-325.

While it always preferable to have the wider Micro Radio community make earlier input to these types of documents, unfortunately the amount of time to gather signatures, the holidaze, and the technical nature precluded this. I though better something than nothing, so here you go. As this comment has been filed, it is not open to amendment.

If you are not familiar with this type of filing, take a look at the group filing we did for the Low Power Radio Rulemaking.

Remember, signing the supplement for this comment does not prevent you from filing your own reply comments or signing other reply comments.

If you wish to add your name and/or organization email me with the following information:

Legal Name
Organizations Full Name
City and State (a full address is not required)
Please put "IBOC" in the subject heading.

A Supplement this comment will be filed no later than 12 noon Pacific Time, February 22, 2000.

The filing is being organized by Rogue Radio Research which is part of Rogue Communication.

Ted M. Coopman

Go to Rogue Radio Research Homepage | Go to FCC Homepage | Go to FCC Electronic Comment Filing Page

Before the
Federal Communications Commission
Washington, D.C. 20554

In the Matter of RM No. 9395
Amendment of Part 73 of the Commission's Rules to Permit the
Introduction of Digital Audio Broadcasting in the AM and FM Broadcast
Services )

We, the undersigned organizations and individuals, representative of a wide spectrum of advocates for a democratic, community service oriented, free AM-FM broadcast service, strongly believe that the NPRM concerning the adoption of In Band On Channel (IBOC) terrestrial Digital Audio Broadcasting (DAB) is ill-conceived. We the undersigned, urge the Commission to reject RM 9395 and explore other proven technologies for terrestrial Digital Audio Broadcasting.

1. There has been no proven public demand for the conversion of FM analog to DAB. Considering this move will make every one the of the current 500,000,000 or so radio receivers in the United States obsolete, affect virtually every US citizen, and cost consumers hundreds of millions if not billions of dollars to replace them, it would seem that national public hearings on this matter are in order before IBOC is voted on by the Commission.

2. Forcing the conversion of analog FM to DAB would prove a hardship on existing small commercial, public, and community radio stations, not to mention the many stations that will exist under the creation of a Low Power Radio Service. Many of these stations provide a vast quantity of the truly local programming and information and often operate on very tight budgets. Having to replace transmitter equipment on the whim of a few powerful companies that stand to make millions if not billions from selling digital transmitters is unacceptable. IBOC will result in the further consolidation of the spectrum and the extinction of many of these community stations.

3. FM analog is an accepted international standard. With the exception of Japan and some former Eastern-Bloc countries, the 87.5-108.0 MHz band is used around the world for FM audio broadcasting. The AM/FM radio can be used practically anywhere in the world. Such a global standard does not and never will exist for DAB.

4. While the undersigned support the development of a digital radio service, we feel that such a service should not be within the 76-108 MHz band. the Commission should look at core television spectrum between channels 7-13, 14-36 and 38-51 for a digital broadcasting service. Several lower bandwidth digital FM channels can be splintered between DTV channels after the transition. Either the entire VHF high band (174-216 MHz) can be dedicated to DAB or stations can be placed throughout the UHF (470-604, 610-694 MHz) band. Signals above 174 MHz are less prone to propagation, which has been known to happen in the current FM broadcast band.

5. Failing to move DAB to another band would deprive the public billions of dollars of revenue in auctioning off these frequencies. Simply granting additional spectrum to broadcasters inside the FM band for this conversion is nothing more than a give-away of national resources to for-profit business interests. Moreover, the potential for FM broadcasters to deploy data systems, pager, and cell phone services using their FM bandwidth is clearly unfair competition to those services who must bid for limited frequencies and install expensive towers and other facilities. FM license holders are getting bandwidth for these services for free, again depriving the public of revenue.

6. IBOC is far from an being an efficient or proven technology. Unlike an analog signal, you either pick up a digital signal or you do not. There is no "static," no weaker signal. IBOC will reduce, not improve reception. We know from our experience with digital cellular telephones, that reception of digital signals are marginal in mountainous areas. Service to remote areas must be maintained.

7. DAB technology is something that will have to prove itself and should not be an imposed standard. Just like compact discs and DTV, DAB receivers will be extremely expensive at first but should come down in price based on public acceptance. DAB may fail in the US. Many technologies, such as quad, AM Stereo, Betamax for home use, IVDS, RDS and CED video discs have never gained public acceptance. As long as DAB is marketed correctly, it will obtain limited public acceptance. However, this should not be done by disrupting the current analog FM service. Moreover, the Commission should not give special dispensation to analog broadcasters by imposing standards while letting other technologies succeed or fail on their own merits.

8. IBOC will interfere with the implementation of the Low Power Radio Service and bar entrants to the market. Unlike IBOC, the proposed Low Power Radio Service has wide public and institutional support and drew more public commentary than any NPRM in Commission history. This ground swell of diverse support clearly places locally focused, locally programmed, and locally controlled community radio as a priority. Assigning extra bandwidth for IBOC will impede the implementation of LPFM and will further encourage consolidation, which presents a barrier to most new entrants.

9. In the event that the FCC decides to adopt one of the proposed IBOC systems and assigns extra bandwidth, these stations should not be allowed to keep this extra allotted bandwidth after the full conversion to digital. ANY extra bandwidth beyond that needed for the transmission of the stations primary signal and interference adjacents should be returned to the FCC to allow for more entrants into the market.

10. Any question of the possible conflict between IBOC and LPFM should not be whether LPFM interferes with IBOC, but if IBOC interferes with LPFM. The demand for LPFM is clear, there is no proven public demand for IBOC.

11. In the event that the Commission elects to establish DAB off the normal band, we strongly suggest that 50% of such spectrum be reserved for non-commercial educational services.

12. Under no circumstances should FM analog license holders be given frequencies or allotted special status in the auction process for a dedicated DAB band. However, we do suggest that if these license holders wish to trade their FM frequencies on a 1 to 1 basis for digital frequencies that they should be allowed to do so, as long as the traded FM frequencies are totally allocated to the further creation of low power radio stations.

13. Industry experts say that by 2003 more than 600 million people will be accessing the internet from mobile devices compared to 550 million using desktop computers. This will enable current analog FM broadcasters, many of which already "webcast" their signals, to compete with DAB even if they elect to not purchase frequencies on a designated DAB Band. It is premature to move to an IBOC style conversion without taking into account this type of technology.

14. Conversion of FM analog to IBOC will further erode the "free public service" aspect of radio. Currently, the trend has been to use more and more bandwidth for ancillary services not for use for free by the general public. This is inconsistent with the traditional use and purpose of radio. This will only accelerate under any IBOC style conversion. This will allow FM license holders to unfairly compete with digital pager and other services who are held to stricter standards for obtaining frequencies.

15. IBOC is unnecessary as the bandwidth and technology to broadcast already exists and is currently in use. Ancillary services that are currently granted to FM license holders as "bonuses" to their frequencies (and are used to carry services such as paging), and are without specific authorization by the Commission, already transmit data via the Radio Data System. FM license holders are not legally entitled to the use of this bandwidth for these purposes. Since 1979 broadcasters have had the technology to send nonaudio information out to radios for emergency traffic or weather alerts, banner ads on the face of your radio, or an announcement of the song and artist. This bandwidth is already sufficient to allow for DAB without allotting extra bandwidth. The loss of any officially unauthorized ancillary services offered by incumbent broadcasters is immaterial. Businesses are often put in the position to choose between offering competing services. Let these broadcasters make these choices and pay the consequences for them.

In conclusion, we the undersigned urge the Commission to reject the two proposed IBOC systems and the overall concept of IBOC. Moreover, we further urge the Commission to commit to preserving the FM band as an analog audio service and pledge that any DAB services will be placed on other bands.

Respectfully Submitted.

Ted M. Coopman
Rogue Communication.

We, the undersigned organizations and individuals, representative of a wide spectrum of advocates for a democratic, community service oriented, free AM-FM broadcast service, strongly believe that the NPRM concerning the adoption of In Band On Channel (IBOC) terrestrial Digital Audio Broadcasting (DAB) is ill-conceived. We the undersigned, urge the Commission to reject RM 9395 and explore other proven technologies for terrestrial Digital Audio Broadcasting.

If you wish to ad your name and/or organization email me with the following information:

Legal Name
Organizations Full Name
City and State (a full address is not required)


Rogue Communication, Santa Cruz, CA
Spryex Communications, Inc., Hamilton, OH
REC Networks, Tempe, AZ
Arizona Microradio Association
Michigan Music is World Class Campaign, Detroit, MI
Grid Radio, Cleveland, OH
Excellent Radio, Grover Beach, CA
WKJCE Radio, Vowinkle, PA
Free Living Radio, Howell, MI
Citizens' Media Corps, Allston, MA
National Lawyers Guild, Committee For Democratic Communication, San Franciso, CA
Hodge Productions, San Francisco, CA
Nordonia Hills Radio, Sagamore Hills, OH
Free Range Radio, Salida CO
Salida Radio Club, Inc., Salida CO


Ted M. Coopman, Santa Cruz, CA
Bill Spry, Hamilton, OH
Keith Dueer, Hamilton, OH
Jerry Szoka, Cleveland, OH
Maryjane Stelmach Honner, Canton, MI
Richard D. Demorest, Canton, MI
Charles Goodman, Grover Beach, CA
Trish Goodman, Grover Beach, CA
John R Benjamin, Vowinkle, PA
Tom Ness, Ferndale, MI
Susan Ness, Ferndale, MI
Rick London, Nipomo, CA
Ron Gutzeit, Howell, MI
Steve Provizer, Allston, MA
Don R. Vaughan, Hattiesberg, MS
Richard K. Harrison, Winter Park, FL
Rusty Hodge, San Francisco, CA
John Anderson, Madison, WI
Kevin Coan, Sagamore Hills, OH
Lyn Gerry, Waterloo, NY
Shawn Ewald, Waterloo, NY
Christopher Maxwell, Richmond, VA
Jesse Walker, Los Angeles, CA
Debra Juchem, Salida CO
Mark Minor, Salida CO
Jeremy Peterson, Salida CO
Jane Carpenter, Salida CO
Martha Roskwski, Salida CO
John Waitman, Salida CO

Signatories Filed During the Reply Comment Period as a Supplement, Beginning January 25, 2000



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