I would like some advice on what is the most proper and effective way
to issue a complaint with the FCC regarding harmful interference being
caused by a radio station that is using the IBOC digital system.

The station in question is 710 WOR in New York City, which has been
using the IBOC digital system since October 2002. And since that
time, they have been causing harmful interference to frequencies as
far as 40 kHz away from their carrier -- across a region of at least
680 through 750 kHz.

I have observed this interference throughout northern and central New
Jersey -- at locations up to and beyond 50 miles away from WOR's
transmitter site -- on a wide variety of receivers, ranging from
highly selective car radios to hi-fi AM Stereo receivers. And
tellingly, this interference completely disappears the instant that
WOR stops transmitting their IBOC digital sidebands at sunset each
day.

Of course, I understand the fact that the IBOC system is designed to
occupy a 30 kHz total bandwidth, including 15 kHz above and below the
station's carrier. Thus, when WOR's IBOC is in use, I do not expect to
be able to receive anything but noise on 700 and 720 kHz, and I expect
my reception on 690 and 730 kHz to be severely degraded, if possible
at all. That is indeed what I am observing, but that is not my
complaint.

My complaint is about the scratchy, crackly type of "splatter"
interference that WOR is causing to be heard on 680 through 750 kHz
whenever their IBOC system is in use. This interference varies in
intensity in accordance with WOR's analog modulation -- the "louder"
their audio is, the more severe the interference is. Thus, by these
indications, this interference appears to be very similar in nature to
the wideband splatter caused by an analog AM station that is
consistently exceeding the -100% negative modulation limit, or by a
station whose directional antenna array is affecting their signal to
such a degree that a similar receiver-based effect is being produced,
especially towards the signal's "nulls".

Having mentioned this to WOR's engineers numerous times, their claim
is that according to the modulation monitor and spectrum analyzer at
their transmitter site, WOR's radiated signal (with IBOC in use) falls
within the NRSC radiated emission limits, and therefore is "legal" --
end of story. They have refused to conduct any field measurements
that might support or dispute my claims, other than "it sounds fine on
my car radio". In fact, WOR's engineers have even threatened legal
action against me, because of my claims that WOR is operating
"illegally". Needless to say, this has resulted in a breakdown in
communication between them and I. I have chosen not to discuss this
issue with WOR's engineers any longer, because nothing was being
accomplished.

But now that WOR has made headlines in national radio publications,
boasting about the success of their IBOC installation, I feel the time
has come to address these issues, and put it in the hands of the FCC
and more capable engineers to decide whether or not WOR's IBOC signal
is causing harmful interference and/or is exceeding the FCC's radiated
bandwidth specifications. In particular, WOR's Director of
Engineering brings into question the performance of their directional
antenna array and how it may be affecting their IBOC signal -- stating
in his Radio World article, "It should also be noted that the pattern
bandwidth of our null is not great. On a spectrum analyzer, WOR's
upper sideband does not exist north of Paramus, NJ".

Obviously, that kind of problem can seriously degrade an analog AM
signal, and would be particularly harmful to the quadrature-modulated
component of an AM Stereo signal. But what would the complete lack of
an upper sideband do to an AM IBOC signal, which also makes use of
quadrature modulation? That is a big question mark, because nobody
has ever addressed it before -- not the FCC nor the NRSC -- and
because WOR's engineers are apparently not concerned about it enough
to conduct any field tests with and without their IBOC signal in use.

Obviously, as one of the very few AM stations in the world using the
IBOC system, WOR is essentially "flying by the seat of their pants" --
and in that regard, I can cut them some slack as they continue to
experiment with it. But to consistently ignore and dismiss these
interference issues is a serious problem -- especially during these
short winter days, when skywave propagation during the early morning
and late afternoon "critical hours" can cause WOR's IBOC signal to
interfere with distant stations, including several in Canada, such as
690 CINF and 730 CKAC in Montreal and 740 CHWO in Toronto. In fact, I
distinctly remember tuning in 740 kHz on my car radio a full hour
before local sunset and hearing CHWO's signal coming in with heavy
interference from WOR's IBOC "splatter". That was observed in
Princeton, NJ, nearly 50 miles away from WOR's transmitter site.

So, to sum up this long-winded message up, since my attempts to
address these issues directly with WOR have failed, how should I go
about bringing it to the FCC's attention? Hopefully they can take
some time our from their crusade against non-existent
third-adjacent-channel interference from LPFM stations to address a
much more significant interference issue on the AM band....

The antenna pattern can cause the audio to sound distorted (because the
carrier is lower than the sideband you're hearing) but it won't move
any energy out of band or in particular cause splatter.
--
Ron Hardin


On the internet, nobody knows you're a jerk.

(WBRW) writes:

I would like some advice on what is the most proper and effective way
to issue a complaint with the FCC regarding harmful interference being
caused by a radio station that is using the IBOC digital system.

The station in question is 710 WOR in New York City, which has been
using the IBOC digital system since October 2002. And since that
time, they have been causing harmful interference to frequencies as
far as 40 kHz away from their carrier -- across a region of at least
680 through 750 kHz.

You can be sure WOR's operation is entirely in accord with the FCC's
rules. By now the local FCC field office will have checked them out
six ways to Sunday.

The problem is not WOR. The problem is that digital modulation
schemes tend to require more bandwidth than analog schemes. As a
result, neither the AM nor the FM form of "HD Radio" is truly
in-band, on-channel; in-band, adjacent-channel is a more accurate
description.

The January 2 issue of _Radio World_ contains an article describing
a Chicago FM station's experiences with "HD Radio", and notes that
several stations in adjacent markets, having complained to the
FCC about interference from this station's "HD Radio" signal, have
been told they have to put up with it. The official line seems to
be that stations are only licensed to provide coverage out to their
protected contours, and anything they cover beyond that is subject
to whatever interference may arise in the future, whether from
"HD Radio", LPFM, local computer networks, or whatever.

I believe this position is poor policy because a lot of smaller
stations are dependent on coverage beyond the protected contour
for their economic survival. These are, for the most part,
stations that were "dropped in" over the past twenty years as
"rimshots" to various markets, licensed to suburbs or rural
communities that can't realistically support them. Deprived of
access to adjacent markets, many of them are likely to become
unsustainable, I think.

If the FCC wants to pretend stations serve no listeners beyond
their protected contours, then it should not be authorizing
stations that can't prosper within those contours. Moreover, it
ought to recognize that just as broadcast spectrum is a limited
resource, so are advertising dollars in any community, and it is
not necessarily the case that more stations on the air mean better
service. But I digress.

The bottom line is I believe IBOC is a mistake, and many stations
and their listeners will suffer because of it.


umar
--
URL:http://hippogryph.com/green
Send 'em back to Texas: T minus 293 days, 22 hours, 40 minutes.

In article , WBRW wrote:

Having mentioned this to WOR's engineers numerous times, their claim
is that according to the modulation monitor and spectrum analyzer at
their transmitter site, WOR's radiated signal (with IBOC in use) falls
within the NRSC radiated emission limits, and therefore is "legal" --
end of story. They have refused to conduct any field measurements
that might support or dispute my claims, other than "it sounds fine on
my car radio". In fact, WOR's engineers have even threatened legal
action against me, because of my claims that WOR is operating
"illegally". Needless to say, this has resulted in a breakdown in
communication between them and I. I have chosen not to discuss this
issue with WOR's engineers any longer, because nothing was being
accomplished.

Sadly, they are probably right. Write a letter to your local FCC
field bureau and let them know what you've heard and what you've been
through.

My bet is that the FCC will send someone out with a spectrum analyzer to
look at the spectral envelope, and it'll be totally legal. It is pretty
depressing to see what is legal.

The FCC pretty much only responds to letters, but they do actually respond
to letters.
--scott


--
"C'est un Nagra. C'est suisse, et tres, tres precis."

"umarc" wrote in message
...

The problem is not WOR. The problem is that digital modulation
schemes tend to require more bandwidth than analog schemes. As a
result, neither the AM nor the FM form of "HD Radio" is truly
in-band, on-channel; in-band, adjacent-channel is a more accurate
description.

The "IBOC" surely falls within the emission mask that has existed for a long
time. Problem is that before IBOC, what fell toward the edges of the mask
was the ocassional zing or sput. Now IBOC fills it chock full on a
full-time basis. We have the mask used to condon a type of emission for
which it was NOT designed.

The January 2 issue of _Radio World_ contains an article describing
a Chicago FM station's experiences with "HD Radio", and notes that
several stations in adjacent markets, having complained to the
FCC about interference from this station's "HD Radio" signal, have
been told they have to put up with it. The official line seems to
be that stations are only licensed to provide coverage out to their
protected contours, and anything they cover beyond that is subject
to whatever interference may arise in the future, whether from
"HD Radio", LPFM, local computer networks, or whatever.

The flood of FM translator applications will be judged on the same basis,
further limiting the real coverage of FM stations.

I believe this position is poor policy because a lot of smaller
stations are dependent on coverage beyond the protected contour
for their economic survival. These are, for the most part,
stations that were "dropped in" over the past twenty years as
"rimshots" to various markets, licensed to suburbs or rural
communities that can't realistically support them. Deprived of
access to adjacent markets, many of them are likely to become
unsustainable, I think.

I don't have sympathy for the rim-shots which never had any intention of
serving the town they used to justify "first local service" in order to get
their license.

If the FCC wants to pretend stations serve no listeners beyond
their protected contours, then it should not be authorizing
stations that can't prosper within those contours.

The FCC hasn't required applicants to even file fake income projections for
a number of decades. Their policy is to allow as many stations as the
technical rules permit, and they've watered down the tech rules over the
years in order to allow more stations. Every Congressperson has had a
friend who wanted a radio station.

Moreover, it
ought to recognize that just as broadcast spectrum is a limited
resource, so are advertising dollars in any community, and it is
not necessarily the case that more stations on the air mean better
service.

Ever hear of "Let the marketplace decide". Those phone calls from Capitol
Hill would keep the FCC busy full time if they tried to use the kind of
judgement you recommend.

The bottom line is I believe IBOC is a mistake, and many stations
and their listeners will suffer because of it.

I certainly agree with you. And the flood of more FM translators will
further degrade the service of existing stations.

Sigh!

Subscribe to satellite radio or FM.

"R J Carpenter" wrote in message
...
..

The FCC hasn't required applicants to even file fake income projections
for
a number of decades. Their policy is to allow as many stations as the
technical rules permit, and they've watered down the tech rules over the
years in order to allow more stations. Every Congressperson has had a
friend who wanted a radio station.

In any case, the income projections were intended to show that an applicant
coulda fford to build and operate the station, not the overall ability of a
market to support additional signals. It was called "Financial
qualifications" and had nothing to do with competition.

On 13 Jan 2004 19:58:35 GMT, "R J Carpenter"
wrote:

I don't have sympathy for the rim-shots which never had any intention of
serving the town they used to justify "first local service" in order to get
their license.

I have less concern for the "rimshots" than I do for the 50KW
blowtorches that actually derive ratings from beyond their protected
contours.

KGO has been #1 in San Francisco since dirt was invented. What I'm
watching is what effect wiping out such stations' profitable fringes
will have on their numbers. WOR actually gets some numbers in
Philadelphia. What happens if another IBOC station wipes out WOR in
Philly? Will it be enough to drop their overall share from 1.8 to 1.6?
It'll take a number of years before we'll know how many stations will
be wiped out, and where.

It strikes me that IBOC is mutually assured destruction.

Rich

I'm in L.A. County and KGO comes in much better than the local ABC O&O
POS dink station.

On 14 Jan 2004 16:07:33 GMT, Rich Wood wrote:

On 13 Jan 2004 19:58:35 GMT, "R J Carpenter"
wrote:

I don't have sympathy for the rim-shots which never had any intention of
serving the town they used to justify "first local service" in order to get
their license.

I have less concern for the "rimshots" than I do for the 50KW
blowtorches that actually derive ratings from beyond their protected
contours.

KGO has been #1 in San Francisco since dirt was invented. What I'm
watching is what effect wiping out such stations' profitable fringes
will have on their numbers. WOR actually gets some numbers in
Philadelphia. What happens if another IBOC station wipes out WOR in
Philly? Will it be enough to drop their overall share from 1.8 to 1.6?
It'll take a number of years before we'll know how many stations will
be wiped out, and where.

It strikes me that IBOC is mutually assured destruction.

Rich

Rich Wood writes:

It strikes me that IBOC is mutually assured destruction.

May I quote you on that?


umar
--
URL:http://hippogryph.com/green
Send 'em back to Texas: T minus 292 days, 17 hours, 21 minutes.