On Friday 28 September 2007 07:45, Gil Stacy wrote:
> Kevin,
> If writing letters, "public comment",  would have made a difference, the
> FCC wouldn't have approved BPL just a few years ago.  Radio amateurs and
> the ARRL mounted an intensive campaign against BPL and urged FCC rejection.
> Comment after comment was sent by snail and email to the FCC against it.
> The ARRL conducted testing and monitoring which refuted
> BPL's non-interference claim.  European and Japanese experience with BPL
> should have been enough to prevent the implementation.  Government agencies
> dependent upon emergency HF communication voiced concern regarding FCC
> approval of BPL. It didn't make "jack spit" difference.  If all IRCA and
> NRC had written letters it would  have been a fraction of the letter
> writing done to the FCC on the BPL issue.  The FCC invitation to comment on
> an issue is like the old western criminal trial when the judge announced to
> the spectators that the defendant would receive a fair trail before he was
> hanged.
>
> Complaints from all angles now won't hurt and may even be more effective
> now than before, especially if commercial interests, affected stations,
> have suffered.

Well said, Gil.

A bit of history to put this all in context:

Back in the early 90's when interest in digital radio was stirring, the NAB 
looked at the possible technological approaches, and decided that the way to 
go was to get some new spectrum and use the Eureka-147 system then being 
developed in Europe.  They championed this approach for a time, but then some 
heavyweight FM owners came along and laid down the law to the NAB honchos: 
this approach was a non-starter.  There was no way that they would support a 
digital radio technology that might level the playing field in terms of 
coverage, and which might allow new entrants onto the field.  The only 
approach that was acceptable to them was an "IBOC" scheme, and the NAB was 
forced to drop the new spectrum idea like a hot potato.  There followed many 
years of development and tests, various players falling by the wayside, 
etc... eventually culminating in the formation of iBiquity.

There was a problem, however.  The NAB couldn't sell this approach to its 
membership unless it worked on AM as well as FM.  The IBOC approach looked 
feasible for FM, although it involved some serious compromises.  If it was 
adopted, then the days of having analog coverage well beyond protected 
contours would pretty much be history.  Applying IBOC to the AM band, 
however, looked much more iffy.  Even in the early days, it was obvious to 
unbiased observers that it couldn't be done without causing major problems, 
including lots of interference inside protected contours.  Moreover, 
performance of the digital system would take a huge hit at night.  
Nevertheless, without AM IBOC, there would be no IBOC at all, so they 
soldiered on and developed both systems.

Now we come to the evaluation of the prototype iBiquity IBOC systems by the 
NRSC.  The NRSC committee that did the evaluation was composed largely of NAB 
staffers, broadcasters who were NAB members (and some who were iBiquity 
investors), and broadcast equipment vendors, who were entranced by the 
thoughts of the new markets that IBOC could open up.  It's sort of like 
having a beauty contest in which there is only contestant, and the judges are 
the parents of that contestant.  Now they had to deal with that problem 
child, AM IBOC.  For the most part, they danced around the potential problems 
with some fancy verbal footwork, and in some cases, they just ignored them.
One thing that was clear, though: if nighttime AM IBOC operation was allowed 
right off the bat, the worst problems would be exposed for all to see.  That 
in turn would reflect badly on IBOC in general, and could stall the rollout, 
possibly even kill it completely.  The important thing in the early days was 
to keep the AM owners from knowing the truth about the AM IBOC system, so the 
NRSC recommended that it not be used at night, pending further studies.  
Interim IBOC operation was allowed starting in 2002, but it was 5 more years 
before AM night operation was allowed, giving the FM system lots of time to 
become entrenched.  In those 5 years, there was exactly one documented AM 
IBOC night test conducted, lasting a couple of nights and involving only two 
stations.  Yeah, they really studied it to death.

Then we have the FCC... they really lost interest in digital radio once it 
became clear that there would be no new spectrum involved.  They were quite 
content to let the industry (i.e., the NAB lobby) do what it wanted, and they 
turned a deaf ear to the voices of dissent.  If they really had the public 
interest at heart, they would have ordered an independent evaluation of the 
IBOC system, but the days of the FCC protecting the interests of the public 
are long gone.

Fast forward to today.  FM IBOC is indeed well entrenched, though the general 
public is massively indifferent.  AM IBOC, however, now has its ugly 
underbelly exposed, and it's on the cusp.  Now is the time to smack it good.  
Some small broadcasters are organizing to fight it, and they can use all the 
help they can get.  I strongly suspect that many insiders knew it would 
unfold like this all along - FM IBOC was the big prize, and now that's it 
rolling along, they can cut AM IBOC loose.  They don't have to string the AM 
guys along any more.

So, keep those complaints flowing, folks!

Barry

-- 
Barry McLarnon  VE3JF  Ottawa, ON
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