FCC Commissioner Ajit Pai and his Chief of Staff, Matthew Berry met with a pair of Clear Channel executives last week to discuss proposals pertaining to the future of the AM band. Jeff Littlejohn, EVP/Engineering & Systems Integration and Jessica Marventano SVP/Government Affairs discussed multiple proposals, with a focus on four initiatives.

The Ratchet Rule

Clear Channel is supporting the engineering community’s initiative to eliminate the “Rachet Rule”. The 1991 ruling required AM stations making voluntary changes to reduce their interference to other stations if they contributed interference above the 50% RSS levels to another station. Clear Channel’s positions was that the rule had done little to improve interference issues in the AM band, while serving as an impediment to improvements or necessary relocations of AM stations.

Relaxing AM Community of License Coverage Requirements

Clear Channel stated its support for the relaxation of the community of license coverage requirements to 80% of the community by the 5 mV/m daytime contour and 50% of the community by the nighttime interference free contour while retaining nighttime coverage requirements.

FM Translator Window/STAs for AM Stations

Noting that “FM translators rebroadcasting AM stations increase listenership to the rebroadcast AM station, and have served to encourage listeners usually accustomed to the FM band, including young adults and females, to tune directly to the AM band,” Clear Channel is endorsing additional opportunities for AM’s to gain FM translators via an AM licensee-only filing window prior to the LPFM window and via a special temporary authority process, as AM stations transition to all digital broadcasts and/or other spectrum.

Revise Location Limits for FM Translators Rebroadcasting AM Stations

On a related note, Clear Channel would like the current restrictions on the area to locate the transmitter for an FM translator rebroadcasting an AM signal be reformed to either eliminate the 25 mile radius requirement altogether or to change the location requirement to sites either within the AM station’s 2 mV/m contour or 25 miles from the AM transmitting site.

Clear Channel also came out against recent proposals to convert the AM band to all digital by a certain date or to increase power for all stations instead proposing the use of translators until the FM band could potentially be expanded into the spectrum used by TV Channel’s 5 and 6.

In response to a question from Commissioner Pai, Mr. Littlejohn stated that it would be challenging for the Commission to set a date certain to convert AM stations to all digital broadcasts, given the investments necessary for such a transition by broadcasters, and on the reception side, the large percentage of analog radios in the market. Mr. Littlejohn answered Commissioner Pai’s question regarding the feasibility of across-the-board power increases for AM stations, by noting Clear Channel’s opposition, explaining that when the Commission implemented such a power increase for Class IV stations in the past, it resulted in a sea of interference surrounding islands of service. In response to Mr. Berry’s inquiry regarding the proposal of replacing the AM minimum efficiency standard with a minimum radiation standard, Mr. Littlejohn noted that any such change would need to be carefully designed to prevent additional signal from entering into the skywave, which would create more interference. In response to a query as to anti-skywave antennas, Mr. Littlejohn stated that international testing to date had not proven their effectiveness. Mr. Littlejohn responded to an inquiry regarding potential alterations in the timing of AM daily power reductions, noting that such requirements are based in physics and should not be altered without considering the impact on interference. Mr. Littlejohn noted that other spectrum, such as the Channel 5 and 6 bands, could be an eventual location for AM, LPFM and educational stations, with an engineering solution for incumbent TV stations in those bands. In the interim, FM translators would serve as a bridge until the transition to new spectrum and/or the transition to all digital AM broadcasts.