November 1999 Newsletter

News from the Offices of

Munn-Reese, Inc.

Broadcast Engineering Consultants

100 Airport Drive – PO Box 220

Coldwater, MI 49036-0220

Wayne S. Reese, President

Telephone: 517-278-7339

Internet: www.munn-reese.com

Fax: 517-278-6973

November 1999

Munn-Reese Matters

The last time we sent you a newsletter we promised we would try to send another before the end of September. Well, so much for good intentions! Actually, you’ll never believe what happened to our wacky newsletter editor, Thumbs Feebleman—he was politically kidnapped! Several of his neighbors and supposed friends twisted his arm to run for Town Council in the little "one-horse" town where he lives. His kids were embarrassed to appear in public because Dad had become a politician. However, when his eldest found out Thumbs was running as an Independent candidate, he wanted to know if he could get a picture of Dad with Jesse Ventura!

Fortunately for Thumbs—and maybe his "friends," too—the voters chose someone else. Now he’s been running around the office quoting the late Dr. Martin Luther King, Jr., "Free at last! Free at last! Thank God Almighty, I’m free at last!" Alas, his freedom had only a short life. Now the boss has nailed his office door shut until he finishes another newsletter. Given his "caloric dependencies," we don’t expect it to take long!

Commission Matters

One of the most important developments at the FCC since the last newsletter has been the long awaited Notice of Proposed Rulemaking (NPRM) on Digital Audio Broadcasting (DAB) by terrestrial means, MM Docket No. 99-325. Among other things, DAB is expected to provide enhanced sound quality while improving the immunity of the signal to interference and other impairments. Two different DAB models are under consideration.

The first DAB model uses In-Band On Channel (IBOC) technology. Such systems are under development by three different companies and would allow stations to simultaneously transmit digital and analog program material. Once the transition to digital broadcasting was complete, the analog portion of the signal could be dropped. According to proponents of the IBOC technologies, digital FM signals would be of "near CD-quality" and digital AM signals would provide "FM quality."

An alternate model would place DAB signals in a separate portion of the spectrum. The Commission has specifically requested comments on a proposal to reallocate the present TV Channel 6 (82-88 MHz) for this purpose. This would eliminate the need to make the digital transmissions compatible with existing analog signals. However, it would also delay implementation of the plan until at least 2006 or the end of the transition to digital television (DTV)—whichever is later.

One of the concerns regarding an IBOC system has been compatibility between any IBOC system that might be adopted and the Commission’s Low Power FM (LPFM) proposals. In early September, General Media asked the FCC to act on its request, made earlier with a group of supporters, to extend the date for reply comments in the LPFM proceeding to 45 days after the release of a DAB NPRM. The request was opposed by the United Church of Christ and others. In mid September, the Commission ruled that it would extend the deadline to 14 days after the release of the NPRM and that it would not extend the deadline again. Shortly after the extension was granted, a Motion for Reconsideration was filed, but that motion was denied, and the extension was allowed to stand.

A second NPRM has been issued. This one will be of particular interest to LPTV broadcasters because it asks whether and/or how to give certain LPTV stations "Primary" status as Class A television facilities. The proceeding, MM Docket No. 99-292, asks for comments on a vast number of issues—mostly relating to how much the new class of stations should resemble full-services facilities and how much they should resemble secondary services. The proceeding can be downloaded from the Commission web site: www.fcc.gov/Bureaus/ Mass_Media/Notices/1999/fcc99257.txt. The document can also be obtained in a WordPerfect or Acrobat format by using either .wp or .pdf in place of the .txt file extension. Comments in the proceeding will be due December 21, and reply comments will be due January 20, 2000.

The Commission is finally implementing the long promised online call sign system. On October 22, the FCC stopped accepting manually filed requests for new call signs and changes in existing call signs. Our office has no call signs to try changing, so we can’t address the question of how that part of the new system is working. However, we can tell you that it will allow users to check whether or not a given call sign is in use. The system can be accessed from a link on the Mass Media Bureau page: www.fcc.gov/mmb. According to the FCC, the new system will offer the option of printing out a "ready for filing" fee form or the alternate option of paying the fee using Master Card or Visa credit cards.

The Commission has announced a new Consolidated Database System (CDBS). The system will provide information about existing broadcast stations, status of various applications, and electronic representations of various authorizations, such as construction permits and licenses. The information will be available on 20 computer terminals located at the Portals. The FCC copy contractor will also provide debit cards that will allow users to print various screens from the CDBS. Unfortunately, the new CDBS replaces the existing Broadcast Application Processing System (BAPS), which has been available on the Commission’s Web Site for the past several months. Although the information is still technically available to the public, it will not be nearly as accessible as the Internet based BAPS pages.

The Commission has announced some bureaucratic shuffles. When the dust settles two new bureaus will be established—the Enforcement Bureau and the Consumer Information Bureau. The new Enforcement Bureau is expected to consolidate enforcement functions and personnel from the Common Carrier, Mass Media, Wireless Telecommunication, and Compliance and Information Bureaus. The new bureau will also include the Regional and Field Offices of the FCC. The new Consumer Information Bureau will consolidate the Gettysburg Call Center, the Office of Public Affairs, and Reference Operations Divisions. The Commission will retain a small stand-alone Office of Media Relations that will be responsible for working with the news media and overseeing the agency web site.

During the time since the last newsletter, the FCC completed the first auction of broadcast licenses. After 35 rounds of bidding, 91 winners were announced for FM Broadcast, FM Translator, TV Broadcast, and LPTV construction permits. The auction raised net high bids that totaled $57,820,350. The winners were given 10 days in which to file the down payments on their winnings and 30 days in which to file any amendments to their pending long form applications.

The FCC Office of Engineering and Technology (OET) has issued a report on transmission standards for DTV. The study was initiated in response to tests performed by Sinclair Broadcasting Group. The Sinclair tests made direct A/B comparisons between receivers for the FCC approved 8-VSB system and the alternate Coded Orthogonal Frequency Division Multiplex (COFDM) system. The Sinclair tests were performed at two different locations in the Baltimore area and indicated that COFDM receivers were able to outperform 8-VSB receivers when using simple indoor antennas. Analog TV reception at these sites was described as either very poor or not acceptable due to the presence of strong static multipath. The OET tests concluded that both systems have certain advantages and disadvantages. After holding discussions with a number of industry representatives, OET concluded that, with the exception of Sinclair, there was continuing support for the 8-VSB system. OET said the Sinclair study provided useful insight into certain indoor reception problems. It also concluded that many of the 8-VSB problems identified by Sinclair would be solved with subsequent generations of adaptive equalizers.

Commissioner Matters

Recently, FCC Chairman William E. Kennard responded to the creation of a major investment fund by broadcast leaders to boost media ownership by women and minorities. "All too often women and minorities run into a glass ceiling when it comes to ownership and management opportunities in the broadcast industry. Last year, I challenged the broadcast industry to shatter these barriers and to make equal opportunity a reality in their businesses. Today, the industry is taking a first critical step to meet that challenge." "The Prism Fund will give women and minorities access to badly needed capital. At a time of rising prices for radio and TV stations, the fund will help women and minorities purchase and run their own radio and television stations, giving them the opportunity to participate more fully in one of our nation’s most important communications mediums. I applaud the broadcasters for their vision—and for helping make the communications industry accessible to all Americans."

Miscellaneous Matters

The Office of Management and Budget has approved the new FCC Form 317. The form is for those DTV stations that choose to sell their excess digital capacity to ancillary or supplemental services. The form must be filed, along with FCC Fee Form 159 (July 1997 edition), by December 1. The Mass Media Bureau has sent the forms to each commercial DTV station subject to the new annual reporting and fee payment requirements. Our guess is the workload for 1999 won’t prevent any FCC staff members from celebrating the Holidays!

We often tell you about "pirate" radio broadcasters, but this story has a new twist. Last spring, questions were raised with the FCC about licensing localized television broadcasting of automobile drag races from a race track at Ennis, TX to its parking lot. On a race weekend Friday, the FCC issued a one time authorization for the telecasts—presumably the 100,000 fans were pleased. The operator told FCC officials he had been unaware of the need for any kind of license, and promised to obtain one before the next telecasts. The story has a happy ending—a license for the racetrack telecasts was issued in August.

While the race track was trying to clear up its telecasts, apparently others have been trying to find ways to jam cellular telephones. In October, the FCC issued a Public Notice acknowledging a number of inquiries about the use of transmitters "designed to prevent or jam the operation of cellular telephones in hospitals, theaters and other locations." The Public Notice pointed out that Section 333 of the Communications Act prohibits willful or malicious interference with radio communications of any licensed or authorized station. The Commission also said that the "manufacture, importation, sale or offer for sale, including advertising, of such transmitters is a violation of 47 USC 302(b). … Fines for a first offense can range as high as $11,000 for each violation or imprisonment for up to one year. The equipment can also be seized and forfeited to the U.S. Government."

The FCC doesn’t always have to play the "bad guy" role. This fall US Forest Service firefighters were experiencing severe interference on seven of their frequencies while trying to fight large wildfires in southern California. The interference was believed to be coming from Mexico. The Forest Service contacted the FCC, and the FCC asked their counterpart in Mexico for help. Less than 48 hours later, the interference had diminished to the point that one of the Forest Service pilots was heard to ask, "Where did they go?" As a result of this spirit of cooperation, the fire was contained sooner than expected; no lives were lost; and additional forestland and property were saved. The Forest Service thanked the FCC and the Mexican administration for their respective roles in reducing the interference.

Acting on a petition from Media Access and People for the American Way, the FCC has reversed an October 3, 1994 Declaratory Ruling. The Commission is now saying that broadcasters will have to make non-standard time slots available to candidates for federal offices (President and Congress) during a one year period before an election. Under the old ruling broadcasters could limit candidates to 30 or 60 second spots—or sell them a half-hour or greater time block. Under the new ruling, federal candidates will apparently have the right to purchase 5 minutes or 3 ½ minutes or 7 minutes or whatever. Commenting on the change, Chairman Kennard said, "I think voters will benefit from political messages that are longer than a one minute- or 30- second spot. Candidates will use this new flexibility to better inform voters and get a more complete message out." Our wacky editor Thumbs Feebleman just cannot resist the temptation to remind you that the Chairman was appointed by people who would like to bring you political messages that are longer than the messages from your local car dealer or pizzeria!

A government double-speak award goes to the FCC News Release that was titled, "Inter-American Mutual Recognition Arrangement for Conformity Assessment of Telecommunications Equipment Completed." Frankly, Thumbs doesn’t have a clue what that means, but he doesn’t think it concerns broadcasting!

And speaking of government humor, anyone who has encountered problems trying to register a tower may enjoy this story. Recently a representative from a nearby airport stopped by and asked our president Wayne Reese for some assistance. Apparently, when the airport tried to renew the FCC license for their Unicom frequency, they were told their tower was a potential air hazard and would require antenna structure registration! Further investigation revealed the tower had been assigned coordinates that placed it in the middle of a runway (Oops!). We are happy to report the coordinates have been corrected, and the structure is now registered.

Upcoming Matters

The list of FM Allocations for which future windows are expected continues to be posted on our web site (www.munn-reese.com). We are considering putting together some simple studies for many of the channels. These studies would be available on a non-exclusive basis at a reasonable price. The goal is to help potential applicants evaluate which allocations might be beneficial to them. Please let us know if you would be interested in this service or if you have some ideas on what information would be most useful to you in making such an evaluation.

The month of November marks the beginning of the Holiday Season. Of course, this month we will celebrate Thanksgiving Day. We do want to take this opportunity to express our sincere appreciation for you and for your business. We recognize that this time of year can get very hectic and busy. However, we hope you will join with us in taking time to be thankful—not only for the many blessings we each receive, but also for the people who make life worth living. May you have a team of coworkers who bring out the best in one another, and may you be surrounded by friends and family this Thanksgiving.

*E-Mail Addresses*
Wayne Reese, President	wayne@munn-reese.com
Virgil Royer, Staff Engineer	virgil@munn-reese.com
Don Baad, Staff Engineer	don@munn-reese.com
Ed Trombley, Field Service Engineer	et@munn-reese.com
Justin Asher, Staff Engineer	justin@munn-reese.com
Thumbs Feebleman, Newsletter Editor	thumbs@munn-reese.com