Federal Communications Commission	"FCC  XX-XXX"


STATEMENT OF
COMMISSIONER MICHAEL O’RIELLY

Re:	Revitalization of the AM Radio Service, MB Docket No. 13-249

In this Second Further Notice of Proposed Rule Making, the Commission is considering further reducing the contour by which Class A stations are protected at night, in order to represent a more realistic view of where a listenable signal is, and, therefore, actual listeners.  At the same time, the Commission also has proposed to enhance Class A stations’ co-channel interference protections, thereby reducing the potential impact on Class A stations’ nighttime service.

The Commission bases its new proposal on engineering data in the record indicating that protection of the 0.1 mV/m Groundwave contour cannot be heard under current noise conditions.  Therefore, it is contended, that it is only necessary to protect Class A AM stations to their 0.5 mV/m Groundwave contour.  If true, I would be more sympathetic to this change as it wouldn’t alter the realistic reach or expectations of those holding existing licenses.  I appreciate the Chairman accommodating my request to clarify that, at this time, this is not a universally held viewpoint.  I hope the record will reflect a consensus by engineers on how far a listenable signal extends.  I will be hesitant to support a final order on this proposal without such consensus.  However, at this stage, I support moving forward and developing a record on this, and other, important questions presented in the SFNPRM.       
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