2 FCC Red Vol.5 Federal Communications Commission Record FCC 87-27 Before the Federal Communications Commission Washington D.C. 20554 MM Docket No. 87-6 In the Matter of Amendment of Part 7 to Authorize the use of Multiple. Synchronous Transmitters by AM Broadcast Stations NOTICE OF INQUIRY Adopted January 15, 1987; ReIeased March 3, 1987 By the Commission: I. INTRODUCTION 1. This action initiates a J'otice of Inquiry (Inquiry ) into the use of multiple. synchronous transmitters to enhance and extend the signal coverage of AM broadcast stations. In April 1986. the Commission released the Mass Media Bureau's Report on the Status of i/ic AM Broadcast Rules. RM-5532. (Report ).' The Report discussed. among other things. the use of multiple transmitters. Of the various uses of multiple transmitters discussed, the application of "synchronous transmitters" has prompted the most inter- est as a means of providing immediate benefits. Thus, this proceeding will initially focus only on issues primarily related to the use of synchronous transmitters. Synchro- nous transmitter systems involve the use of two 01. more broadcasting transmitters on the same frequency in neal geographical proximity. broadcasting the same program material. They employ precision carrier frequency and phase control in order to minimize mutual interference. Other uses ot multiple transmitters will he considered in other rule making actions where appropriate. 2. Although there has been much interest expressed regarding the use of synchronous networks, the Commis- sion has concluded that ii is necessary to develop a more complete record on the several related technical and non-technical issues before proposing specific rules. In addition to this Inquiry, the Commission has encouraged applications for experimental authorizations to develop technical data.2 Additionally, the Federal Communica- tions Commission Radio Advisory Committee is encour- aged to study these issues and to report its recommendations to the Commission. II. BACKGROUND 3. Conventional methods for enhancing and extending the service area of an AM broadcast station typically called for increasing the transmitter power, designing a directional antenna system to improve service in a desired direction, relocating the station, or any combination of these. However, the crowded conditions that now exist in the AM band limit the opportunities for such changes without creating objectionable interference. MQreovel. these conventional methods do not always provide sta- tions with sufficient economic flexibility to improve their service to all areas. The use of additional transmitters that simultaneously broadcast the programs of a primary origi- nating station is an effective and economical method that could be applied in some circumstances to improve and extend a station's service area. 4. The technology relating to synchronized transmitters was discussed early in the United States in a paper written by Charles B. Aiken of Bell Telephone Laboratories in i933, In 1937. the first experimental authorization to explore this technology in the U.S. was granted to radio station WLLH. Lawrence. Massachusetts. which has con- tinued its synchronous operations to this day. Similar experiments have been conducted in Boston (WBZ). Charlotte. North Carolina (WBT). Cincinnati. Ohio (WSAI). and in Washington. D.C. (WINX and WWDC). Synchronized groups of transmitters have been used in the AM band on a large scale in Europe for many years. and more recently in Japan. These foreign operations have been based upon the same theoretical bases as the earlier Uniied States operations.4 The results of the inter- national experience have been largely consiStent with those obtained in the United States. These operations have further demonstrated the feasibility of synchronous oper- ations and have confirmed earlier predictions of perfor- mance to be expected from different system designs. 5. There are numerous examples where such applications could be made. For instance, additional transmitters simultaneously broadcasting thc programs of a primary station could he located in or near the areas where service improvements are desired. Such service enhancements could be instituted along major highways in order to permit a station to serve the traveling public over long distances forming 'ribbons of service." Addi- tional transmitters also could he located in nearby com- munities lacking sufficient population to support their own independent stations. Other uses could include use of low power transmitters within a stations predicted service area at locations suffering from inferior service because of anomalous propagation conditions or to pro- vide service in nulls of directional antenna patterns. 6. Although three distinct uses of multiple transmitters were discussed in the Report, synchronous operation stim- ulated the greatest interest, as revealed in the comments that were filed in response to the Report. The comments gave general support to the suggested use of multiple transmitters for improvement or extension of AM service areas. The commenters were encouraged by the prospect for coverage enhancement that synchronous techniques may offer. Other commenters to the Report recognized the need for careful study and the value of experimenta- tion. CBS Inc. and Association for Broadcast Engineering Standards Inc (ABES). however, expressed concern that such uses might increase the overall level of interference in the AM frequency band. Although ABES agreed with the Report's suggested methods of minimizing mutual interference within synchronous transmitter networks, it added that synchronous operations would offer only mar- ginal improvement in the coverage of some stations. I 2O FCC 87-27 Federal Communications Commission Record 2 FCC Rcd VoL 5 . . .... . ... ... III. DISCUSSION 7. There are both technical and non-technical issues on which data and information are needed in order to estab- lish bases for specific rule proposals for the operation of synchronous transmitters. Of particular importance are issues pertaining to criteria used to define mutual inter- ference between transmitters in a synchronized network. Of equal importance are the interference protection cri- teria to be applied between synchronous networks and stations outside of the synchronous systems. 8. With respect to non-technical issues, the Commission is of the view that restrictions on the use of synchronous transmitters should be minimized to the extent possible. in order to maximize opportunities for innovation and service improvements to the public. Non-technical mat- ters of importance include Ownership and licensing issues. These are discussed in detail below. Technical issues 9. Previous experiences, both in the United States and abroad, have demonstrated that there are areas of concern in synchronous transmitter operation. While advance- ments in fixed point-to-point communication techniques made since the earlier experiments will solve some of the earlier program distribution problems. e. g.. radio or land line signal propagation delay. a principal consideration of synchronous operation is that of the zones of mutual- interference. This interference occurs most prominently in the service areas of the synchronized transmitters at locations where the signal levels from two or more syn- chronized transmitters are nearly equal. AM radio receiv- ers located in these interference zones may experience program signal fading or distortion, depending on the method of transmitter synchronization employed. The boundaries of these zones or areas of interference as well as the nature of that interference are dependent upon the system design of a group of synchronous transmitters. 10. The interference can he controlled through geo- graphically spacing the synchronous transmitters or by locating them in such a way as to cause the areas of mutual interference to occur at locations where there are few listeners. The effects of mutual interference can he further minimized through the equalization of modula- tion delay among transmitters.5 and through the use of phase rather than frequency synchronization. At nighL however, these zones of interference may be less signifi- cant. because skywave interference received from trans- Initters within the group or from co-channel stations outside the synchronized group could have a gleater effect uponservice. . ' ' Intra - system interference considerations 11. Synclzroni2aiion Techniques. Synchronization can be achieved through either frequency synchronization or phase synchronization. The former is accomplished by closely aligning the carrier frequencies (to 0.1 Hz or better), and the latter is accomplished by phase locking the transmitters together through the use of a control circuit. The earlier experimental operations. previously referred to, tested both forms of synchronization. The experiments for phase synchronization employed trans- mitters called "boosters" or "synchronous amplifiers. Where synchronization is only required during nighttime hours, it may be feasible during the daytime hours for each transmitter to broadcast separate programming. de- pending on the transmitters' proximity to each other. 12. When phase synchronization is employed, there is no relative carrier frequency variation between the dif- ferent transmitters, and the pattern of mutual-interference remains fixed in time and place. Such interference would not be very noticable on automobile receivers since auto- mobiles in motion would normally move quickly through any areas of interference. For AM radios with ferrite rod antennas (virtually all modern table models and portable radios), the effect of the stable pattern of interference can be greatly reduced by orienting the radio to improve the signal strength received from one of the transmitters. 13. A difference among the carrier frequencies of the transmitters in the group results in a variation in the total received signal at any point in the common service area over time. If the frequency difference is small enough (On the order of 0.1 Hz). the variation can be compensated for by the automatic gain control (AGC) circuitry of the receiver and the listener will not notice significant distoi- tion. except at locations where the signals from the dif- ferent transmitters are nearly the same field strength. At these latter points, the variation may exceed the dynamic range of the AGC and distortion effects similar to slow fading will be experienced. 14. The relative merits of these methods need to he studied, Is there a significant advantage of one technique over the other or should the Commission establish rules for both? Where possible. those stations operating under experimental authorizations with synchronous transmit- ters are encouraged to develop data on this issue. 15. Projection rajios for synchronized !ransniiuers. The term protection ratio" generally refers to the minimum ratio of the field strength of a desired signal to the field strength of an interfering signal. in order to define the existence of interference, in the case of synchronized network, such a ratio is applied in determining the zones of mutual interference that occur within the synchronized system.5 In order to facilitate establishment of an appro- priate protection ratio for synchronous Operations. we encourage present and prospective experimental licensees to investigate the values of the signal-to-interference ratio applicable to reception of transmissions from synchro- nized transmitter groups comprised of two or more trans- mitters, taking into account alternative frequency tolerances. Both phase and. frequency methods of synchro- nization should be. considered..A European study .s.ug- gested one .ap.prach o .r.i.ningJhe .'prptctioio. This appioach involves the use of a statistical method based .:.Ofl ,st,i.bjctive. inpg; imp,resso c.recpt;ion quality, from a:transmitter.in a. synchronized. group. The results are then compared with. reception.., quality of. a single non-synchronized transmitter station.9 The EBU Report cited an instance in which protection ratio values for nonfading signals were first determined under labora- tory conditions. For fading signals. however, only Opel'- ational tests using a synchronized network were conducted. 16. There are several factors to heconsidered in deter- mining the protection ratio. These factors include: dif- ference of transit time, frequency tolerance, whether the interfering signals are groundwave or skywave. and the effects of stereo and other audio processing techniques. Thcre are also subjective factors to consider. For instance. 1390 2 FCC Rd Vol.5 Federal Communkations Commission kecord FCC 87-27 speech and some forms of contemporary music may ap- pear less susceptible to distortion than other program formats. 17. When three or more transmitters are used in a synchronous network, the problem of mutual interference is compounded. In such cases the combined effects of miltiple interfering signals during nighttime hours must he considered. For non-synchronized transmitters, this is accomplished by calculating the root-sum-square (RSS) of the interfering signals. The EBU report, referenced above. states that in most cases where the desired signal is the groundwave and the interfering signals are skywave. the interference protection ratio is defined as the ratio of the field strength of the wanted signal to the median value of the interfering field strengths. They also suggest. however, that the time probability of interference will lessen with the use of several synchronous transmitters within a net- work. We invite comments on the treatment of multiple interfering signals within a synchronized network. Addi- tionally. where experimentally possible. tests should be conducted on the effects of two as compared with three or more synchronized transmitters. Results of such tests should be rported in the comments. 18. Transit time. Transit time is the signal propagation time interval from the transmitter to the receivei. It is dependent on the location of the receiver, and may vary in the case of nighttime ionospheric propagation. if the difference in transit time from several sources is negli- gible and the distribution delay is equalized, theoretically there should be no distortion, but this occurs in practice for only a very small geographical area. Comment is requested on the effects of transit time and the manner in which program distribution equalization can be employed to minimize these effects. 19. Transmiuer Power. Much of the experience from experimental synchronized operations previously gained within the United States employed relatively low powered synchronized transmitters. As shown in the EBU report. however, this is not necessarily an inherent requirement for synchronous operation. Comments are requested as to whether the power of synchronized transmitters should he restricted or whether power levels up to that permitted for the station class of the primary statioO should be allowed, consistent with requisite protection to other sta- tions. Inter - system interference considerations 20. Additional important issues upon which comment is desired concei'n the interference protection criteria that would be applied between synchronized networks and stations not in the synchronized network. With respect to groundwave interference protection criteria, it appeal's that the groundwave signal overlap restrictions specified in Section 73.37(a) of the Rules may be appropriate. The matter of skywave interference protection criteria, how- ever, is not as clear. One such issue concerns the manner in which transmitters in the synchronized network should be protected from skywave interference caused by stations not in the synchronized network. 21. Similarly, another issue is whether the nighttime skywave interfering signals from the transmitters in a synchronized network should be considered individually or whether the cumulative interference effect of the entire synchronous group should be considered when calculat- ing skywave interference to other stations on the channel. In this regard the effect of the 50% exclusion rule must be evaluated. A decision in this area could affect the amount of power permitted for each transmitter in a synchronous group. Non - technical Issues 22. Beyond the technical issues discussed above, we also solicit comment on various non-technical policy isues related to the use of synchronous group transmitters. These non-technical issues can be divided into two major categories -- (1) licensing and eligibility requirements, and (2) ownership restrictions. 23. Licensing and EligthiUty Requirements. There are three areas of concern regarding the substantive require- ments and applications procedures that should be utilized in authorizing synchronous transmitters. FirsL we request that commenters address the question of what criteria should he utilized in deciding whether a synchronous transmitter should be authorized. For example, would a synchronous transmitter be appropriate only in situations where a conventional AM station would be precluded? Such preclusion could occur if a proposed new AM Station would cause prohibited overlap to other AM sta- tions in violation of Section 73.37(a) of the Commission's Rules or would cause nighttime interference in violation of Section 73.182. Additionally. would the mere desire of a licensee to increase coverage in one or more directions be sufficient justification to permit synchronous opera- tion? 24. Although synchronous transmitters may be used to enhance or extend the coverage areas of AM stations, should there be any limits ihposed on the extent to which the coverage area of an AM station may be aug- mented by the use of synchronous transmitters. and if so, what should they be? Alternatively, should synchronous operation be permitted only within an AM station's pro- tected contour under the Commission's Rules? We solicit comments on these questions and other matters related thereto. 25. Second, we invite comment on who may be licensed to operate synchronous transmitters. Because these trans- mitters may cause interference to the signal of the pi'i- mary AM station that is being rebroadcast or to other synchronous transmitters within the same network, we are not inclined to authorize their use by any party other than the AM station licensee who seeks to expand its service area. Moreover, such a licensing limitation is consistent .with the requirement that FM boosters--which rebroadcast the programing of a parent FM station on the same carrier frequency as the parent station-he autho- rized only to the licensee or permittee of the parent station)0 Since synchronous transmitters, like FM boost- ers. operate on the same frequency as the parent station and pose a potential for interference to the primary station. we believe that a similar licensing limitation would be appropriate. 2o. Third, we question how requests or applications for synchronous transmitters should be processed. Our initial view is that such applications should be processed like applications for major or minor changes in AM broadcast facilities because synchronous transmitters are intended to be permanent and protected improvements to the cov- erage of existing AM stations. Consequently. if an applica- tion for a synchronous transmitter is processed like a major change, it would be placed on a cut-off list and could not be acted upon by the Commission until after a 30-day public notice period. During that time. the public l11 FCC 87-27 Federal Communications Commission Record 2 FCC Red Vol.5 . ............. ....... . . would be afforded an opportunity to file petitions to deny pursuant to Section 309(d) of the Communications Act and Section 73.3584 of the Commission's Rules. In addi- tion. any applications for changes in existing AM facilities or for new AM stations which may be mutually exclusive with a synchronous transmitter proposal would have to be filed during this 30-day period)' Such mutually exclusive applications generaib,' warrant a comparative hearing to select a permittee under the As/ibacker doctrine:12 I-low- ever, if a request for a synchronous transmitter were processed like a minor change in facilities, it could be gianLed without the necessity of being placed on a cut-off list: and only those informal objections filed prior to grant could he considered. Accordingly. we request com- ment on whether such a cut-off list approach should he utilized or under what circumstances requests for syn- chronous transmitters should he considered as minor changes. Alternatively, we question whether synchronous transmitters should he treated as secondary to full-service stations and be afforded no continuing protection. 27. Ownership Restrictions. Next, we must consider whether owneiship restrictions should apply to synchro- nous group transmitters on either a local or a national basis. Such restrictions currently apply to the commercial AM. FM. and television services. With respect to national ownership restrictions, the Commission generally permits an individual to have a cognizable ownership interest in a maximum of 12 commercial AM stations.' The ques- tion arises as to whether synchronous transmitters, addi- tional to the primary station, should he counted for purposes of this 'rule of 12.' Our preliminary view is that synchrohobs transmitters shouki not he attributed under this rule. We base this position on two reasons. First, we believe that such a restriction may not allow for the full development of this proposed new broadcast technique and the benefits that it may afford. If broad- casters are limited to owning a total of 12 commercial AM stations, including synchronous transmitters, then they might he discouraged from building many synchro- nous transmitters because it could affect the number of additional AM stations that they could acquire. Second. exempting synchronous transmitters from the national ownership restrictions would be consistent with Commis- sion precedent. in this regard. the Commission does not count terrestrial satellite television stations for purposes of the twelve-station i'Wc. Like synchronous transmitters. these satellite television stations repeat most, if not all, the pràgramming from a parent station'and can have broad- cast facilitie comparable in power and coverage to the paient station Accoidingl we solicit comment on whether:we should take .the same approach for synchro-• flOU5:trnSrflittClS; ..::::. . ....,. ., 28. W also jf to cOnside whéthëf JodalO*nership i'eti'ictions should apply to synchronous group transmit- ters. One such restriction is the AM 'duopoiy" rule which currently prohibits overlap between the I mV/rn contours of commonly owned commercial AM stations.'5 Clearly. the 'duopoly" rule should not apply to overlap occuring within a synchronous network. Such local own- ership restrictions would have the detrimental effect of unnecessarily inhibiting the development of this new technology and preventing the enhancement or expansion of service by AM broadcasters. For similar reasons. we also believe the "duopoly" rule should not prohibit in- stances of contour overlap between synchronize transmit- ters and other comrnonl owned AM stations that are not part of the same synchronous network. 2. Another local ownership restriction is the 'one-to-a-market" rule which, inter alia, prohibits the common ownership of commerciaL AM and television stations in the same market. Specifically, the rule achieves this result by barring cross-ownership whei'e either the 2 mV/rn groundwave contour of the AM station encom- passes the entire community of license of the television station, or where the predicted Grade A contour of the television station encompasses the entire community of license of the AM station." We bel'reve that it would he inappropriate to apply this cross-ownership restriction, to synchronous transmitters as this would also hamper the development of this technology. Moreover, exempting synchronous transmitters from this rule would give AM broadcasters greater flexibility in using this technology to enhance and expand their service areas since they would not have to he concerned with contour encompassment between ,commonly owned television stations anti AM synchronous transmitters. Accordingly. we solicit com- ment on whether the public interes) would be served by exempting synchronous transmitters from the "duopoly' and 'oneto-a-ma,'ket" rules. IV. CONcLUSION 30. Synchronous transmitter systems have been success- fully used in Europe for many years to extend service. Although conditions in the United States differ, such operations appear to offer advantages here as well. Inter- nationally. general standards fo,' synchronous transmitter systems already exist, hut standards specifically tailored for the U.S. need to be developed. Moreover, non- technical issues unique to the U.S. need to he resolved before synchronized networks can he routinely autho- rized. 31. The primary issues addressed in this Inquir,v are summarized as follows: What technical standards should be adopted govern- ing the operation of a synchronous group of trans- mitters as it affects intra-system interference and other system impairments. What interference protection criteria should be ap- plied between synchronous networks and individual stations not in the synchronous network What level of distortion can be anticipated as a result of using frequenço phase synchronization techniques and which synchronization technique is more adyantageous? . Would the utility of nighttime synchronous trans- mitter operations be diminished significantly be- cause of skywave interference? What treatment should synchronous transmitters be afforded under the multiple ownership rules and what licensing criteria should be applied? 32. In order to assemble a comprehensive record, we invite comment from all interested parties on the issues discussed in this Inquiry. We also encourage experimental licensees to submit their results or observations relating to the technological concerns raised in this Inquiry. If corn- 1392 2 FCC Red Vol. Federal Communications Commission Record FCC 87-27 menters wish to address issues we have not identified, we encourage them to do so. The record established in this proceeding will allow the Commission to analyze the impact of synchronous group transmitters on the delivery of AM service to the general public, and to develop rule proposals. 33. Pursuant to applicable procedures set forth in Sec- tions 1.415, and 1.419 of the Commission's Rules, inter- ested parties may file comments on or before May 4, 1987 and reply comments on or before June 3, 1987. All relevant and timely comments will be considered by the Commission before final action is taken in this proceed- ing. To file formally in this proceeding participants must file an original and five copies of all comments, reply comments and supporting comments. If participants want each Commissioner to receive a personal copy of their comments. an original and nine copies must be filed. Comments and reply comments should be sent to Office of the Secretary, Federal Communications Commission. Washington. D.C. 20554. Comments and reply comments will be available for public inspection during regular business hours in the Dockets Reference Room (Rm. 239) of the Federal Communications Commission. 1919 M Street. N.W., Washington. D.C. 20554. V. AUTHORITY 34. Authority for issuance of this Notice is contained in Sections 4(i). 303(r) and 403 of the communications Act of 1934. as amended. 35. For information concerning this proceeding contact Bernard Gorden at (202) 632-9660 or Andrew 3. Rhodes (Legal) at (202) 632-7792. FEDERAL COMMUNICATIONS COMMISSION William .1. Tricarico Secretary FOOTNOTES The Report (pp. 71-77) included a discussion on the follow- ing three types of multiple transmitters: (1) synchronous opera- tion, (2) AM satellite stations, and (3) AM/FM translators. 2 Since January 1986, the Commission has granted experimental authorizations for the construction of synchro- nous systems to the following licensees: I(ROL of Henderson. Nevada; KOB of Albuquerque. New Mexico; KIPA of Hilo. Hawaii; and WiNO of West Palm Beach. Florida. Requests for experimental authorizations for synchronous transmilter oper- ations are currently pending from the following stations: KGNW of Seattle, Washington; KNEW of Oakland. California: KNIJZ of Houston, Texas; and WORC of Worcester. Massachu- setts. Experimental authorizations are on a secondary basis and are not afforded interference protection from other existing or future primary station assignments. Such authorizations also require that the permittees file comments to this Inquiry and detailed progress reports on their experimental operations. Sec Bell Telephone System technical publication. A Study Of Reception From Synchronized Broadcast Stations.t by Charles B. Aiken. Bell Telephone Laboratorie5. published in Proceedings of the Institute of Radio Engineers, Vol. 21, pp. 1265-1301, September. 1933. ' See European Broadcasting Union (EBU) Technical Report 3210, August 1974. 'Synchronizei1 Groups of Transmitters in LF and MF Broadcasting." which includes examples of low to high powered synchronous transmitters and techniques of fre- quency control. etc. Modulation delay, in thi5 case, is the amount of time that the program signal is delayed in being processed onto the carrier frequency. The control could be accomplished in any of several ways. including for example. the use of digital techniques employed via a microwave radio link. See the British Broadcasting Corporation. Research Depart- ment Report. February 1976, "Reduction of mush-area distor- tion in common-frequency M.F. transmitter networks." The current international protection ratio for synchronous operation used in international Agreements applicable to the U.S. is 8 dB. See Final ActS of the Regional Administrative MF Broadcasting Conference (Region 2). 1981 and Agreements be- tween the U.S. and Canada. and Mexico. respectively signed in 1984 and 1980. ' See CCIR Document Recommendation 500-I listing EBU reports on synchronized transmitter networks from the United Kingdom. India, and Japan. It) Sec 47 C.F.R. Section 74.1232(e) (1985). A mutually exclusive situation arises whenever two or more bona fide applicants timely file for use of the same broadcast frequency. or for different frequencies whose use would be technically incompatible under the Commissions Rules. 12 See Ashbacker Radio Corp. v. FCC. 326 U.S. 327. 333 (1945). 13 An individual generally has an attributable interest in a broadcast station if the individual is an officer, director, general partner, or owner of 5% or more of the voting stock of the station. See 47 C.F.R. Section 73.3555. Notes I and 2 (1985). ' Sec 47 C.F.R. Section 73.3555(d)(L) (1985). This limit may be increased to 14 AM stations provided that the additional two stations are controlled 50% or more by members of minority groups as set forth in 47 C.F.R. Section 73.3555(d)(3) (1985). ' 47 C.FR. Section 73.3555(a)(1) (1985). We recently pro- posed to relax the radio 'duopoly" rule. See Notice of Proposed Rule Making in MM Dockei No. 87-7. FCC 87-28. adopted January 15, 1987. 47 C.F.R. Section 73.3555(b)(I) (1985). In MM Docket No. 87-7, we have also proposed to modify the scope of the radio- television cross-ownership provisions of the 'one-to-a-market' rule. See note 15, supra. I