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Re: Rant About LPFM

<< The engineering argument against third-adjacent LPFMs is specious at
best.  It's clear from the real world that third-adjacent spacing on FM
works fine in cases involving much more power than LPFMs would... >>

That argument only carries to the extent that the discussion remains in
realm of analog to analog. Noboby knows what effect, if any, third
adjacencies will have on IBOC digital, simply because we have no real world
situations in which to conduct proper testing.

IBOC digital is all present broadcasters have for the future. In rejecting
the (more or less) worldwide standard Eureka 142 system, US broadcasters
have hung their entire digital future on a system that --over a decade from
its dubious inception-- is still being invented. What little we know about
the progress of IBOC development seems to indicate real problems in
extending dependable digital coverage to anything close to an approximation
of the analog curves. Maybe the researchers will someday find a way to get
full coverage in digital, but they aren't there yet.

The major point of my written commentary to the FCC was a simple one: In
that nobody can predict with a degree of certainty worthy of the future of
free, over the air broadcasting what the effects of LPFM will be on digital
IBOC, why not wait until comprehensive and conclusive field testing can be
done under actual terrain and propagation conditions? According to some IBOC
sources, we might be less than a year away from being to do exactly that.

So what's the rush? Is LPFM Bill Kennard's contribution to Bill Clinton's
legacy? Is the need for new outlets of expression for women and minorities
in rural areas (few if any fit in the largest cities) so dire that we can
afford to gamble on the final degree of effectiveness of the digital future
of the entire industry?

The FCC itself hasn't been a completely straight shooter in all this. Their
representatives consistently, almost piously, assured broadcasters they
would *never* do anything to cause interference to existing signals, only to
promulgate new rules that roll back the interference-free contour area for
all stations from 50% to 75%. Obviously, they aren't quite as sure about new
interference as they pretend to be. The new definition of 'interference'
lets them off the hook ... now and in the digital world ahead.

In the larger context of existing 50 and 100kw FM, Web audio and the
imminent deployment of S-DARS, it appears to me that giving
"underrepresented" minorities and groups 100 and 10 watt toys that primarily
fit where those entities are not --is a new low for tokenism.

I suspect that someday LPFM will be said to not have collapsed under its own
weight, but to have evaporated due to its inherent weightlessness.