FCC Releases Draft AM Revitalization Order to Simplify Proofs of Performance

Last week, the FCC released a draft of an order to simplify the proofing of AM stations. This order will be considered at the FCC’s September 26 meeting. While the proposals to be adopted are part of the AM Revitalizationproceeding, even the Commission recognizes that these are not fundamental changes in the way that stations operate, but instead technical changes that can, hopefully, save some AM stations some money. The FCC also noted that it was removing proposals for changes in the AM main studio rules from the AM Revitalization proceeding as these changes are already being considered in the proceeding proposing to entirely eliminate the main studio rules (see our post here).

The rule changes in the proposed order address AM antenna proofs of performance – principally proofs that are conducted after a station has been initially constructed and licensed. The need to re-proof an AM station’s directional pattern typically occurs when additional antennas or other equipment is added to an existing AM tower, or when there are other changes that suggest to the licensee that the AM directional pattern’s values may have changed (e.g. when there is significant construction in the immediate vicinity of the tower). Most of the FCC’s planned changes deal with Method of Moments (“MoM”) modeling used to proof AM stations (see our posts here and here on the FCC’s adoption of the computerized technology used to make proofing of AM antennas easier), though one change dealt with more traditional AM proof of performance techniques.

The rule change affecting traditional proofs deals with how many radials need to be proofed when there are changes in the equipment located on the AM tower or when other changes necessitate an AM partial proof of performance. The FCC’s draft order provides that measurements only need be taken on the radials in an AM pattern that contain a monitoring point. In the current rules, additional radials adjacent to the radials containing monitoring points must be measured when the station has a pattern with fewer than four monitored radials.

For stations using MoM modeling to proof their facilities, the FCC’s draft order would make a number of changes to make the modeling process somewhat simpler. These changes would:

  • Eliminate periodic recertifications of the performance of a directional pattern for stations licensed pursuant to a MoM proof as the technology has proven its reliability and needs less verification. The new rule would require recertification only when equipment has been repaired or replaced;
  • Eliminate the requirement to conduct reference field strength measurements when relicensing a station that was licensed pursuant to a MoM proof;
  • To encourage the co-location of AM stations, eliminate the requirement for a registered surveyor’s certification of the location of towers in an AM array when existing towers in an existing AM antenna array are being used by a new station using MoM modeling;
  • Clarify that the provisions of a certain rule section will only apply when total capacitance used for MoM modeling of base region effects exceeds a particular value and only when a particular type of sampling is used; and
  • Codify the standards under which a new MoM proof of performance is needed when adding or modifying antennas or other system components above the base insulator of a tower in an AM array.

The FCC declined to allow MoM proofing for AM stations with a skirt-fed antenna, finding that the technology has not yet been reliably demonstrated for modeling the patterns of such antennas. Obviously, each of these changes is very technical, so consult your engineer to determine how they may affect your operations.

Finally, the FCC stated that it would no longer be considering any changes to the rules for AM station’s main studios as part of the AM revitalization proceeding. Instead, those changes will be part of the proceeding to abolish the main studio rules entirely. As we wrote here, FCC Chairman Pai stated in his speech at last week’s NAB Radio Show that he had reviewed the record of that proceeding, and was convinced that the main studio rule needed to be abolished. Obviously, the other Commissioners need to weigh in before any change in the rule can be adopted. Some have suggested that the main studio rule may be abolished before the end of the year, so stay tuned to watch for that action.

And watch for the FCC to adopt these proposals on AM improvements at its meeting in two weeks.