A New Direction for AM Directionals, or...

What's the most time consuming, anguishing thing you have to do that you wish you could tell the FCC where to put if you didn't have to worry about an indecency investigation?

If you're operating a directional AM station -- and yes, there are plenty of them out there -- I'd make book that, to you, one of the most aggravating things about being in radio has to do with monitoring point verification. In this age of computer modeling and electronic FCC filing, when nearly all other FCC technical monitoring tasks have been simplified and automated, why do AM directionals still have to track changes in signal levels manually at specified monitoring points?

Well, maybe we're about to bring AM directionals into the 21st century after all. The FCC is considering going to the computer generation for these stations, bypassing monitoring point verification.

Indeed, the rules dealing with AM directional monitoring have required updating for years. In 2003, I obtained a clarification for our AM clients that solved a conflict between the requirements of Sections 73.62 and 73.1350 of the rules. Each rule required a correction when monitoring; point information indicated that there was a directional antenna problem. One rule required action within 24 hours and the other required correction within three minutes or the station had to come off the air. We asked that conflict be resolved in favor of 24 hours in all cases. The Commission agreed -- as long the variation in operating parameters was "minor" and there were no interference complaints. A minor variation was defined as:

• A variation of operating parameters of less than 15% or 10 degrees in phase, or...
• A monitoring point measurement of less that 125% of the licensed limit ...
• UNLESS the operation at variance caused a complaint of interference.

But we didn't get rid of the required periodic monitoring. The Commission did, however, acknowledge that monitor points go out of tolerance frequently due to circumstances beyond the AM station's control, such as nearby construction or weather variations, but that they rarely cause actual interference to others.

So the station owner has to spend a lot of money and go through much grief over a problem that will generally solve itself. Now comes the 21st century, and computer modeling that can end the aggravation with software in much the way we now deal with FM and television. Reviving an old 1989 rulemaking proceeding, a coalition of broadcasters, engineers and equipment manufacturers, known as the AM Directional Antenna Verification Coalition (the "Coalition") reactivated the request claiming that the very future of AM depended on implementation of these changes. Gone are the doubts from 1989 engineers and consultants who lacked experience with computer modeling. The Coalition even expanded the proposal to allow the use of computer modeling in lieu of field strength measurements for new structures. It also has coordinated the proposal with the wireless trade associations whose members could be affected by the proposed rule change, including the Land Mobile Communications Counsel, PCIA-The Wireless Infrastructure Association, CTIA and the Wireless Communications Association, which now support the proposal.

If adopted, an AM antenna will be treated like FM or TV with a onetime computer model to verify its performance. Then the antenna could operate without having to perform costly routine field measurements. If there is nearby construction, the computer model could be used to determine if the AM pattern has been adversely affected, instead having to use complicated, time consuming and expensive field strength measurements. With these measurements, AM directional applications would not be filed electronically, in the CDBS system.

The savings and benefits of the computerized approach will be obvious to any AM station owner with a directional antenna. But, if you wish to retain the manual monitoring point system, the rule would allow it.

Reply comments were due last September and some think that action may be coming soon. Stay tuned.

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This column is provided for general information purposes only and should not be relied upon as legal advice pertaining to any specific factual situation. Legal decisions should be made only after proper consultation with a legal professional of your choosing.