more onBroadcast Lobby Caught Red Handed With Red Herring

[Dave Farber <dave () farber net>]

> Date: Sat, 19 Jul 2003 16:44:32 -0600
> From: Dale Hatfield <hatfield () spot colorado edu>
> Subject: RE: [IP] more onBroadcast Lobby Caught Red Handed With Red Herring
> To: dave () farber net
>
>
>
> Dave, I am hesitant to get involved in this thread but I would point to the
> following on the FCC website:
>
> http://www.fcc.gov/Bureaus/Engineering_Technology/News_Releases/2000/nret000
> 5.txt
>
> I could give other examples.
>
> Best regards,
>
> Dale

                                             March 24, 2000
                          STATEMENT OF
DALE HATFIELD, CHIEF, OFFICE OF ENGINEERING AND TECHNOLOGY, AND
             ROY STEWART, CHIEF, MASS MEDIA BUREAU
           CONCERNING LOW POWER FM ENGINEERING ISSUES

We are concerned that Members of Congress have received misleading engineering
information about alleged interference from low power FM radio stations.

One particularly misleading disinformation effort involves a compact disc being
distributed by NAB that purports to demonstrate the type of interference to 
existing radio stations
that NAB claims will occur from new low power FM radio stations. This CD 
demonstration is
misleading and is simply wrong.

  ·  The NAB CD does not portray actual interference that might be 
experienced.  The NAB CD
  was produced by artificially mixing two previously recorded radio 
signals and is not a
  demonstration of actual interference between two FM radio stations.

  ·  The type of "crosstalk" interference suggested by NAB, that is, where 
you can intelligibly
  hear portions of both transmissions, does not occur from LPFM stations 
operating on 3rd
  adjacent channels.  Any such interference that might occur would only 
appear as noise or
  hissing. The NAB "crosstalk" demonstration simply does not represent 
actual FM radio
  performance and therefore is meaningless.

  ·  The NAB also incorrectly states that the FCC considers a 3% level of 
total harmonic
  distortion plus noise from interference to be acceptable. This too is 
wrong. The FCC Report
  and Order refuted a similar previous NAB assertion and clearly indicated 
that the
  Commission based its evaluations on a 1% level. To continue to make the 
argument in this
  CD about the 3% level can only be viewed as a deliberate 
misrepresentation of the FCC's
  findings and analysis.

There also have been concerns raised by NPR about the impact of low power 
FM radio
on radio reading services. Radio reading services, which carry newspapers 
and other information
aurally to the visually impaired population, operate as subcarriers on FM 
frequencies.  Just as our
testing has determined that existing stations will not experience harmful 
interference, the
Commission stated in the Report & Order that subcarriers on these 
frequencies should not
experience harmful interference.  Nevertheless, we  will continue to work 
with NPR to test radio
reading service receivers, and will, if necessary, recommend to the 
Commission steps
specifically tailored to deal with the radio reading service issue.

We believe the Commission took a thorough and indeed conservative approach in
designing a low power FM radio service that protects the integrity of the 
broadcast radio
spectrum.



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