Radio Survivor

The National Federation of Community Broadcasters just wrapped up its annual conference this past weekend in St. Paul, MN. The NFCB has been a true anchor in the community radio movement, both supporting individual stations and advocating on their behalf in DC. This year the FCC actually graced the conference, with Commissioner Mingon Clyburn giving a speech on June 10.

Commissioner Clyburn certainly let loose quite a few surprises, starting with suggesting that TV channels 5 and 6 could be reallocated for non-commercial FM radio, low-power FM or AM broadcasters. While she said that she wasn’t suggesting an immediate change, Clyburn said that, “it is time for us to take a serious look at
where these services fit within the overall spectrum plan, and that Channels 5 and 6 maybe a good home.”

The spectrum allocated to analog channels 5 and 6 sits just below the FM band’s lower limit of 88 MHz. Before the digital transition you might remember being able to hear channel 6 TV audio at the bottom end of your FM dial. Although the transition meant full-power stations lost their analog audio signal, low-power TV stations were permitted to remain analog. As I’ve reported before, there are several low-power channel 6 stations taking advantage of their proximity to the FM dial to function effectively like radio stations rather than TV.

Any reallocation of channel 5 and 6 spectrum would require dealing with the few full-power stations that chose to stay put rather than move to different spectrum space. It would also have to deal with the LPTV stations on channels 5 & 6. My guess is that these stations could be offered to move into spectrum allocated for digital, though it might take some horse trading. It’s also likely that those few LPTV stations on channel 6 are going to be very reluctant to move and give up their radio-like business, although it’s just a matter of time before the FCC kills that business model by forcing all LPTV to go digital.

Commissioner Clyburn also suggested that community stations consider the charms of HD Radio. She acknowledged that, “limited receiver penetration and the cost of digital transmission equipment may make owning an HD Radio station an unappealing option for community radio groups.” However, she also proposed that “HD can provide yet another way to promote broadcast diversity and expanded programming option.” She even suggested that community stations or groups seeking stations could partner with other commercial or non-commercial stations to program their secondary HD-2 and HD-3 channels.

It’s pretty rare for community radio to get such a courtesy call from an FCC commissioner, and all the more rare for a commissioner to drop so many bombshells. I’m cautiously optimistic to hear such support for community radio and an apparent willingness to consider an expansion of the FM band in order to accommodate more non-commercial stations. I do have to note, however, that there’s no indication that an expanded band would be only for community radio. Nevertheless, it will be interesting to see if the idea gains any traction with the full Commission.

Over the past year I’ve been tracking the mini-phenomenon of a few low-power TV stations on channel 6 using their signal as a back-door to the FM dial rather than real TV stations. This situation occurs because the audio portion of analog TV channel 6 bumps up against the far left end of the FM dial. Full-power TV stations on channel 6 have gone digital, and some have moved to other spectrum space. In either case their audio is no longer heard on the FM dial. But LPTV stations were not required to go digital last year, and so are still heard.

While this loophole remains open for existing stations, new LPTV stations will not be able to take advantage. Today the FCC released a notice [PDF] saying that applicants for new LPTV stations must amend their applications to be digital before May 24 of this year.

It looks like there are seven channel 6 applications pending. Who knows if any of the applicants were planning on taking advantage of proximity to the FM dial. But if any were, that option is now off the table.

At this point I think it’s safe to say the countdown timer is ticking closer to zero on channel 6 on FM. Last October the FCC ended protection of channel 6 signals from interference coming from FM stations. As the commission whittles away at analog LPTV it’s just a matter of time until the Media Bureau gets around to setting a mandatory digital transition date for LPTV stations. I think this is especially true given the fact that the FCC is seriously looking at reallocating broadcast spectrum for wireless broadband.

A couple of  weeks ago I reported on Chicago Public Radio taking a glancing swipe against LPTV channel 6 stations that are effectively functioning like radio stations, taking advantage of their audio channel’s proximity to 87.7 FM. Now the owner of the Chicago smooth-jazz LPTV “radio” station WLFM-LP is striking back at CPR in both reply comments to the FCC and a press release, which I received via email [.doc file].

In its FCC comments WFLM’s owner, Venture Technologies Group, takes the gloves off, charging that Chicago Public Radio’s “attempt to characterize these LPTV stations as ‘invaders’ of NCE spectrum is ridiculous,” although CPR never specifically names WLFM-LP. VTG goes on to accuse that,

WBEZ appears to be arguing that non-commercial stations should have the right to approve the programming of their commercial neighbors merely because they are adjacent to each other and a listener may hear commercial matter while scrolling through the radio dial looking for a non·commercial station. This is an absurd argument!

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Far outside the view of the general public, the virtual cratediggers of the FCC’s electronic recesses like Matthew and myself are sometimes privy to the little slap-fights that go on between broadcasters. In this case things are getting a little heated over the far left end of the FM dial, with a prominent public radio station calling out LPTV broadcasters exploiting the channel 6 backdoor to the FM dial.

As I’ve been already reported, the FCC recently ended restrictions on the use of FM frequencies adjacent to TV channel 6– 87.9 to 88.5 FM–in markets where former analog channel 6 stations went digital and changed channels.  Now, National Public Radio has petitioned the FCC to open up these frequencies everywhere, even in markets where digital TV stations decided to stay on channel 6 or where there are grandfathered analog low-power TV stations.

NPR’s argument rests on a technical analysis concluding that digital TV signals are far more interference-resistant than analog, and that modern TV tuners are selective enough to make interference from FM negligible for even analog LPTV signals.

Predictably, fellow noncommercial FM broadcasters are lining up in support of NPR’s proposal, while the ABC network and the National Association of Broadcasters have filed comments in opposition, calling into question NPR’s engineering data. There’s a few sparks coming from these opposing comments, but the real fun is buried in comments from Chicago Public Radio.

Without naming names, CPR  pointedly complains,

LPTV stations have begun to invade FM radio, broadcasting audio signals that were licensed for TV broadcast as if they were commercial radio stations on 87. 7 MHz. Not only are these signals inappropriately being broadcast as radio, they are also bleeding 24·hour dance music, with commercial advertising, over into the noncommercial stations that are on the lower NCE FM channels. Like squatters moving into recently-vacated homes, these LPTV stations are, in effect, intentionally broadcasting commercial radio which spills over onto the reserved portion of the FM band, trespassing on the limited territory of their noncommercial neighbors. Before this phenomenon becomes entrenched, the Commission owes the public, as well as public radio stations, a reasoned consideration of this problem.

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Perhaps it was too good to be true. The overcrowded FM dial of the New York City metroplex offered no easy opportunity to bring a new cutting edge dance music station to the radio. But an opportunity was found at the far left end of the dial in the space occupied by TV channel 6 audio. So in February, 2008 87.7 FM the Pulse went on the air using the analog audio of low-power TV channel 6. Then, just 20 months later, the station pulled the plug yesterday at 5 PM, only four hours and forty-five minutes after announcing its imminent demise on air.

The death of the Pulse was not unexpected, given that the station’s owner Mega Media Group filed for bankruptcy in August. No doubt, commercial radio is a tough business in the 21st century, especially following nearly thirteen years of rampant industry consolidation which triggered ruthless cutting of ad rates in order to drive independent operators out of business and into the arms of megabroadcasters like Clear Channel and Cumulus. It’s fair to say that the Pulse had an uphill battle to begin with. Even with a unique format and a potentially very loyal audience, there’s fewer and fewer ad dollars to go around.
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Regular readers may recall that I’ve been doggedly pursuing the minor phenomenon of analog TV channel 6 broadcasters exploiting their audio signal’s proximity to the FM dial to become radio broadcasters. At present the only analog TV stations capable of exploiting this backdoor are low-power TV stations which were not required to go digital this year.

However, the future viability of that idea became a little less secure this past week when the FCC’s Media Bureau announced (PDF) that beginning Oct. 27 it will end the protection of channel 6’s audio spectrum in areas where a formerly analog channel 6 moved to a new UHF channel when it went digital.

In effect, the FCC is just saying that now that in places where there’s now no analog or digital channel occupying the space next to 87.7 FM, there’s no point in expecting FM stations to avoid encroaching on it. What it doesn’t mean is any sudden increase in available noncommercial licenses at the far left end of the dial. This is because no application window for this class of licenses is scheduled in the near future.

It might allow a few existing noncommercial stations occupying frequencies from 87.9 to 88.5 or so to either raise their power, relocate their transmitter or otherwise improve their signal because they won’t have to protect the vacant channel 6 space any longer. Yet, this might be complicated by the upcoming January 25, 2010 filing window for new digital-only LPTV stations. VHF channel 6 spectrum space should still be in the offing for new LPTV stations, which could block any significant expansion of noncommercial FM into the area of 87.7 FM. However, none of these new LPTV stations will be analog. So they won’t be broadcasting an audio signal that will be heard on the FM dial.

To some it may seem like I’ve been beating a dead horse over the TV channel 6 on FM issue, but I can’t help but be fascinated with TV broadcasters taking such pains to be on what so many observers say is the dying medium of radio.

In my second missive on the channel 6 radio phenomenon back in June I took note of Schenectady New York’s WRGB-TV. That station’s director of engineering made clear his intention to keep WRGB’s analog audio signal going even after the digital transition.

Now some ten weeks after the June 12 analog shutoff WRGB’s little experiment has come to an end. According to a brief statement posted to the station’s website dated August 24, general manager Robert Furlong acknowledges that this digital TV station has no authorization from the FCC to continue an analog broadcast on the FM dial, and announces the FM broadcast has been turned off, “effective immediately.”

I’ve not turned up any additional explanation for killing it so suddenly. My guess is that the station got a pretty firm message from the FCC reminding them that the license to broadcast an analog signal of any kind expired on June 12. I can’t see how WRGB continuing its 87.7 FM broadcast can be seen as anything but unlicensed operation, which would earn any other unlicensed broadcaster an FCC nastygram, at the very least.

Furlong also says that the station management “reviewing our options,” though I can’t really imagine what those options might be. They could petition the FCC to let them resume the analog broadcast, but that’s a very long longshot. Or perhaps they could reach an arrangement for simulcast with a desperate local radio station. Yet that option quickly gets complex, since I’m certain all of WRGB’s network affiliation and syndication agreements are for TV broadcast only. Adding a real radio simulcast would likely require renegotiating all of those contracts.

The appearance of analog TV’s channel 6 on the far left end of the FM dial was not designed in. Rather it was a happy accident which provided some listeners with an extra channel of programming and some other broadcasters an opportunity to sneak onto the FM dial. Like many such accidents, it might have been good while it lasted, but the sun seems to be setting for channel 6 on FM.

It takes a lot of listener donations to take on $3.5 million of debt and liabilities. That’s how far in the hole the owner of New York City’s 87.7 FM The Pulse found itself when the company, Mega Media Group, filed for bankruptcy last week. Loyal RadioSurvivor readers might recall that The Pulse is actually a low-power TV station operating on channel 6, which butts up against the left end of the FM dial, making its audio channel heard on most radios at 87.7 FM.

Last month I wrote about the quasi pledge drive that The Pulse held to try and stave off financial disaster. I found irony in the station begging for donations given that it’s commercial station run by a for-profit corporation. As it turns out, it’s for-profit in name only, since Mega Media Group only lists assets worth $180,000, less than half of the $414,000 it owes the IRS.

There’s been no report of how much The Pulse listeners donated. The station held a “87.7 is Alive Celebration” on July 24, with all proceeds from the event going to “keeping the radio station alive.” But the New York Daily News reports that the station announced that it didn’t need the donations after all. Maybe the company’s management figured out that taking listener’s money might mess up their bankruptcy plans?

It’s difficult to draw any generalizations from The Pulse’s bankruptcy. While finding a backdoor into the country’s largest radio market via a low-power TV station might be cheaper than buying an existing station, that doesn’t mean it comes without cost or risk. And, as I noted before, we don’t know to what extent management fumbled the ball, either. There were apparently plans to launch a record label in concert with the station. At this point it’s hard to know which is the worse business to get into right now, commercial radio or records.

Mega Media Group filed for chapter 11 protection, which means it’s hoping to reorganize. Presumably, the station will remain on air in the meantime.

Last month I wrote about a few legacy analog channel 6 low-power TV stations operating as radio stations, taking advantage of their audio program butting up against the low end of the FM dial. One of the pioneers is New York City’s Pulse 87. However it seems as though the backdoor to the FM dial may not be so easy to keep open.

Arcane Radio Trivia alerted me to Pulse 87’s call to listeners to donate to the station in order to keep it in good stead with creditors. Nevermind that Pulse 87 is a commercial station (ostensibly operating in the noncommercial part of the dial at that).

As of July 21 it looks like loyal listeners came through with the much needed cash, gaining the station “a reprieve from some of our creditors” and the opportunity “to attempt to raise money through more conventional means.” The station also promises to return the donations, presumably once replacement capital is raised.

I’m not really sure what to make of this situation. Commercial media is having a hard time, whether broadcast, internet or print, so I’m hesitant to place blame on the weakness of radio or the channel 6 LPTV method. We have no idea what the books at Pulse 87 look like, so it’s hard to say whether the culprit is insufficient revenue, poor management, or some mixture of both.

However, I do think it’s safe to say that the particular dance music format of Pulse 87 has tapped into some kind of loyal niche audience otherwise insufficiently served by other stations. The real test will be whether or not Pulse 87 can keep up the quality of the programming that keeps a loyal listenership in the face of cashflow problems. The temptation to cost-cut by automating and embracing other Clear Channel tactics may be too strong, even if that’s the surest route to undercut the qualities that make the station unique.

Perhaps the station would be better off going non-profit and relying on its listeners who’ve apparently already demonstrated a willingness to cough up bucks to keep Pulse 87 on air.

Following up on last week’s post about LPTV stations on channel 6 effectively turning into radio broadcasters I’ve been researching the topic a bit more. Turns out that full-power TV stations had the option to stay on channel 6 in their transition to digital, as I learned from this April article in TV Technology. Although their channel space still bumps up against the low end of the FM dial, the don’t retain their analog audio, and so are no longer heard on the radio.

Interestingly, Fred Lass, the director of engineering for Schenectady, NY’s WRGB-TV, tells TV Technology that he’s considering methods for continuing to have an analog FM audio broadcast alongside the station’s digital signal:

“We have a plan to continue operating on 87.7 after we go digital,” he said. “We think that it’s possible to operate with a vertically polarized analog FM audio carrier when we go back to ch. 6 for DTV. That signal will be horizontally polarized, of course, and there should be enough cross pol isolation to make it work.”

Lass admits that he really hasn’t tried this yet, but thinks it should work.

It never occurred to me that DTV stations would be permitted to continue broadcasting an analog FM audio signal, and I wonder if this is something that would require permission from the FCC.
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