Petition Closed
Petitioning Media Bureau Chief, Federal Communications Commissio William T. Lake

Create a Low Power AM Radio Service in the Expanded AM Band (1610 - 1700 kHz)

Update: A companion petition urging the Media Division of the FCC to increase Part 15 power levels to 1 watt in the AM band and 10 watts in the shortwave broadcast bands is now on line. Please visit and sign that petition as well.

 

Dear Mr Lake,

The undersigned urge you to create a Low Power AM Radio Service. We need to enable low and middle income independent broadcasters to serve their communities by setting up their own legal, small broadcast operations, typically at a cost of less than ten thousand dollars.

Roughly speaking, the technical and legal parameters of this service should be as follows:

1) No individual or company currently with an ownership interest in a full powered AM, FM, or TV station should be eligible to apply for or own one of these facilities. The maximum number of LPAM stations that a single individual or company can own should be no more than 7 nationwide. The business entity of the licensees shall be involved in radio broadcasting only and shall not have an ownership interest in any other kind of business.

2) Stations in this service will operate in the under-utilized expanded AM band from 1610 to 1700 kHz. Those that are within 12 miles of a major urban core should be limited to an effective radiated power of 10 watts. Stations outside of the urban cores should be limited to 100 watts. All radiation patterns would be non-directional, day and night. Permitted antennas should conform to the same requirements as TIS stations currently operating in the AM band. But current Part 15 antenna limits can be used where there are financial restrictions or no other options exist, as long as all elements of the transmitting chain are compatible with power output. Broadcasting in analog C-Quam AM stereo should be permitted and encouraged.

2) Unlike LPFM, these stations can be owned by individuals and can be either commercial or non-commercial. The business entity can be registered as either "for profit" or non profit. Operators are free to sell spot advertising to independent local businesses, solicit financial support from listeners, or engage in a combination of both.

3) Also unlike LPFM, there should be NO FILING WINDOWS imposed upon the applicants for this service. This should be an ongoing, FCC-approved class of AM broadcast station that can be applied for when an applicant feels he or she is ready. There should be no requirements of "financial ability" and no expensive field strength measurements on a periodic basis. Compliance with power output and a total antenna length of 50 feet or less should be all that's required. There should be reasonable protection from interference for all successfully licensed LPAM stations within a reasonable distance from their transmitters.

There are many reasons why an LPAM service such as this is urgently needed:

1) Corporate domination of radio (commercial and "non-commercial") has stifled individual creativity, limited employment opportunities, and censored a wide variety of political, social, and cultural ideas and artifacts from the mass audience of traditional media. The talents of many people who once worked in radio, but are too educated or ethical to play the corporate game, or refuse to engage with bickering "community advisory boards" at "public" stations, are now going to waste. We need to put these people back to work in a medium where they are free to create whatever they wish and present it to the local public.

2) Due largely to the neglect and mismanagement of your agency, the AM band continues to deteriorate. It is estimated that only 17 percent of all terrestrial radio listeners now tune to anything on the AM band and that audience gets older with each passing year. Devices like Plasma TV's and poorly shielded dimmer switches can knock out a marginal AM signal for blocks, in violation of the FCC's own interference rules. Furthermore, over the past dozen years, radio manufacturers (in an apparent attempt to make all receivers conform to HD standards) have made the bandwidth of their analog AM sections so narrow, the audio quality now rivals a 1950's phone line. With these strikes against it, AM radio badly needs a new, more positive kind of "buzz." Listeners will put up with a reasonable amount of AM band adversity if they are hearing something desirable they cannot hear on FM.

3) Small independent local businesses are the fabric of our communities. Yet, they are under constant threat from big chains and can't compete with them when it comes to electronic media advertising. An LPAM service, where spot advertising from local businesses is allowed, would offer rock bottom rates that most small businesses could afford, and a whole new audience could be informed of their products and services.  

4) The Low Power FM service, with its ownership and commercial restrictions, has not succeeded in bringing experienced professionals back into radio, nor has it given them any hope of ever earning a living wage in exchange for their services. LPFM is designed for community groups that staff stations with volunteers. This LPAM proposal is designed for radio enthusiasts and professionals who want the freedom to create their own programming on their own terms, with reasonable hope that just enough of an income will manifest to keep the bills paid and to stay on the air. We believe this is even more in the public interest than the effort of LPFM to allow community groups to broadcast.

5) The price of today's commercially licensed, full powered radio stations - even marginal ones - is way beyond what a typical small-to-medium market broadcast employee could ever afford or qualify to finance. Outside of the union shops in major markets, radio programming has for decades been one of the lowest paid occupations one could ever pursue. It is a major injustice that the people most qualified to operate small stations are the least qualified to buy them. The creation of an LPAM service, as described, goes a long way in correcting that injustice.

6) Current FCC rules have resulted in an extended AM band that is obviously under-utilized. There have been no new full powered stations or older licensed AM stations moving into the band in roughly 14 years. In most areas of the country, 1610-1700 is still totally silent during daylight hours. We already have more than enough full powered facilities for rich individuals, institutions, and corporations to play with in order to feed us the same old programming and the same old approach. We need to set aside this under-utilized spectrum for the use of low powered broadcasters of modest economic means, to hear their perspective, and to give them the opportunity to support themselves with a sustainable income. 

7) The evolution of the internet has made a mind boggling array of quality programming available to low power stations, most of it at no cost. Reasonably priced broadcast automation software also makes unmanned 24 hour operation mostly reliable. Yet, very few currently licensed stations air any programming or podcasts from internet-only sources. It is now easier than ever for a low power broadcaster to fill out his or her schedule with some of these offerings when not airing locally produced programming, and provide education, entertainment, and service to the community around the clock.

8) Currently, the only "legal" way to simulate the range of a 100 watt AM station is to acquire a trunk load of Part 15 AM transmitters, find homeowners, business property owners, or tower site owners scattered throughout a region who are willing to host them, link them through an internet stream, and hope you don't get too many failures at once. This is a onerous process that doesn't build much confidence in potential advertisers and financial supporters. Nothing builds credibility like a long term FCC license! An inclusive Low Power AM radio service would nearly end all "pirate" broadcasting in the United States and all the animosity it brings between your agency and broadcasters of limited means. All of the ethnic AM expanded band "pirates" currently operating in major urban areas would gladly convert to 10 watt licensed operation. And current Part 15 broadcasters would have available an upgrade that can result in a real audience and income. Unlike LPFM, a Low Power AM service should have NO RESTRICTIONS on individuals who have operated an unlicensed station in the past, legal or illegal. FULL AMNESTY MUST BE GRANTED.

A decade ago, the composer of this petition was part of a citizens LPAM team, sponsored by the Amherst Alliance, to petition the FCC to create a Low Power AM radio service with far fewer restrictions than the LPFM service that was emerging at the time. If we needed an LPAM service back then, we need it even more so today. Therefore, we, the undersigned, URGE you, Chief Lake, to initiate without undue delay an LPAM service that conforms to the outline of this petition. It is time to better serve and inform our local communities, enhance the viability of local independent business, and reverse the exodus of talent from the radio broadcast industry that has occurred over the past two decades.

This petition was delivered to:
  • Media Bureau Chief, Federal Communications Commissio
    William T. Lake


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