Jump to less technical (more historical) general discussion here
SUMMARY:
IBOC proposal is unecessary and should scrapped because (points 1,2,3,4 and 5) :
1)Analog should not be scrapped without thourouly proving
that it's supposed "obsolescence" is in fact a real and
sufficient detriment to the citizenry sufficient to
subsidize by mandate the electronics industry at the expense
of the citizenry.
OR
2) Scrapped in Favor of (replaced with) the Eureka 147
plan either:
2)a) in whole acceptance of world standard at 1400Mhz OR
2)b) an American variation using the new abandoned UHF TV frequencies.
2)c) IBOC does not work in a real-world mobile
environment
for the same reason that the stereo
subcarrier is the
first to drop out due to interference.
2)d) If data services (pagers etc.) are multiplexed in
signal, first room for a full bandwidth stereo
"channel" must be provided for "Public Access"
in exchange for eleviation of all public
service requirements except EAS.
3) Or the IBOC proposal should be scrapped altogether
because the current IBOC plan is an
UNECESSARY expansion of existing SCA services.
3)b) There is sufficient bandwidth
in the *existing* SCA
channels using proven
robust existing technology
to carry all the services
that the IBOC proponents
requests service for:
3)b)1) Full Digital MPEG1 or MP3 streaming Digital Audio Stereo
broadcasting
3)b)2) Value-Added text/graphic printouts on the face plate of
the reciever such as
banner ads for advertised products,
name of song/artist,
emergency road and traffic alerts etc and
emergency radio activation.
4) The IBOC proposal threatens the desperately needed Low
Power Radio Service
for which there is great demand
(possibly greater demand than even for Digital Audio Broadcasting!)
And for which the major IBOC-related arguments are contradicted
by the very same IBOC proposal flaws:
4)a) IBOC uses double standard that is self contradictory.
The interference argument used to the
detriment of the
LPRS proposal argues that stations cannot
be too close together,
then argues that it is OK to move stations
closer together for DAB.
4)b) IBOC proponents argued that the LPRS would harm consumers
economically
who have inferior recievers ...
then suggest that it is OK to mandate
ALL consumers to upgrade to DAB recievers.
4)c) The LPRS proposal recieved more formal comments than ANY
proposal in US history ...
most of the comments were in FAVOR of
the LPRS.
4)d) And yet sales of DAB recievers has been lackluster in countries
who are using
the superior Eureka 147 system.
This suggests that interest in IBOC
DAB recievers will be abysmal.
5) Evidence suggests that the main interest in FM broadcast stations may not be to create a hegemony of control over advertising and control of programming ... but rather to destroy/absorb competition for beepers and other digital packetized mobile communication services that have utilzed the FCC's spectrum auction (and therby avoid bidding) system for specifically that purpose. THIS COULD HAND THE MOBILE DIGITAL REVOLUTION OVER TO A SMALL GROUP OF PEOPLE FOR FREE!!
Allowing the unecessary expansion of the Subcarrier
(as provided for in the IBOC propsal) footprint would
decimate these services and make a farce of FCC efforts.
5)a) The radio industry was largely a market follower
until the widespread use of SCA
beepers and
other packetized mobile digital
data services
became affordable.
5)b) Beepers recieving their signals from US Standard FM Broadcast
Band spectrum subcarriers provides
the following advantages
over those beepers used on FCC
auctioned sections of spectrum
*originally* intended for such
use:
5)b)1) Towers are already sited
5)b)1)a) No NIMBY from Civic Associations will block distribution
5)b)1)b) No expenditure for towers necessary
5)b)1)c) No additional paperwork with the FAA and no extra zoning
variances needed.
5)b)1)a) EXISTING TOWERS PROVIDE 95% coverage of US population!
5)b)2) Beepers will work ANYWHERE ON THE PLANET
WHERE US FM BROADCAST STD AVAILABLE.
5)b)2)a) These beepers are more standardized therefore cheaper.
5)b)2)b) These beepers are also more useful (to the point of
being a
near monopoly) to lucrative multinational corporate market than
other mobile beeper/packetized data services.
=================================================
DETAILED EXPLANATION OF ABOVE SUMMARIZED POINTS:
=================================================
=====================
SECTION 1 of 5 points
=====================
Obsolete is obsolete:
FIRST of all, it should be noted that there was no such thing as "obsolete"
for the vast majority of human existence.
Until well into the Industrial Revolution, what worked for your great-great-great ancestor, worked for you.
And even to this day, we often come around. A significant number of cars at the turn of the 20th century were ELECTRIC. And here we are going "back" to the "obsolete" technology of the electric car!
Furthermore, radio has changed, but not been supplanted by TV or the Internet. The analog technology is robust and relatively inexspensive.
The explosive prices paid for "real-estate" on the public's commons, the airwaves are more of an artifact of the 1996 Telecom Act, the Corporate feeding frenzy that resulted as the large radio chains realized they could sell beeper and data packet information services on the subcarriers on a nationwide basis, than on the cost of the equipment to deliver this service.
Books are still popular ... in spite of being "obsolete".
So first, the notion that analog radio is "obsolete" and that this is the best excuse to replace it with digital radio should NOT be accepted wihout question.
===================
Radio Most *Potentially* inclusive democratic medium:
===================
Consider that radio provides as no other medium can for the closest
thing to a nearly purely democratic Free Press. It is portable, the radios
are so cheap that you can find working models in the trash cans with a
regularity that is astonishing! For the price of $0.35, you can call in
to a live interactive talk show and VOILA, you are "wired", "online" in
the great debates that make up our progress that we call "civilization."
In short, due specifically to its simple robust nature and ubiquitousness (due to its age as a technology) radio provides for THE greatest *possible* inclusivity for the greatest possible range of people in our society.
That radio is so EXclusive (leaving *out* so many) to so many views and cultures is not a function of technology, rather it is a function of the fact that the beancounters and money-changers of current society do not regard their role as a "Free Press" as anything more than a money-press, a kind of hi-tech way to launder their "cash".
To require all those radios to be unable to recieve anything intelligible
without a major gain for the consumer is to essentially tax-subsidize by
decree that everyone must support the electronics manufactuerers by buying
replacemnt equipment.
=========================================================
THE SINGLE MOST IMPORTANT QUESTION IN THIS PROCEEDING SHOULD BE:
"WHAT IF ANY MAJOR EARTH-SHAKING BENEFIT WOULD IT BRING TO THE CONSUMER?"
==========================================================
DOES DAB PROVIDE SUFFICIENT BENEFIT TO THE CONSUMER FOR GOVERNMENT TO MANDATE A MASS EXPENDITURE (SUBSIDY BY MANDATE) FOR COMPLETE REPLACEMENT OF BILLIONS OF EXSTING RADIOS?
The IBOC proponents claim the benefits to the consumer are:
1) "Near CD" sound quality.
2) Delivery of non-audio information of use to the consumer such as:
2a)EAS information in a text or graphical format such as:
2)a)1) Weather Alerts (perhaps including a small satellite photo of
the doppler radar info)
2)a)2) Traffic Alerts (Again, a graphic showing the location of the
wrecks on a GPS style map)
2)a)3) Emergency Vehicle and School Bus and Train Alerts (current technolgy
does provide for FM radio based GPS positioning software/hardware that
could pick up packetized information specific to that latitude and longitude
range.)
RESPONSE:
Regarding item 1, the "Near CD" sound quality. The short answer is
"So what"?
In the December 1999 Radio & Record magazine, it was reported that
the European consumer electronics sellers were very disappointed with the
very low consumer demand for the Eureka 147 DAB recievers. It would seem
that the European consumers have experienced the same response I had which
was "Who Cares?"
CONSIDER: The usual use for a radio:
1) Entertainment or information source while driving a car.
2) Entertainment or information source while riding a bike or hiking
or walking.
3) Background or mulitasking information while surfing the Internet.
4) Something to fall asleep to.
In none of these instances do I care that the CD player sounds ever so slightly better. First of all, although I am only 34 years of age, my ability to hear the higher notes is quite diminished.
Second (and most important) in most of those instances, the road noise, barking dogs, kids screaming, honking or even just the engine and/or wind noise destroys my ability to discern any sound quality improvement of even stereo FM over an old half-worn cassette tape!!
FINALLY, if I want CD quality, I put in a CD.
The artists and recording companies don't want me to bootleg their
songs off the CD that at least ONE person bought much less bootleg it off
the radio for nothing!!
THEREFORE this "Near CD sound quality" is WORTHLESS to the vast majority
of users.
The lackluster sales in Europe proves that my response if far from
a fringe response.
==========
Regarding Item (and subitems) numbered 2 in this section:
The nonaudio (text and graphic) information of use to the citizen:
The short answer is "we've already HAD *that* technology for DECADES ... and the broadcasters only NOW want to use it?"
Some of these items would be of great addition to my quality of life. This item perhaps is worthy of consideration.
There is only one problem, THE FCC NEED NOT DO ANYTHING FOR US TO ENJOY THIS BENEFIT.
Right now (actually since the late 1970s!!) one of the standard subcarrier
channels has been available for exactly those kinds of services. The Radio
Data System already has products on the market that make impressive use
of this decades old technology.
============================================
THEREFORE my recomendation is that doing nothing is better than doing
something that will have unintended consequences, especially when doing
nothing allows for the exact same benefit asked for by the requested change!!
SO FAR NONE OF THE SUPPOSED BENEFITS ARE BENEFITS OR REQUIRE ANY INTERVENTION IN CURRENT RULES AND REGULATIONS to be enjoyed!
Furthermore, I have data included below that show that even if it is
determined that "near CD quaility" is in fact an actual gain ... the broadcasters
can also implement Digital Audio Broadcasting WITH NO CHANGES IN CURRENT
RULES AND REGULATIONS OR EVEN ANY TECHNOLOGICAL ADVANCES.
============================================
End Section 1 and suggestion that the very concept of DAB is flawed
as unecessary and not providing any significant benefit to the citizen
taxpayer.
============================================
BUT IF FROM NEW DATA OR POINTS IT IS STILL DETERMINED THAT DIGITAL AUDIO PROVIDES A REAL GAIN FOR THE TAXPAYING CITIZEN:
============================================================
SECTION FOR ITEM 2 of 5 major points re: The IBOC Proceeding:
============================================================
Why reinvent the wheel?
In ____, Commissioner _____________was quoted as voting against accepting
the world standard of Eureka 147 for DAB, saying,"I am a hawk, I will not
vote for anything that would keep smart bombs from reaching their targets."
This is such a ludicrous statement that it is obvious that there were
other reasons for allowing the taxpayer funded Pentagon to deny taxpayers
the benefits of the world accepted (and now in use for several years) standard
of Eureka 147 on the "L-Band" at 1400Mhz.
Surely Commissioner ______ didn't mean to suggest that Smart Bombs
would fail in any nation that was using L-Band Eureka 147 transmitters
... for that would mean that eventually the only place smart bombs would
work was on US citizens!!
Thus unless the Taxpayer-funded Pentagon can come up with a better
argument, they should be required to move their test telemetry to another
band and allow Democracy to be strengthened by the power of competition.
Accepting the Eureka 147 standard would be a boon for the consumer
interested in competition.
2)1) A Third broadcast band would provide a new opportunity for new
entrants unencumbered with the problems associated with finding space on
the existing broadcast bands.
2)2) New entrants would all come to the band equally, whether they
were already in possession of large holdings on the other broadcast bands
or not.
2)3) Eureka 147 is a "pure" digital signal with mulitplexed streams
of multiple streams of data that are reduntant (and at or close to the
center frequency) thus allowing for much more robust signal than the expanded
subcarriers of the IBOC plan
2)a) Accepting the whole Eureka 147 world standard would be of maximum benefit to the citizens and taxpayers of America because there is an already existing stock of merchandise built for this standard. Thus it is merely a matter of importation, no other modifications are necessary than perhaps the UL certifications. We can then enjoy all the benefits of a WORLD CLASS level of competition in the development of products to serve ever widening specificity in tastes for features that would not exist for a "odd man out" North American (excluding Canada that HAS accepted the world standard) market.
2)b) If the Pentagon insists on keeping the public's assets from full
use by the public ...
then it would be of second-best benefit to
the citizens and taxpayers of America to use the exact same technology
shifted down to the frequencies provided by the newly abandoned UHF TV
frequencies. Thus we could continue to use existing antenna installations
and existing decoder techologies only requiring the addition of a different
front-end tuner circuitry or upconverter attached to world standard recievers.
2)c) CONSIDER:
When you are driving and experience multipath or other interference,
the FIRST thing to go is the stereo pilot tone. Your car radio switches
to manaural decoding easily.
BUT if your signal WAS in essense the stereo pilot (a series of subcarrier
signals, as provided for in the IBOC) then your digital feed would cut
off and on at the slightest interference!
Then it would have to buffer the signal once it reaquired it (much
like watching DBS satellite TV during interference, or when switching channels,
there is a buffering delay). Then repeat the next time your signal is "picket
fenced" into worthlessness.
FURTHERMORE, the current IBOC proposal is merely an expansion of the
existing subcarrier width ... placing the signals EVEN FURTHER from the
stable center of the assigned frequency, thus MAKING THE IBOC DAB SIGNAL
EVEN MORE SUSCEPTIBLE TO INTERFERENCE THAN THE STEREO PILOT SCA TONE!!
This is why when the former FCC Commissioners chose to reject the Eureka
147 world standard (Which the National Association of Broadcasters originally
supported!), the NAB switched to supporting the IBOC plan ... where it
sat on the shelf with no attention or development from 1992 until 1999
when the Low Power Radio Service was proposed. IBOC did not work in a mobile
real-world environment in 1992 and it does not work now for the same reason.
Notice that the old MUZAK services and stockbroker and commodities information
delivery provided on the SCA systems required their recievers to use a
special yagi antenna and these services did not work well for mobile systems.
There is little evidence that it would work better now with the signal
spread EVEN FURTHER from the center frequency as the IBOC plan proposes.
2)d) Much of the explosive growth of the Internet, the loss of viewership
of mainstream TV evening news in favor of magazines and the Internet is
due to the fact that America does not see itself as a "melting pot". Rather
Americans see ourselves as a "Brunswick Stew" where all the component parts
togother create an "American flavor", yet still retain much of their individuality.
It is accepted that if your values and interests are not represented in
the business board rooms, the Congressional subcommittees and school boards,
then you are essentially invisible!
The explosive growth of Pirate Radio, the Internet and Magazines provides
a "place for everyone" to feel valued, noticed, to have impact and to exist.
In this environment many have tried to impress public service requirements
on those broadcasters whose use our public assets are protected by taxpayer
funded agencies such as the FCC ... in exchange for providing a variety
of news/views and culture that is the "Free Press".
Without a "Free Press" that provides for many antagonistic viewpoints
to have a chance to make their case ... Democracy is a joke!
THUS:
GIVEN THAT the PRIMARY reason that the taxpayers pay for the FCC
and allow FM radio stations to exist without
rent on our public asset
(the airwaves) because they are a part of
the "Free Press" that is
established as vital to a Democratic Government,
AND GIVEN THAT many efforts at providing for
a competitive environment
have failed in the new environment of consolidation
AND GIVEN THAT many American regard efforts
to create a media that
has a place in it for them and their values
AND GIVEN THAT the pure digital signal provides
for dynamically
configurable bandwidth use such that either
the public signal or
other digital packetized (like on a LAN) signals
could be given more
or less bandwidth by the broadcaster
THEREFORE if the broadcasters are going to
start using a digital
signal on the public airwaves protected at
taxpayer expense ...
THE BROADCASTERS CAN DROP ALL PUBLIC SERVICE
REQUIREMENTS IN
FAVOR OF A "PUBLIC ACCESS" AUDIO CHANNEL MULTIPLEXED
INTO THE DIGITAL FEED
THAT CAN BE SELECTED BY THE LISTENER AS EASILY
AS ANY OTHER 'PUBLIC'
PACKETIZED INFORMATION SUCH AS EAS, ADVERTISER
BANNERS AND WEATHER
AND TRAFFIC ALERTS MULTIPLEXED INTO THE PACKETIZED
(SOME PUBLIC,
SOME PROPRIETARY) BITSTREAM.
2)c)1) The trigger for this public access channel will be
If data services (pagers etc.) are multiplexed in
signal, first room for a full stereo
"channel" must be provided for "Public Access"
in exchange for eleviation of all public
service requirements except EAS.
==============================================
THUS CONCLUSION FOR SECTION 2:
IBOC IS INHERENTLY UNSTABLE IN A MOBILE ENVIRONMENT FOR WHICH RADIO
EXCELS
AND THUS IS WORTHLESS UNDER REAL-WORLD CONDITIONS
AND SHOULD BE SCRAPPED IN FAVOR OF THE ALREADY PROVEN AND ACCEPTED
(AND THUS MORE ECONOMICAL) WORLD STANDARD EUREKA 147 SYSTEM.
==============================================
==============================================
SECTION 3 of 5 points:
IF after all, A)Analog services are determined to be of sufficient
relative
detriment to the citizenry to mandate the expense of a
mass-upgrade in technology and
B)The Pentagon comes up with a GOOD reason that the FCC
should not
implement the world standard of Eureka 147 technolgy for DAB
on the L-Band THEN
==============================================
THEN IBOC should STILL be scrapped as ultimitely UNECESSARY:
In short, ALL of the proposed benefits for Digital Audio Broadcasting
in the IBOC proposed expansion of the existing SCA technolgoy can be done
with EXISTING TECHNOLOGY using EXISTING SCA RULES!
Thus this document proposes to demonstrate (in an overview) how the FCC can serve all parties their stated desires without the IBOC proposal needed at all!
=================
DISCUSSION OF ABILITY OF BROADCASTERS TO TRANSMIT DIGIALLY RIGHT NOW
WITH NO CHANGES NECESSARY FROM THE FCC:
=================
The second common SubCarrier Authorization channel is generally referred
to as the DARC (DAta Radio Channel channel).
This DARC channel is 35Khz in bandwidth.
Using a very basic technology invented in 1916 by Ma Bell , several "virtual modems" or "vitual phone lines" can be transmitted down one channel.
line one is 0 to 4Khz, channel two takes the voice, or the fax machine info, or the digital audio stream and shifts the frequencies up 4khz.
Thus the 400 Hertz tone that contains a digital bit of information on the first channel becomes 4,400 Hertz on the second "virtual channel".
And so on until you run out of bandwidth.
So if you divide 4Khz (telephone standard bandwidth) into 35Khz (Bandwidth available on DARC established Subcarrier technology) you get 8.75 virtual channels.
Then we look to CURRENT STANDARD MINIMUM GURANTEED-TO-CONNECT SPEED on phone lines ... 9600 baud (most fax machines run at this speed for that reason).
Then we recall that in the quest for higher speed modems, for a short time "multi-frequency" modems were considered that would divide the bandwidth of the phone line into several virtual modems each with a fraction of the total speed capability of the modem. That way noise on the phone line would only cause the loss of a fraction of the speed where the noise blocked one particluar set of the total available range of frequencies containing information.
If we revive this technology, and use the most robust proven modem technology that provides a capacity of 9600 bits per second per 4Khz slice ...
We then see that we obtain a Digital Audio Broadcasting capacity ON
ONLY ONE OF THE MANY ALREADY EXISTING LEGAL AND TECHNOLOGICALLY PROVEN
SUBCARRIER CHANNELS of:
8.75 virtual channels * 9600 bits per second capacity per virtual channel
= 84000 bits per second.
Radio Shack right now is selling an MP3 player that is advertised as offering music fed at 63 bits per second. 84,000 bits per second is easily twice the actual realistic log-on speed for most users of most currently existing modems!
So using ESTABLISHED TECHNOLOGIES we see that we can send a Digital
Audio Broadcast signal down the ONE existing SCA channel WITH CAPACITY
TO SPARE for other services such as:
-Traffic and Weather Alerts
-Name of Song, Artist ...
-As well as added value information for advertisers of interest to
the listeners such as web site addresses, simple pictures of products (like
banner ads on web pages)
AND BEST OF ALL ... the broadcasters *still* have other SCA channels available for control of transmitters, sale to paging services etc.
THE ONLY BENEFIT TO THE IBOC PLAN to expand the size of these subcarriers then is to INCREASE THE BANDWIDTH AVAILABLE FOR PAGING SERVICES.
The radio entertainment and news consumer gains nothing from these paging services, and the FCC has already stated openly that they WILL NOT ACT TO DEFEND BROADCASTER PROFITS.
Indeed, the Broadcasters have been enjoying 35%-40% profits during the late 1990s ... they will not suffer any significant (bankrupting) economic hardship by requiring them to transmit Digital Audio Broadcasting down their existing SCA channels and furthermore will also enable the FCC to concentrate on enforcement of existing services in the interest of the public that pays taxes to support the FCC's regulation of the public's airwaves.
Indeed, SINCE THE FCC HAS ALSO IMPLEMENTED A PROGRAM TO AUCTION FREQUENCIES
FOR WIRELESS SERVICES SUCH AS THOSE THAT THE SCA EXPANSION WOULD PROVIDE
FOR ... ALLOWING BROADCASTERS TO USE TAXPAYER PROTECTED FREQUENCIES TO
COMPETE UNFAIRLY WITH THOSE WHO BID FOR PAGING FREQUENCIES WOULD BE A FARCE
OF AMZAING PROPORTIONS FOR THE FCC AND THE TAXPAYER.
=================
TO REVIEW:
=================
This plan requires NO NEW ACTIONS or CUTTING EDGE TECHNOLOGIES to proceed:
Since 1916 we have had robust proven technology used by the phone companies to "multiplex" (send multiple "channels" of information down one main audio channel) by shifting clusters of information up the available bandwidth in 4Khz wide clusters.
Since 1955 We have robust proven technology to send information down the same FM modulated signal at higher "center" frequencies that can be divided up any number of ways until the legally and technologically available bandwidth is used (Industry Standard equipment top limit is the highest channel centered at 185Khz with a 7.5Khz bandwidth, well in excess of the standard needed for established decades-old facsimile technology of 9600 bps)
Since the Mid 1980s, a new standard has been developed for digital use of Subcarriers, MBS and RBDS centered at 57Khz and the extension of that system, the DARC channel (centered at 76 Khz with a bandwidth of 35Khz).
And if even more ancient SCA technology would be preferable, consider that MARTI has for many decades sold SCA encoders that provide SEVEN channels on 39, 41, 67, 92, 110, 152 and 185 KHz with bandwidth capacities of 3, 5 or 7.5 KHz.
It would require only a variation of existing multiplexing technologies for a reciever to be enabled to recieve all seven frequencies and combine the 7 virtual modem lines of streaming audio into one Codec stream ... the seven channels have a possible robust established capacity almost DOUBLE that of the existing phone lines (the 7.5Khz bandwidth option on the MARTI SCD-10 model) wich provides for quite a bit of redundant rebroadcast of data to make up for multipath or frequency-selective interference on one channel or another using established CRC (Cyclical Redundancy Check) error correction already used for MPEG1 Audio DAB technology.
Note also that the potential for increase in speed is nothing short of amazing.
The MARTI encoder mentioned here has a total capacity available to it (and going thru industry accepted standard transmitters with no problems) of 30Khz (minus half of the 7.5Khz bandwidth per channel providing for a bottom edge of 26.25Khz ... all the way up to 190.75Hhz [187Khz centered SCA channel with the 7.5Khz bandwidth option, half of which is above the 187Khz center adding up to 190.75Khz). If we view the entire capacity as ONE POSSIBLE channel ... that provides an available bandwidth of 164.50 Khz ...
Applying the earlier 1916 multiplexing technology ... to this new bandwidth
164.50/4Khz bandwidth per standard phone line ... = 41.125 virtual
channels.
IF THEN we review the fact that ALTHOUGH 9600bps IS THE STANDARD NOW
FOR GUARANTEED CONNECTION OVER STANDARD PHONE LINES ... it is also established
that using established V.32terbo modulation and MNP5 compression technologies,
reliable connections of 19,200 bps per virtual channel
(telephone line) are standard now.
Even higher bits per second rates are actually standard on telephone lines now, but those technologies require that the modems speak to each other to establish wave shaping and equalization of the frequecy response of that particular phone line connection. This is not possible for simplex DAB broadcasting where the reciever never communicates back to the transmitter. Thus we will stick to the latest in simplex-capable compression and modulation schemes.
To reapply the math then, and to push our technological limits all the way up to the mid 1990s established and robust technology, we surmise that the actual total capacity for existing SCA DAB rebroadcast (Monaural FM analog transmission) IS:
41 virtual channels * 19,200 bits per second per channel = 1689200 bits per second!!!!!!!!!!!
If we use the established mobile "walkman style" MP3 technology for sale right now at Radio Shack of 63bits per second necessary for mobile-quality acceptable stereo digital audio ...
THAT MEANS THAT RIGHT NOW BROADCASTERS COULD TRANSMIT 26,812 channels of Digital Audio on their existing subcarriers using existing technology!!!!
DONT FORGET that this will be SIMPLEX and NOT DUPLEX ... so that 19,200 bits per second current capacity can be almost DOUBLED as ALL the channels will be one-way, simplex instead of eating up much of the capacity in duplex error correction and communication.
Since the actual gain will depend on the CRC error correction scheme chosen further math is not relevant, besides, you can see that the capacity becomes truly far more than necessary for providing Digital Audio Broadcasting and basic listener services such as Weather and Traffic Alerts.
MORE REALISTICALLY we could send the 19,200bps data streams down only
the MARTI's available slots above the full analog stereo signal ... the
channels centered at 67, 92, 110, 152 and 185 KHz with a bandwidth each
of 7.5Khz provides for MORE than enough capacity to provide:
19,200bps * 5 channels = 96,000 bps.
The remaining RDS channel still provides text/banner/EAS services.
26,000+ music channels is not likely to happen and most of that digital
capacity will consist of paging services and other mobile digital information
services that would provide unfair competition for the paging companies
that have paid auction prices to the FCC for frequencies that require that
they fight civic associations for tower location rights to serve a population
that the existing FM broadcasters already cover nearly 100% ... FOR FREE!!!!!!!!
=================
TO CONCLUDE SECTION 3:
=================
The legal entities that have had their use of the public's airwaves protected at taxpayer expense by the FCC ... do so for no rent or bid on those frequencies because they provide a benefit to the public provide that informational link we call a "Free Press" that is VITAL TO A HEALTHY DEMOCRACY.
In short, they use our resources because they are a vital part of a healthy democratic process.
If they essentially steal bandwidth to unfairly compete with paging companies and simultaneously come up with anticompetitive schemes such as IBOC to block competition from others who wish to be heard. ...
Then they are in violation of their social contract with the American Public that pays for their use of our spectrum!
This document demonstrates that there is a serious possibility that broadcasters can get what they say they need with NO hardship to the communities that wish to compete with the Low Power Radio Service ... AND with NO changes vis-a-vis IBOC necessary from the FCC.
At the very least, the hope is that this document will give the commissioners
serious pause in consideration of the IBOC proposal and that legitimate
concerns of fairness suggest that perhaps the current IBOC proposal should
be :
1) Shifted to the Eureka 147 standard patterns (either accepting the
world standard in whole, or creating an American variation on the newly
available UHF spectrum (formerly the UHF television spectrum) ...
2) Scrap the IBOC concept altogether as :
2)a) Unecessary
2)b) Anticompetive
2)c) Contributing to a monopolistic and antidemocratic scheme where
only a few boards of directors control the vast majority of outlets for
news/views and culural exchange as well as competition for campaign commercials.
Thank-you for your time and consideration.
===============================================
SECTION 4 of 5 points:
The IBOC proposal threatens the desperately needed Low Power Radio
Service
for which there is great demand
(possibly greater demand than even for Digital Audio Broadcasting!)
===============================================
The OPponents of the Low Power Radio Service (LPRS) argue that the LPRS
would:
a) Cause interference for the reception of current radio stations by
many consumers.
b) Therefore cause an economic hardship in requiring consumers to buy
better FM recievers
c) Because the outer edges of the radio stations would be closer together
both geographically as well as in terms of their spacing on the FM Broadcast
Band spectrum.
Yet the PROPonents of the IBOC Digital Audio Broadcasting proposal (largely the same people who oppose the LPRS) argue that it is OK to expand the footprint of the subcarriers to implement IBOC and therefore push the edges of the transmitters closer together on the FM Broadcast Band spectrum.
As if that inherently self-contradicting double standard "speaking out
both sides of their mouth" were not bad enough ...
The proponents of IBOC think nothing of requiring *everyone* to purchase
new recievers to pick up the DAB signals after the analog services are
discontinued.
Furthermore, even *IF* it were true that many people would have to buy new recievers to deal with the new LPRS stations on their dial (and both the CDC AND the FCCs own studies state that only __to __% of recievers would need replacement) ... it is only a small number, a tiny fraction of the number of people that IBOC would force to spend money!
And finally, SINCE the FCC exists (at taxpayer expense) to protect the
use of the public's airwaves by private institutions IN THE PUBLIC's INTEREST
... AND
THE FCC HAS STATED THAT THE FCC WILL NOT ACT TO PROTECT BROADCASTERS
PROFITS
AND SINCE THE BROADCASTING INDUSTRY IS CURRENTLY ENJOYING 35%-40% PROFIT
MARGINS
IT BEHOOVES THE FCC TO ERR IN FAVOR OF THE PUBLIC INTEREST in PROMOTING
COMPETITION AND DIVERSITY OF SOURCES OF NEWS/VIEWS AND CULTURE.
the Low Power Radio Service has recieved more formal comments than any other single FCC proceeding in US history ... most of them favorable!
===========================
Section 5 of 5
===========================
See the rest of this website for need for
the Low Power Radio Service!!
APPENDIX:
============================
GENERAL (less technical) DISCUSSION OF ISSUES:
============================
The IBOC proponents claim the benefits to the consumer are:
1) "Near CD" sound quality.
2) Delivery of non-audio information of use to the consumer such as:
2a)EAS information in a text or graphical format such as:
2)a)1) Weather Alerts (perhaps including a small satellite photo of
the doppler radar info)
2)a)2) Traffic Alerts (Again, a graphic showing the location of the
wrecks on a GPS style map)
2)a)3) Emergency Vehicle and School Bus and Train Alerts (current technolgy
does provide for FM radio based GPS positioning software/hardware that
could pick up packetized information specific to that latitude and longitude
range.)
NOTICE that the technology to send nonaudio text/graphical information to a display on a radio faceplate (such as items 2 and subitems) has existed for decades.
Only now are they finally using it.
The system now used is generally called the "Radio Data System"
Research herein that shows that the broadcasters COULD GO DIGITAL TODAY
right now with their EXISTING equipment and rules ... (More discussion
in the appendix below)
but they would rather expand their signal size ... BECAUSE THEY WISH
TO COMPETE UNFAIRLY WITH PAGER AND DATA DELIVERY SERVICES at the expense
of the listeners that pay taxes to protect their use of our assets (the
airwaves) for their private gain.
This could be the next biggest ripoff since we got Manhattan from the Indians for a bunch of beads.
Consider that one of the biggest advances (and need for radio frequencies)
has been wireless digital services like:
-Alphanumeric paging (phone numbers and more)
-Sending of data for delivery trucking companies from a base to mobile
trucks.
-specialized (mostly one-way voice mail etc.) cellular phone services
For example, it is promoted openly thusly:
"SUBcarrier
COMmunications
Cell phones.
Pagers. Digital PCS. Modems. New area codes.
These
are the most visible signs of the
telecommunications
revolution. People are demanding more
portable
personal communications and users require more
specialized
services. The dynamics of this rapidly
changing
market revolve around deploying new services
that generate
revenue."
From: http://www.yearbooknews.com/html/subcom.html
The explosion of paging and cell phones is pushing the unprecedented growth of area codes in the USA. Most of those new numbers are for wireless services.
The FCC initiated an AUCTION system to divvy up the few frequencies available to the many companies that wanted to compete for access to customers.
Now imagine that you already own a network of transmitters ... that
covers 95% of the USA!
Imagine now that you could compete with all those paging companies
for customers ...
WITHOUT BIDDING FOR FREQUENCIES!!!
AND even better, WITHOUT HAVING TO BUY ADDITIONAL TOWERS, TRANSMITTERS.
And FINALLY, Imagine that this allows you to COMPETE WITHOUT FIGHTING
CIVIC ASSOCIATIONS TO ALLOW LOCATING PAGING TRANSMITTER TOWERS.
That would be the huge FM broadcasting networks that are now using the "excess" broadcasting capacity to sell airtime to paging and mobile digital data customer.
Excess capacity, allow a brief explanation.
An FM stereo signal is legally definded as 200 Khz "wide".
Imagine the FM band represented by a string. 89.7FM is at the
left
end of the string, 107.9FM is at the right hand side of the
string.
You are given a "channel" on that string, which is defined as
a 200Khz
(0.2Mhz) long piece of that string that is "centered" at your
advertized frequency (say, 88.9Mhz FM WCVE "public" radio).
Your "real-estate", your slot on the public aiwaves in this example
goes from the center of 88.9FM, minus/plus 0.1 Megahertz So
your
realestate begins at 88.8 and ends at 89.0 on that string.
Then the FCC requires a certain amount of an "easement" between
the stations as a guard against interference.
This is necessary
because the FCC has never used its power of regulation to require
that recievers be able to separate two stations that are right
next to each other on the string. The consumer equipment manufactures
were able to convince the FCC to allow them to sell us junk
recievers ...
because nowadays all but the cheesiest 3% of radios can and
regularly
DO separate stations that are very close to each other on the
string for a particular geographic area. In fact there are over
300 "Short Spaced Grandfathered Superpowered" FM radio stations
that
are closer together and more powerful than current regulations
would
have allowed.
The (legitimate) theory appears to be that if no-one in the recieving
public complains that their recievers are unable to separate
reception
of one station from another ... then for all practical purposes,
THERE
IS NO INTERFERENCE.
And indeed, the FCC has stated that they have never recieved
a
complaint from any reciever users of those stations in 30+ years.
This indicates that either people don't care, and/or that
current recievers are good enough to separate stations that
are much closer together than regulations are assuming are
necessary. This ironically is of course THE reason that
the proponents of IBOC DAB feel confident in their attempt
to pursuade the FCC to expand the size of their existing
subcarriers and thus their "footprint" on the FM band ...
and thus push their outer edges closer together.
Now ... on to this matter of "excess" braodcasting capacity.
Basic sound is 0 Hertz (vibrations a second) to 15Kilo ("thousand")
Hertz.
Your assigned space is 200 Khz wide.
But you want to transmit in stereo.
So you need:
That original monaural signal that is 15Khz wide.
A left channel
A Right channel
and a sound tone at 19Khz to activate the stereo decoding circuit
and turn on the stereo light.
That then gobbles up 0Hertz to 53Khz. Well, you have 200 to legally play with!
For many many years, it has been legal to add an addional set
of
information called "subcarriers" on top of the basic radio station
info mentioned above. SCA info at:
http://www.toltbbs.com/~bhammond/sca.htm
For DECADES (since 1955), "Muzak" and primitive paging and some
religious services as well as "reading services for the blind"
have
been carried on these subcarrier channels.
Depending on how you want to divvy it up, you can
have two large channels, or subdivide it into 5 or 7 channels
that sound
like a telephone when you send voice down it.
Here's a page giving an example of a product that provides 7
channels:
http://www.brainm.cz/products/stls/scd_10.html
You would then sell special "SCA" (SubCarrier Authorization)
enabled
reciever to pick up the muzak or to the blind etc to hear your
SCA service.
Well, nowadays, the muzak is delivered by DBS satellite technology
...
and many reading services for the blind have moved to a third
TV audio
channel called "Second Audio Program" (SAP) that is available
to anyone
with a stereo enabled VCR or TV. This is because the stereo
VCR or TV
is much more universally available than the special SCA FM recievers.
So the subcarriers have laid unused for some time ... and now
the
paging companies such as Nokia's founded CUE corporation are
advertising
their 95% coverage of the American population via the FM radio
station's subcarrier systems!
See:
http://www.directories.mfi.com/embedded/ce/artic_03.htm
Apparently this is not enough for broadcasters.
They want to kill the Low Power Radio Service, and create
EVEN MORE EXCESS BROADCASTING CAPACITY FOR THESE PAGING SERVICES
AT NO ADDIONAL COST TO THE BROADCASTER.
This provides three awesome benefits to the huge chain broadcasting
networks.
1) Destroys competition from the new LPRS stations
2) Utterly overwhelms the competition from other paging companies that
have to:
2a) BID for frequencies from the FCC
2b) FIGHT local "Not In My Backyard" civic associations that
dont
want the paging antennas in their neighborhoods
2c) Pay for paging recievers that are on different frequencies
in different towns.
(whereas Nokia and CUE and the big broadcasters
can provide nationwide, indeed
even WORLDwide paging where the
pagers work on the standard FM band whereever
regular FM recievers exist!!!!!!!!!!!!!!!!!)
It is no exagerration to say that this is an amazing THEFT of broadcast access PAID FOR BY TAXPAYERS that also REDUCES the taxpayers ACCESS TO COMPETITIVE BROADCAST STATIONS AND PROGRAMMING all in one fell swoop.
Finally, this will likely be one of THE main carriers for the wireless revolution for users of mobile Internet revolution products ... whatever filters to your access are placed by the few corporations that are likely to be left standing after the merger frenzy started by the Telecommunications Act of 1996 will be for all intents and purposes unavoidable!!
The Robber Barons of the 19th century would be proud ....
+++++++++++++++
More information
+++++++++++++++
"Radio Data System ___ TUN
RDS (Radio Data System) - is a radio information system
widely used in Europe, growing in North America and likely to
expand locally. It allows a variety of audio and text based
information to be transmitted by radio stations including traffic
updates, alerts, music titles, etc. "
http://www.alpine1.com/soundadvice/atoz.html#R
and this description that shows how old the technology is! :
"What is RDS ?
A Brief Introduction to RDS (Radio Data System for VHF/FM broadcasting)
The use of more and more frequencies for radio programmes
in the
VHF/FM range make it inceasingly difficult to
tune a conventional radio to a desired programme.
This kind of difficulty is solved with the Radio Data
System,
that has been on the market since 1987, and whose spectacular
evolution is still continuing. RDS has by now conquered
all receiver price classes and one can easily imagine
that it
will soon be part of the standard equipment of any radio
receiver.
The development of RDS started some 20 years ago in the
European
Broadcasting Union, EBU. The developers aimed at making
radio
receivers very user-friendly, especially car radios when
these
are used where a transmitter network with a number of
alternative
frequencies (AF) are present. In addition listeners should
be
enabled to see the programme service name (PS) on an eight
character alpha-numerical display and the transmitter
frequency
information, displayed on non-RDS radios, is then only
used,
in the background, by an RDS radio. All this has become
possible
by the using, for many years, microprocessor controlled
PLL
tuner technology, permiting a radio to be retuned within
milliseconds.
During this process the audio signal is muted which because
of the
short time is usually not detected by the ear. Thus, the
radio
is able to choose the transmitter frequency, among a number
of
alternatives, that gives the best quality reception.
It is also sure that the switch-over is made to exactly
the same
programme service by performing a kind of identity check
using
the programme identity (PI) code."
Travel information with RDS is possible using the Travel
Programme (TP) and Travel Announcement (TA) flags.
Information is broadcast for motorists, identified in
parallel
with the ARI system with the corresponding RDS features
TP/TA. But ARI is being replaced on a European scale,
so
it will cease after the year 2005. A more recent
development of RDS is the digitally coded Traffic Message
Channel (TMC) which is now planned to be introduced all
over Europe, within projects funded by the European Union.
However, present RDS radios are not yet suitable for RDS-TMC.
Once a radio is tuned to a programme service broadcast
within
a network, using the RDS feature Enhanced Other Networks
(EON)
additional data about other programmes from the same broadcaster
will be received. This enables the listener, according
to his choice,
to have his radio operating in an automatic switch-mode
for travel
information or a preferred Programme Type (PTY, e.g. News)
and
this information comes from a service that, at a given
time, does
not necessarily contain such travel information nor even
broadcasts
the desired programme type.
Many of the Hi-Fi home tuners or receivers at this IFA
implement,
apart from the usual RDS features (PI, PS, TP,TA, AF),
some of
the newer features such as Programme Type-PTY, Radiotext-RT
and
Clock-Time, displaying the time/date.
RDS is absolutely future proof and will not be replaced
by DAB,
at least until such time as when FM broadcasting ceases
to exist
and this, for sure, is not going to happen within the
next 20 years,
in spite of the breathtaking developments of the
new era of digital broadcasting.
Issue Date 05 November 1999
Copyright © 1997, 1998, 1999 EBU and RDS Forum. All
rights reserved."
FROM http://www.rds.org.uk/rds98/rds98.htm
==============
Also here is a page that discusses some of the uses of the *European*
system that uses much higher frequencies (1400Mhz) than our current FM
band.
Keep in mind that many of the sound and interference benefits do not
carry over to the IBOC system nor do the high data transmission rates.
http://www.worlddab.org/whatis.htm
===============
Here is a description of the RDS subcarrier data system that shows how
an FM signal is divided, good chart.
Note the unlabeled pip at 19Khz ... that is the "stereo pilot subcarrier"
signal that when present lights the stereo light and activates the circuit
that decodes stereo subcarriers (labeled "stereo bandwidth" in this chart).
http://www.info-telecom.com/rdstechnology.htm
Note the age of the technologies referenced here:
"Sub-carrier data transmission has been
used for many years,
notably by MBS (1979) which is exclusively
dedicated to the
paging application. It is the system
used particularly
in the USA and in some Eastern Europe
countries.
The RDS system (1984) drew on experience
from MBS and has
been extended to many other applications
(including paging),
becoming a multi-applicative protocol.
The RDS system also has a derivative
called RBDS
(Radio Broadcast Data System) which
is the adaptation of
the European RDS to the U.S. federal
standards due to the
specificities of the US car- radio applications.
All these protocol (RDS, MBS and RBDS)
could be treated
by the same hardware device,
only the software part is slightly different."
================
and
"RDS was invented in the UK to make it simpler
to tune your radio,
you don't even need to know the frequency.
RDS Radios have been available for nearly
ten years
and in the last three years have have become
standard equipment in
most new cars."
http://www.2-ten.co.uk/about/rds.html
================
Also ... (far more lucrative for broadcasters) you can send proprietary
information over a "broadcasting Local Area Network [LAN]" that is encoded
for paying users.
Broadcasters could charge trucking companies, grocery stores, companies
that do deliveries and mobile repair etc. a fee to send digital inforation
encoded just for their recievers to pick up the data from the "subcarrier"
of the broadcasters main FM Signal.
In fact, a case could be made that the whole desire for a wider subcarrier
signal via the IBOC argument is not to bring Digital Audio Broadcasting
to the masses ... but rather to expand the Radio Data System to compete
with those companies that had to BID for other frequencies in order to
sell paging and mobile data sending services.
A case could be made that the National Association of Broadcasters
is actually trying to get radio frequency access for data services WITHOUT
PAYING FOR THEM AS OTHER COMPANIES HAVE HAD TO, THUS USING THE TAXPAYER
FUNDED FCC TO IN-EFFECT STEAL ACCESS THAT OTHERS HAVE PAID FOR AND THUS
GAIN AN ADVANTAGE!!
They are quite blatant about it, calling it "The Radio Station within"(http://www.wduq.com/rdsdetails.html) and promoting it as "Using the FM radio subcarrier for wireless communication is easy and low-cost. CUE's North American geographical coverage is several times that of other paging and wireless data communications companies." (http://www.directories.mfi.com/embedded/ce/artic_03.htm) for paging and delivery of services that originally were restricted to AUCTIONED radio spectrum.
This gives them an unbeatable advantage over the other paging companies, since they don't have to site antennas because the "network which operates in 550 markets" uses the existing FM broadcasting facilities (which are NOT AUCTIONED, are FREELY included in the existing station's cost of ownership and liscensing! (http://www.Cue.Net/cuereceivers/cuepccard.htm)
"CUE offers the most extensive nationwide messaging in the United
States.
The coverage on the CUE network is approximately five times the
geographical coverage of any other paging network in America.
This extensive coverage results from the fact that CUE is the
only
paging company to use FM subcarrier to distribute it’s signals.
Our network of more than 600 radio stations covers more than
two
million square miles and 95% of the population of Canada and
the United States. CUE is the only paging carrier that
operates
it’s own network on both sides of the border and it’s North
American coverage is unequal in the marketplace.
Given it’s extensive coverage, CUE focuses its marketing efforts
on the long-haul trucking industry, as well as the railroad industry.
Today there are almost 170,000 subscribers using the network,
including all major trucking companies in the country.
The network covers over 50,000 miles of interstate highways.
To examine our nationwide coverage click here. To subscribe
to our services, please go to our on-line store. "
(http://www.Cue.Net/products_services/messaging_services.htm)
In fact, there are some religious broadcasters that USED to use the
subcarriers (as well as reading services for the blind, bilinqual services
etc.) that are being pushed off the air to make room for these new lucrative
paging and data delivery services.
Check out http://www.ldsradio.com/subcarriers.html
And they have had YEARS to act on this, even for AM broadcasters, the
FCC deregulated the use of the "excess bandwidth" (beyond what is necessary
for transmitting the audio you can hear on a normal radio).
http://www.ldsradio.com/subcarriers.html
Shows that AM broadcasters were allowed to use their subcarriers for
information unrelated to the broadcast content or control of the equipment
since 1964.
EXAMPLES OF EXISTING PRODUCTS:
http://www.info-telecom.com/produits.htm
http://www.scimitar.co.uk/system/index.html
http://www.hip.atr.co.jp/~eaw/minidisc/part_Sony_MDX-C670RDS.html