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Comments on the IBOC (In Band On Channel) DAB (Digital Audio Broadcasting) proposal:

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 itís 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
 itís own network on both sides of the border and itís North
 American coverage is unequal in the marketplace.

 Given itís 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
 
 

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