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Virginia Center for the Public Press: Radio Free Richmond Project
Links Galore!
Your favorite programming
and radio stations may be

Your radios ...
All turned to junk
By Government edict ...

Digital Audio will not restore lost listenership:

The National Association of Broadcasters (NAB) Commented to the FCC in their attempt to persuade the FCC to force their IBOC DAB standard on the US population and broadcasters:

"While the Commission seeks comment on alternative approaches for DAB in the U.S., NAB believes that Commission should focus its attention on IBOC DAB as the appropriate model for DAB. The transition to digital for terrestrial radio broadcasters must be made a priority as they face the advent of satellite digital radio service in the near term." Sony argues to the FCC in favor of a forced In (FM) Band On Channel (IBOC) Digital Audio Broadcasting (DAB) Standard:
"There are many emerging technologies that will offer broadband Internet access. Services for fixed applications will be offered by DSL technologies, Cable Modem, LMDS and satellite services at s-mKu- and Ka-bands. It is simply a matter of time before the wireless industry can offer broadband Internet access to mobile applications, using point-to-point or broadcast connections and directly compete with Broadcaster markets. It is therefore important for the Broadcaster to be given the opportunity to convert to digital in the near future."

"The players [of Internet Audio files such as MP3] themselves are offering high quality digital audio and are increasingly becoming a more desirable alternative, in some cases, to the limited variety of music offered on the radio. [italics addedby this website] This is, therefore, another reason the Broadcasting Industry needs to advance to a digital format and offer not only digital quality, but also an alternative pipe for the value-added services offered over the Internet."

The unstated but suggested logical statements here are:

  1.  That the REASON that satellite radio will provide damaging competition is that they are digital



    Is that (satellite or the Internet being in a digital format) in fact the reason that people will pay $10/month plus hundred$ of dollar$ for satellite (and computer) audio receivers ... is solely the fact that it is digital?

    Consider that:
    Duncan Radio Research shows a 12% "historically large decrease" in listenership starting in 1989. 

    Major Warning Signs for Radio


    Yesterday we told you analyst Jim Duncan's twin worries: "The way we treat our advertisers and the fact that an increasing number of our listeners are going away." Do you doubt they're going away? Here's a just-released 23-year Duncan's American Radio chart of mean APR (average percentage of the 12+ population using radio in any quarter hour, 6 AM to midnight). The entire decade of the 1990s hasn't been pretty==17.5 to 15.4 equals a 12% decline. At Monday's PaineWebber confab Duncan called it "historically a huge decrease." Villains? Higher spot loads (maybe 20+ units an hour), more canned programming and a lack of programming innovation. Solutions? Jim Duncan Prescribes a "commitment to localism" -- "Local operations, local research, local programming decisions, local promotion, local news and events."

    Text by Tom Taylor of M Street. Chart by Tony Sanders of Duncan's American Radio.

    First published in the 8 December 1999 edition of M Street Daily.

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    Duncan's research comments do NOT mention a lack of "near CD sound quality", but they DO mention "increase spot loads (ads) ... lack of programming innovation."

    Consider: The Internet was not a viable alternative for sound until about 1997.

    Consider: The CD was common in the early 1980s. The tape in the mid 1970s.

    Consider: Listenership picked up as citizens began discussions on talk shows ... and dropped off as inclusive radio talk show hosts like Larry King and Patrick Buchanan with interesting guests were replaced with cheaper bombastic shows (with  few to no guests to challenge hosts) like Rush Limbaugh and Dr. Laura.

    Consider: People are going to Internet radio, MP3 sites and bitcasting ... because the Internet provides more variety (and Sony even baldly said so above) where the LISTENER EDITS THE PLAYLIST, NOT DUE TO BETTER SOUND!!!

    None of these trend issues have to do with encoding methods and everything to do with CONTENT.

    To ban analog FM and reduce the number of stations recievable by consumers due to overlapping signals caused by 430kHz version of IBOC is akin to forcing all movies to include special effects and banning movies like "Blair Witch".

Digital encoding alone will not reverse the increasing irrelevance of the programming choices by the Big Broadcasters. 

Digital encoding will not alone create useful new content that the public is demonstrably interested in.

This indicates that the unstated logical item number one for the NAB's support for Digital Audio Broadcasting is FLAWED. 

  1. Unstated logical assertion number two is that one of the reasons that the consumers and citizens of America pay taxes for regulatory bodies such as the FCC is to ensure constantly increasing profits for the regulaTEES ... at consumer and citizen expense if necessary!



    If you read the comments in the DAB-IBOC proceedings, a recurring theme is that the Broadcasters "need" the FCC to force this new standard on the American Public and furthermore that the giveaway in spectrum is necessary to remain competitive and furthermore that the existing broadcsters must get "replacement service" with DAB before any new entrants (competition) is allowed in!

    That would be like arguing in the 1950s that only existing AM stations be allowed to start FM radio stations ... and that the FCC must ensure that there is not enough room on the FM dial for new entrants to create competition! 

    To continue the analogy, it would also be like additionally requiring free spectrum be given to the braodcasters so that they can send phone conversations and data over a portion of their signal that is many times larger than the broadcast  portion ... and if they cannot compete with the phone companies on our spectrum for free , they will "take their ball and go home" (deprive us of digital radio).

    And even furthermore, only the largest broadcasters would benefit, since they would overlap the signals of smaller stations and thus only the large stations would have a solid "auxiliary" signal to sell subscription mobile digital data delivery services on.

    Joe McCarthy would have had a field day with that argument.

    BIA associates noted that in 1998, the average profits for large public radio ownership groups such as Clear Channel were running 35%-40%. Considering that the average Grocer earns 1% profit margin and most stockholders would be deliriously happy to achieve a 15%-20% return on investment, an assertion such as this from the NAB is a cruel joke to taxpayers at the least.

Therefore that unstated logical assertion number two 


Since it appears that the entire IBOC DAB process is founded upon these two assertions, it is very likely possible that the entire reason for Digital Audio Broadcasting is flawed and should be considered then only with much caution for its potentially deleterious effects on a Democracy that counts on a "Free Press" that is free of domination by ANY particular group of people, be that government, religious OR Corporate!

The large radio  chains have fired the staff that would have created that programming innovation that the Internet, community and satellite radio are now creating.

Trying to "fix" a programming problem with technology is like putting special effects on a bad movie and then trying to ban the indpendent productions like "Blair Witch".

Even more amazing ... 

Sony themselves said in the IBAC proceedings (docket 99-325):

"The players [of Internet Audio files such as MP3] themselves are offering high quality digital audio and are increasingly becoming a more desirable alternative, in some cases, to the limited variety of music offered on the radio. " AND "Sony has seen a very slow market penetration in Europe with DAB, which employs the Eureka-147 standard. The disappointing ramp-up is attributable to a service that offers little more than improved audio." THEY EVEN REPEAT THIS ADMISSION: "In Europe, Eureka-147 sales have been very slow. This is largely due to there not being enough incentive for consumers to buy a more expensive radio for simply getting digital quality and very limited data services. " AND MOST TELLINGLY: "... needs to be more of an impetus for the average consumer to adopt DAB. This impetus is either derived from a variety of new channels or new value-added services. S-DARS in the U.S. has chosen both methods. A value-added service offered by S-DARS, as an example, is commercial free radio broadcasting." AND THE FINAL BLOW: "Sony also recognizes the potential benefit of a fixed analog "sunset" date to foster a transition to an all-digital service and, believes one should not preclude the other. In fact, both may be necessary to stimulate the market to fully adopt the digital transition. " Sony is as much as admitting that few will buy in unless forced to by taxpayer funded government agency edict! Only then would we abandon our Billion$ inve$ted in analog FM receiver equipment.

Technology Investor magazine in discussing Worldspace (the Satellite Direct radio service already implemented in South Africa) said, "The only complaint: customers want more radio stations, more niche stations."

So WHAT potential benefits is Sony referring to when they demand "encouragement" of the purchase of their products?

If you look at Duncan American Radio analysis, there is no mention of a desire for "near CD quality" nor for the banner ads and artist IDs proposed as a variant of the Radio Data Systems (RDS) style radios that have already been available since 1979 and have always been a crashing market failure!

And what is "near CD quality"? Lucent cites in appendix F.1 of their 99-325 comments that:

"...result of the first test indicates that audio compressed by the FM IBOC system has a quality rating of 4.23 which is better than best FM (4.05) by approximately 0.2 points on the MOS scale. ... the CD source [on the MOS scale is (4.32)]." When that slight an increase in sound quality (mostly in reduced noise) has to compete with road noise, wind noise, office noises or is on a walkman or a clock radio ... would anyone notice or care enough to spend hundreds of dollars and lose access to the only station that had their favorite programming? Significantly, roughly 20% of listeners can only find their desired programming on smaller noncommercial stations.

The NAB stations have largely fired the staff that would have created that programming innovation or Sony's "variety of new program channels" and show no sign of rehiring.


Sony again in the same proceedings (FCC Docket 99-325) commentary state:
Page 5:

"Today's technology will permit a spectrum efficiency of between 0.7b/s/Hz and 1.5b/s/Hz. With a 200kHz bandwidth, data rates between 140kbps and 300kbps are achievable. With PAC or AAC, near CD quality at 64kbps should be possible with enough link margin. However, in order to attract customers, CD quality at 128kbps (MPEG AAC) and a limited data capability is preferred. This still translates to a bandwidth of between 100kHz and 200kHz. Sony believes, however, that bit rates of 64-384Kbps are required to add enough value to attract customers to this new technology. The exact rate depends on whether the service would carry text, a still picture or moving picture. This additional bit capacity would require a frequency bandwidth between 200kHz and 400kHz, which is equivalent to what is offered by the all-digital system. If these rates are attempted at narrower bands, the system becomes too susceptible to frequency-selective fading and compromises robustness."

"AM which offers a bandwidth of less than 9-10 kHz should accommodate FM quality audio and a very limited auxiliary data service. However, full stereo quality will not be available with a 9-10kHz bandwidth. A frequency bandwidth between 18-20kHz would be needed, given today's audio coding technology."

There it is, from Ceasar's mouth himself, DAB is a market flop, and they don't need any more than perhaps 40kHz of bandwidth to create Digital Audio anyway! So  why do they claim to need 430kHz of bandwidth?

This leaves then the only reason that they would need so much bandwidth (the excess signal that would stomp your favorite station's signal) is the proposed "auxiliary services" ... such as ... wireless data delivery like the Subcarrier  based Radio Data Systems products that have been available since 1979 ... and have always been a market flop. Or perhaps they plan to create a subscription-only DAB variation of CUE Corporation's SCA-based voice beepers ON YOUR AIRWAVES THAT USED TO CONTAIN YOUR FAVORITE  PROGRAMMING!

If then Digital will save the Big Broadcaster's bacon, let them try it within the 137kHz of excess broadcast capacity already provided within the 200kHz of the presently legally allowed bandwidth!

FURTHERMORE, with the advent of "Flash BIOS" technlogy (seen most commonly in V.90 modems) NO MANDATORY STANDARD IS NECESSARY.

The FCC could simply require that all DAB recievers mush have a Flash BIOS with a standard upgrade code that can even be recieved through the antenna for immediate on-the-fly-upgrades to new digital CODECS as our ability to compress audio digitally improves.

From that point forward it is up to the builders and purveyors of Digital Audio to make their case in a marketplace and for us to freely choose or refuse.

Free Radio Network

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contacting your FCC Commissioners

Thank-you for reading all this 
and considering helping us 
create a radio dial as diverse 
as the population that listens 
and pays taxes to regulate it.

Contact Information
for Congress HERE

Virginia Center for the Public Press
1621 W Broad St.
Richmond, Va. 23220
This is an effort to ensure that the public's airwaves are kept open for the benefit of all, not just the beautiful, rich or popular.

This site is designed to address efforts by a powerful minority to bend public policy to their aide and benefit at our expense and loss of liberty and access to the many voices of a healthy Democratic Republic.

The Basic Plan: Force  a new standard for Digital Audio Broadcasting (IBOC-DAB) * that destroys the remaining stations that have resisted consolidation including any new LPFM stations that are started.


Please call your Congressmen and Senators ... make sure they know you know that you want to hear your favorite station on the radios you already own! 

Your Congressmen
and Senators
by ZIP Code HERE

Ask your Federal Representatives and Sentators to send a letter to the FCC Commissioners that we must:

1) Keep the FM dial FM
 (no "mandatory sunsetting" [prohibition] of affordable analog FM broadcasting)

2)  We want access to more choices in program values and sources [stations], not less.
Tell them to tell the FCC not to force a new standard for the FM dial for Digital Audio that will block your ability to hear the LPFM and smaller stations.

3) Help Digital Audio find a third separate "Digital Band" just as we moved FM to a different band from AM in the 1950s.


* What is "IBOC-DAB"? ("In Band On Channel--Digital Audio Broadcasting")

Digital Audio Broadcasting sends the sound out coded the same way a fax machine codes a picture, as little blocks that are "on" or "off" (the binary language of computers and other digital devices).

In Band On Channel describes where that digital signal is placed, in this case IN the FM BAND and centered ON their original signal  center location "CHANNEL"  on the FM dial.

If you drive up toward Washington DC and tune your radio to 106.5, then get within 20 miles of the test IBOC-DAB station, WJFK 106.7 in Alexandria, Va., you will hear a "buzz saw " sound, that is the digital carrier of the on-off-on encoded signal.

IBOC-DAB claims:
1) Better sound (actually, less noise)
2) More robust signal (like your PCS cellphone)
3) The ability to put banner ads and weather maps or traffic wreck warning maps on a display on the radio faceplate. 
Don't stare too long while driving or you're the next car wreck mapped!

There are those who claim that your favorite station is threatened by the NEW Low Power FM service stations ... what about that?


Time Is Fleeting ...
1) "Goliath" will now 
attempt to kill Community Radio with the Digital Radio Farce.

First the monopolists will have to kill the Low Power FM radio stations that might use some of the spectrum they need to kill your favorite station!

They will do this by passing laws against the recent FCC decision to create LPFM stations:


[VCPP Testimony on HR3439]

[Resources on "Beeper Network" issue]

[Dr. Rappaport's Testimony to HR3439]
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A stable society 
is an inclusive
and just society.

Community radio is designed to encourage 
a diversity of cultures represented on the airwaves 

by encouraging a diversity of ownership/control. 

A diversity of people and organizations 
with different values and priorities 
will create a more inclusive media 
(and therefore government policy) 
because they will have different definitions 
of what is “newsworthy” and “viable” 
for sharing on the public's airwaves.

Index of documents
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well as the hundreds 
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A healthy democracy hears from everyone, not just the beautiful or profitable people.

 WHY doesn't the 
"Almighty Market"
 Serve Everyone?

Media is the 
lifeblood of 
a Free Society",

Newt Gingrich, 1994



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Thomas Jefferson

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