In 2015, four of the ten highest billing radio stations in America were on the AM band totaling approximately $167 million. For sure there are many others across the country not doing well. AM broadcasters have been asking the FCC for technical help, for what seems like a decade, as the digital world of crisp clean listening picks listeners off year after year. This with the MMTC sent a letter to the Trump administration asking the new government to decommission the AM band. We turned to broadcast attorney John Garziglia to get his opinion on that plan. Here’s what he had to say and check out the comments we received on our story yesterday
By John Garziglia
One of the funniest things I ever read about AM radio was from a trade publication spoof distributed at the 1988 Washington, DC NAB radio convention titled “Outside Radio” which, as its lead article, declared:
NAB DEDICATES MONUMENT TO AM RADIO TO OPEN CONVENTION. Dubbed “The AM Memorial”, monument is actually a hole in the ground as deep as the nearby Washington Monument is tall. Passersby will be invited to throw money into it so they can watch it disappear, giving them the exact feeling of owning an AM station. Later in the spoof publication’s Radio Glossary there was the definition: “AM: (n) Almost Moribund”.
Now, some 28 years later, the MMTC is asking in a letter to President-Elect Trump that the AM band be decommissioned.
There is no question but that there will be a multitude of AM stations facing failure in the next several years. Times change – radio listeners are no longer willing to schedule their listening for daytime only, and AM band noise levels have reached extraordinary levels.
But, the MMTC “ask” for the FCC to “Create a ‘Glide Path’ for the Short-Term Survival and Long-Term Humane Decommissioning of the AM Band in a Manner that Preserves Minority Ownership” is both misguided in its AM broadcasting prognosis, and also tone-deaf as identity politics is expected to play a lesser role in governmental policy with the change in administrations that is about to occur.
MMTC asks the FCC to “start thinking about a future without AM radio”, and assistance for AM station owners to transition “to other platforms such as FM subchannels and online stations.” MMTC also asks for “ownership structure rule relaxation for the limited purpose of ensuring that [AM] station sellers will find buyers, and compensation or tax incentives for turning in an AM license.” It is unclear from its proposal how a “future without AM radio” comports with “find[ing] buyers”.
MMTC advocates that the FCC “identify potential uses of the low-band spectrum now assigned to AM, such as maritime mobile, aeronautical fixed, and aeronautical mobile, as well as exploring new potential classes of users such as drones, driverless vehicles, rural irrigation, and the Internet of Things (IOT).” Unfortunately, if what is now the AM band spectrum could be advantageously used for any of these applications, that is news. MMTC does not cite any support for the proposition that the AM band might be used for any of these alternate purposes.
Rather, the future of the AM band, while challenging, is certainly not impossible. AM radio continues to be the one non-subscription consumer radio service that can reach the vast rural areas of our country, both with the tremendous groundwave coverage enjoyed by our higher power stations, and the nighttime skywave coverage from clear channel stations.
All-digital HD AM has a tremendous potential to resurrect reception quality for those AM stations that enjoy a robust consistent day and night coverage. The hope is that, at some point in the next five years, HD radio penetration into automobiles will reach a tipping point where a significant number of potential radio listeners will have HD AM radio receivers. At that point, an AM station that is also carried on an FM translator may be able to transition to all-digital transmission without abandoning at least a portion of its non-HD radio audience.
MMTC is right in observing what our industry has known since well before the 1988 Outside Radio spoof was published – AM radio station ownership is a challenge and will remain so for the foreseeable future. If other more profitable uses can be identified for the AM band spectrum, then bring it on. If congestion and interference reduction on the AM band can be accomplished by regulatory measures such as encouraging the turning-in of marginal AM station licenses, then let’s explore that. And even though solving the increasing harmful AM band ambient noise level issue carries with it a difficulty akin to tackling global climate change, if there is a way to reduce AM band interference, then by all means let’s push the FCC to pursue it.
For now, however, significant players in our industry such as MMTC proclaiming the death of AM by positing contrived solutions for “when the AM band disappears” is an undeserved obituary for the many AM broadcasters who continue to operate successful radio stations in our senior band.
John F. Garziglia is a Communications Law Attorney with Womble Carlyle Sandridge & Rice in Washington, DC and can be reached at (202) 857-4455. or [email protected]