Further Study of FM IBOC & FM SCA Compatibility

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May 24, 2002

Marlene H. Dortch, Secretary
Federal Communications Commission
Office of the Secretary
445 12th Street, SW
Washington, DC 20554

Re: Digital Audio Broadcasting Systems and Their Impact On the Terrestrial Radio
    Broadcast Service, MM Docket No. 99-325
    Further Study of FM IBOC & FM SCA Compatibility

Dear Madam Secretary,

Pursuant to the Public Notice (DA 01-2932), dated December 19, 2001, in the abovereferenced matter, National Public Radio (NPR) and the International Association of Audio Information Services (IAAIS) respectfully submit the attached “Further Report on Analog SCA Compatibility with iBiquity’s Digital FM-IBOC System.”

NPR, IAAIS and the Advanced Television Technology Center jointly crafted the
parameters of the study with the active support of iBiquity Digital, which generously funded the effort. iBiquity Digital has separately filed the data from the further tests with the Commission.

Using the study’s data, NPR contracted V-Soft Communications to prepare a visual
representation of the likely real-world impact on Radio Reading Services of adding
iBiquity’s FM system to all stations within the top 16 radio markets. NPR and IAAIS express appreciation to iBiquity Digital for the funding and support without which the underlying testing would not have been possible.

NPR and IAAIS stand ready to assist the Commission in considering the technical and policy implications of the study’s results in the referenced proceeding.
Respectfully submitted,

/s/
Michael Starling, Esq.
VP for Engineering & Operations
NPR
 /s/
David Andrews
Chair, Technology Committee
IAAIS

 

c: Albert Shuldiner
VP & General Counsel
iBiquity Digital Corporation
Columbia, Maryland

 

David Wilson
Secretariat, NRSC
Consumer Electronics Association
Arlington, Virginia


Executive Summary


During 2001 the National Radio System Committee (NRSC) conducted tests to evaluate
the compatibility of iBiquity Digital’s FM IBOC system with analog subcarrier (SCA)
operations. National Public Radio (NPR), and the International Association of Audio Information
Services (IAAIS) represent members who operate SCA analog facilities. The IAAIS represents
over 100 radio reading services for the blind and print-disabled. NPR provides programming and
representation to over 640 public radio stations, many of which operate SCAs. Reading services
in thirteen of the top sixteen radio markets utilize subcarriers of NPR member stations.


During NRSC deliberations, NPR and the IAAIS noted the inconclusiveness of test
results concerning analog SCA compatibility with IBOC transmissions. The parties suggested the
need for additional data points to achieve greater resolution and a better understanding of the
likely interference consequences to analog SCAs of a mass deployment of IBOC transmissions in
the FM band. Additional information was sought to analyze the effects of IBOC transmission
on subcarriers operating on different frequencies (e.g. 92-kHz vs. 67-kHz) and design variables
affecting the relative susceptibility or immunity of different SCA receivers.

iBiquity Digital volunteered to fund further tests to help resolve these concerns and
sought to conduct the tests as expeditiously as possible for their consideration by the FCC
during the current comment period on terrestrial digital radio. IAAIS provided ten SCA receivers
believed to be representative of those currently in use. iBiquity, IAAIS, NPR and Advanced
Television Technology Center (ATTC) staff, as well as outside consultants to all parties,
collaborated in shaping test criteria and observing the tests that were performed by the ATTC
during February and March 2002. Additionally, multipath issues were raised as a significant
factor affecting SCA performance and additional work was done to analyze the audible effects of
multipath on SCA performance. The ATTC’s documented test plan and summarized test results
were included in iBiquity Digital’s filing before the FCC on this matter dated 13 May 2002.

At the conclusion of testing, NPR contracted with V-Soft Engineering of Cedar Falls,
Iowa to model the results in the top sixteen radio markets using Longley/Rice propagation
predictions and incorporating predictions from the test data about SCA analog receiver
performance. In addition to revealing areas and populations where terrain effects would limit
reception, areas and populations were calculated and plotted where coverage would be limited by
existing analog adjacent channel interference, as well as the areas and populations calculated to
lose coverage due to new IBOC interference (assuming all 1st and 2nd adjacent channel stations
were transmitting IBOC signals). The performance characteristics of the SCA receivers were
fairly closely grouped, and an average of their performance was used in generating the predictive
impact maps. The coverage studies were projected to extend to the 54-dBu contour, based on an
assessment that few SCA receivers are in use beyond this contour without the aid of outdoor
antennas or cable FM input. This assumption was tested for four markets where actual SCA
receiver distribution was available by Zip Code. These maps are included as Appendix A.

A tabular summary of the raw population counts within the projected SCA reception
areas, the areas and populations delimited by existing analog interference, and the new areas and
populations projected to be interfered with by the addition of FM-IBOC is included as
Attachment B. Pie-charts representing these effects on the populations of each of the markets
studied are included as Attachment C.

On average, the added IBOC-interference effect, based on population, was projected at
2.6%. This figure varied considerably, from as low as 0.3% in markets with relatively flat terrain
and high transmitter power and antenna height to 8.5% in the Los Angeles market on station
KPCC. In general, lower power stations suffer greater interference, both from adjacent analog
stations, as well as from new potential IBOC interference.

There appeared to be no discernible distinction in the susceptibility of 92-kHz SCA
receivers versus 67-kHz receivers. Additionally, second adjacent channel interference contributed
the bulk of interference attributable to IBOC operations. Apparently, first adjacent channel
IBOC interference was effectively “masked” by the analog interferer, whereas IBOC energy
added to second adjacent station’s signal contributed a measurable increase in undesired signal
competing with the capture of the desired SCA signal.

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