Chapter 9 COMMERCIAL DEMANDS ON SCA'S (FCC & Others vs RTB) Update note: Upon the original preparation of this material, FCC decisions regarding several proposals for commerical, and other, uses of the SCA channels of Public FM Broadcasting stations had not been reached. Although the decisions of the FCC on petitions Nos. 82-1 and 82-536 have now become law, the following material has been left in its original form so as to provide a solid foundation on which to fully understand these issues. The FCC's decisions, and their effects upon "Radio Talking Book" services to blind people have been included at the end of this chapter. I suppose it is just a fact of human nature that if someone invents "a better mousetrap", someone else will try to "make a buck" out of it. Such a situation can, and does, exist with the SCA channels we need to deliver our Radio Talking Book services. Not that I can, or am, claiming that we, by any means, "invented" the SCA. We merely recognized it's existence and learned how to use it very effectively. There is little question that our well known success in using SCA inspired others to consider alternative applications. Muzak and other background music services uses of SCA, of course, preceded us by about 14 years. Their interests were for a different technique of SCA operation than ours, and being a commercial enterprise they could not utilize the SCA channels of "Public Radio" stations whose SCA's have been required to be used as educational and non-profit operations (F.C.C. rules 73.593). Therefore, our historical relationship with Muzak has been one of helpful sharing of information. Since our Radio Talking Book services are not restricted from also using the SCA's of commercial radio stations, it is possible we could have had a conflict of interest with Muzak. However, they are so well established, and we are so poor, that no serious competition has ever occurred to my knowledge. Other commercial interests have "raised their ugly heads" recently, however. And they definitely do present a very serious threat to our future ability to provide Radio Talking Book services. QUADRAPHONIC FM (Does Anyone Really Care?) In order to understand "Quadraphonic FM" you must have some understanding of stereophonic (sometimes termed "Bi-phonic", for two channel sound by engineers). I believe nearly everyone today understands that audio reproduction can be done as a single channel (speaker) system which is called "Monophonic", or it can be presented over two channels, one on the left side and one on the right side in front of the listener, called "Stereophonic". Stereophonic is essentially just two monophonic systems used simultaneously. The concept of "stereo" is that by recording an event from the perspective of sounds on the left and also the separate perspective of the sounds #n the right, and then reproducing these two sound sources in correct perspective to each other, the listener will more realistically perceive what the original event sounded like. Although this technique is not able to accurately recreate the sounds of the original live event (from a technical analysis), it does an admirable job of pleasing it's audiences. It also was soon discovered that the audiences were usually even more pleased if this "stereo" presentation was very exaggerated rather than attempting to be as accurate as possible. This leads us into the world of artificial "electronic music" that we suffer today. But, not only did people like the effects of stereo, it also presented the electronic equipment manufacturers with the quite literally "golden" opportunity to sell everyone what amounts to being two monophonic high- fidelity sound systems under the label of "stereophonic". Naturally it quite quickly became a very well established standard. Radio broadcasters "had to have it too", they pleaded to the FCC. The FCC authorized FM broadcasting of stereo on June 1, 1960 and AM broadcasting in stereo this year (1982). (There is a vast difference in performance quality of FM and AM stereo, but that's another story.) Note that prior to the FM stereo authorization the FM stations baseband, which occupies to #lOOKHz of spectrum space, utilized information fre- quencies of only 15KHz. This allowed placing SCA subcarriers anywhere between 15KHz and 75KHz so long as they didn't interfere with the "main channel" programs or each other. However, if the FM station elected to engage in stereophonic broadcasting it would now utilize frequencies up to 53KHz which greatly reduced the available space remaining for SCA activities. Although a specific SCA frequency has never been assigned by the FCC, the use of 67KHz as the SCA subcarrier frequency has become a de facto standard. Some "audiophiles" who realized that the sounds we hear at any live event do not come to us just from the front(on the left or right sides), reasoned that more realistic reproduction would result with the use of more sound channels than these two which are used for stereo. Thus, "Quadraphonic" (four channel sound) was born! It was determined that if a listener was placed in the middle of four sound sources, a conventional stereo system in front of him and another one behind him, he would be able to perceive more correctly all the sounds around him as he would have done during his presence at the original live event. (Not only that, but now the equipment manufacturers can sell you two stereo systems! -- Does that sound cynical? OK, I'll admit to being slightly biased, but I'll try to keep my personal opinions of the value of this idea to myself for now.) The "Hi-Fi" audio industry was deluged with several methods of creating Quadraphonic sound reproduction. The electronic manufacturers became quite excited about this "future in sound" as did a good number of the more "far out" audiophiles. The majority of the buying public, on the other hand, greeted this revelation of the audio industry with an un- stifled yawn. Also, the "Hi-Fi" consumer electronic equipment dealers found that it was very ackward and difficult to demonstrate the "wonders" of quadraphonic performance, so they quickly lost the attention of their possible customers, and soon thereafter, they too lost interest in the whole idea of "Quad". Industry is not so quick to abandon a potentially profitable idea. Having failed in the consumer audio market, they turned their attention toward FM broadcasting. After all, when "stereo" was "hyped" by the FM broadcasters, and then soon the only FM tuners available to be purchased by the consumers contained "stereo" capability, the stereophonic system became almost an overnight success. Why not push "Quad" via FM radio?, they reasoned. But, they had problems to reckon with. First of all, there does exist a method of sending quadraphonic information over FM radio that doesn't require any approval changes by the F.C.C. This method is termed "4-2-4" (more about that soon!)but it wasn't any more popular than any other of the consumer quadraphonic audio offerings. Secondly, to "hype" a so called "better idea" for quadraphonic, they needed to get the F.C.C. to change the use assignments of the FM broadcast stations. Thus, they proposed "4-3-4" and "4-4-4" quadraphonic systems be allowed to be broadcast. The F.C.C. observed engineering studies and tests, then issued a "Notice of Inquiry" followed by a "Notice of Proposed Rule Making" to authorize these quadraphonic FM broadcasts. So what, you say? What does any of this "fascinating stuff" have to do with our Radio Talking Book services on FM SCA? We11,4-4-4 wants your chan. nel, and 4-3-4 might increase interference to your services, that's what! But, what is "4-2-4; 4-3-4; and 4-4-4"? This is a simple numeric method of describing the quadraphonic basic technique of transmission. Each number represents the number of electronic channels utilized. The first number is what you start with, the middle number is how many channels you use to transmit it, and the last number is how many channels you end up getting back to use. Very simply explained, all of these are methods that include the sounds to be reproduced behind the listener (back left and right) by adding a rear stereo audio system. In the "4-2-4" concept, this "rear" information is contained within the usual front stereo sounds through a technique which engineers term "phase encoding". This method does not change the bandwidth needed by the audio program materials, sounds "normal" if not decoded from stereo into quadraphonic, and therefore, can, and has been, broadcast by any FM radio station without either transmitter or F.C.C. rule changes required. The proponents of 4-3-4 or 4-4-4 would argue that 4-2-4 does not have "good enough" quadraphonic realism. It is true that there are some "errors" which occur in 4-2-4 but it is perceived by many, if not most, observers as being highly acceptable. The 4-2-4 system has an additional value going for it. It delivers the best "signal-to-noise" performance of all the systems and it is the most likely to make it correctly from the radio station's studio to the listeners speakers in the same form as which it was sent. The SCA channel is unaffected by this quadraphonic operation. The 4-3-4 system proposed to send the new rear audio information channels of quadraphonic as a new subchannel to be broadcast by the FM radio station. This method would "combine" the quadraphonic information with the current stereo information subchannel now being broadcast. The stereo subchannel, which lies between#23KHz and 53KHz, would still exist but in addition, new quadraphonic information would be added by a technique we engineers would term "phase quadrature". This system has the potential of giving better quadraphonic effects, say the supporters of it, because it is mathematically possible to correctly derive 4 channels of discrete information from 3 channels of encoded information. For the SCA users this system must be viewed with some caution. Some of the 4-3-4 proponents would also like to place "tone carriers" at frequencies such as 57KHz. The presence of such "tones" could/would impact seriously upon the Radio Talking Book SCA operations. In addition there is some question yet as to the actual interference levels which would occur to the SCA operations from the 4-3-4 transmissions. Theory predicts no interactions, however, real electronic hardware, especially consumer quality equipment, and the vagaries of nature, etc., often produce results which seem to contradict theories of physics. So even though there may be good reasons for me to feel that this proposal may not have significant detrimental effects upon the SCA operations, I continue to take a position of skepticism until such time as "real world" effects from it could be observed and much better understood. This brings us to the 4-4-4 quadraphonic proposal. As it's numeric designation implies,this system of quadraphonic FM broadcasting would use four channels of transmission. They propose the present stereo channels as two of them, the "in quadrature" additional channel in the stereo subchannel spectrum as per the 4-3-4 proposal, and then the addition of another subchannel to be placed at 76KHz. This additional subchannel would occupy from 61KHz to 91KHz. Two facts are immediately apparent. One; the SCA's now used at 67KHz could no longer exist. Two; the occupied spectrum (out to 91KHz) exceeds the current FCC legally authorized limit of 75KHz. Therefore, the proponents of this system argue that with four transmitted channels of information to convey four channels of audio to the end users, their system would be the most accurate in quadraphonic realism. (Not necessarily true!) And thus, the FCC should expand the station's occupied spectrum space. To those of us who object to the loss of the SCA service, they present two "solutions". One; the FM station won't HAVE TO operate in quadraphonic if it doesn't wish to. The stations can decide whether the SCA services or the profit advantages of using quadraphonic are more important to them. (Guess who's going to win this decision?) Secondly; they argue that the FCC could authorize the FM stations occupied baseband to be extended not to 91KHz but to 99KHz, thus leaving a space at 95KHz to include an SCA service. What they won't admit to is #that an SCA moved from 67KHz with 16KHz of bandwidth available to it compared to one at 95KHz with 8KHz of bandwidth is not reasonable, practical, nor even legally possible for use with speech transmissions such as Radio Talking Book services. My very extensive examinations of this proposal leaves no doubt at all that such an SCA service, if it even could exist with quadraphonic programming present (which I strongly doubt), would be so limited in both fidelity and/or effective distance coverage range that it would be useless for any purposes other than digital data transmissions. I believe that if the FCC decides to authorize this 4-4-4 form of qua- draphonic FM broadcasting that it could very likely be the end of SCA services of speech or music in this country. That this would be true depends upon two events; (1) The stations would chose 4-4-4 over 4-2-4 or 4-3-4 because of a perceived superiority. (2) The consumer equipment manufacturers flooding the market place with quadraphonic FM radios as they did with stereo. The competitive nature of broadcasting demands that if any station is doing something perceived ("hyped") to be more "modern", then every other station feels compelled to do it too. In fact, although 4-4-4 quadraphonic can be shown mathematically to produce more "accurate" quadraphonic results than either 4-2-4 or 4-3-4, the truth is that under most conditions of FM reception even stereo is not very accurately reproduced and the wide bandwidth needed for 4-4-4 quadraphonic will seldom be recovered with sufficient faithfulness to allow this theory to be experienced in practice. Also, the "signal-to- noise" performance of this system is the worst of all the proposals. We still await the decision of the FCC, who have recently been of the mood to let broadcasters "do what ever they want to". I certainly hope that either the FCC will be wiser than that in this case, and/or the public will remain so disinterested in using FM quadraphonic that they will not buy it if it does become authorized. I doubt if many people really care. Incidentally, quadraphonic sound can be quite "interesting". It belongs on tape or digital audio systems where it can be done correctly!! It should never be transmitted over a weak transmission link like FM radio!! (I am, admittedly, a bit of an "audiophile" myself -- but a rational one!) UTILITY LOAD MANAGEMENT (Power Companies Would Like Your Channel!) The FCC's authorization of this activity has recently become fact for the commercial FM broadcasting stations. FCC authorization of this on "Public Radio" FM stations is still being considered, in another form! "Utility Load Management" is a concept of the electric power industry by which they can switch on or off customers equipment (such as "hot water" heaters) to control the amount of power they need to generate at any moment. The power industry makes some pretty good arguements about how energy inefficient it is for them to have to generate for large short-term peaks in power demand by it's customers. They argue that they will conserve this nations energy supply if they are allowed better means to manage customers electrical loads, such as through access to and use of SCA's of Fm broadcast stations. (They've requested AM stations and other H.F., V.H.F., and U.H.F. services as well.) Somehow, the cynic in me makes me wonder if they are really concerned about our nations energy, or if they're not just concerned about what it costs them to construct additional generating plants! Well, whatever their motivations really are, it is curious, to me at least, that in spite of our arguements to the F.C.C., that a whole SCA's channel use was not required to accomplish this purpose, they still wanted the whole channels use. The FCC supported their request and so authorized this form of operation. For you who may be less familiar with FCC rules 73.293 and 73.593, I should clarify this discussion by explaining that these rules, which describe the authorized uses of FM broadcast stations SCA's, specified that the use of the SCA was to be of a "broadcast nature". Controlling equipment for load management purposes is, of course, a non-broadcast use -- therefore, these rules had to be changed to allow such operations. When the FCC approved the rule change for commercial FM broadcasting stations (73.293) they agreed that this service of load management did not require full use of the SCA channel services, but they didn't wish to "restrict" the future ideas of the utility industry. The FCC also decided that there were too many other questions about the commercial aspects relating to "Public Radio" FM broadcasting stations to allow modifying ruly 73.593 at this time, so this operation has not been authorized for those stations; yet! Why doesn't utility load management need the full SCA channel? Because since it is a fairly infrequent switching function it can be done as digital data transmissions at a quite slow rate. These commands CAN be included on an SCA as sub-audible signals, so the usual listeners of the SCA would be unaware of their existence. Also - for very brief moments, the SCA could be interrupted to send these command tones. None of us like interruptions, of course, but they would be very brief in this application and it would be far better than giving them the channel for what amounts to an infinitely long interruption instead!! The other fact is that FM SCA is really a "crummy" vehicle for what these utility companies want to accomplish. I sincerely believe they may most likely make little use of it. It seems like the strategy was for them to ask the FCC for everything they could think of all at one time. I believe that what they really wanted was the use of AM radio stations, not FM so much. They also got AM. - But, the new recent rules which authorized AM stations to broadcast in stereo may make utility load management over AM radio stations impractical. So, the situation is that as an SCA user, you could include these utility management signals with your programs at some slight loss of "signal-to-noise" of your service, or you could let them interrupt your programs briefly now and then, or you could give up and give them the SCA channel. It all will come down to which one of you can afford to pay the most for the SCA, I believe. I doubt that most Radio Talking Book services can outbid the electric power industry! Oh, but wait, that "outbidding" only applies to commercial broadcast stations. "Public Radio" (Educational non-commercial) cannot sell SCA or any other services for a profit, according to that FCC rule 73.593 --- right? Right! But! Well, read on--: THE COMMERCIALISM OF PUBLIC RADIO SCA ("What's It Worth To Ya?") First of all we all know that every "Public Radio" station which charges virtually anything for the SCA is doing it as a profit making service. The actual cost involved in carrying the SCA channel on the FM station is nearly non-existant. Of course, the station managers will "dream up" all sorts of rationale for it's cost, but the fact is that once the hardware is in place (much of it usually paid for by Federal grant money such as NTIA), the operating expense is "nil". Also, the cost of that required hardware seldom reaches, or exceeds, $4,000.00 total. But, we need them - and they need us - so it's a mutually beneficial arrangement for us both to pretend that "costs" of $500.00 to $1000.00 per month must be met. The commercial FM stations don't suffer from such restrictive illusions. They just charge whatever the market will bear, which is closer to $2,000.00 to $5,000.00 per month, and has absolutely no relationship to their imagined cost to provide SCA service. But, now a new concept regarding SCA costs has emerged. BROADCASTING AMENDMENTS ACT OF 1981 (Governments Good Intentions "Run Amuck) Congress, being concerned with the reductions in Federal support money to "Public Broadcasting" passed Public Law 97-35. In that new law, Section 399B, they declared that "Public Radio" stations may seek renumeration (profit) from the use of their facilities so long as it did not "interfere" with the stations telecommunication services! This is to allow the educational non-profit organizations the right to use studio facilities for recording ventures, etc., to help themselves by raising some extra money to replace what their "Federal Uncle" won't be handing out soon. Good grief - the FCC then declared that perhaps this new law means that FCC rule 73.593 requiring "Public Radio" stations SCA's to be educational and non-commercial (like the main channel operation of the station) is not valid. Therefore, said the FCC, they are thinking of eliminating Rule 73.593 and replacing it with Rule 73.293! In other words, allow SCA's of "Public Radio" to be operated the same as those of commercial radio stations. If so, then "utility load management", "Muzak", and any other for-profit uses can be conducted by FM "Public Radio" stations too. Of course, I believe that the FCC is very ill advised and has completely misinterpreted what Congress intended when they enacted Public Law 97-35. In this action, just as in the "Quadraphonic FM" rule making action, we are vigorously attempting to help the FCC find their way back to reality and common sense. However, it is very frightening that such is not very easily accomplished nor is it very often successful once they have announced one of their "good ideas"! NEW SCA'S NEEDED (The Common-sense Solution) To help ourselves and everyone else have what they want we've proposed that new additional SCA channels should be authorized. Even though we do not believe that any telecommunication services of a "Public Radio" station should be other than an educational non-commercial public service, we do think that a reasonable common sense compromise is possible that will give all parties exactly what they want. Remember that the discussion of 4-4-4 quadraphonic mentioned a very UNUSABLE SCA had been proposed to be placed at 95KHz. Well, although that 95KHz SCA concept is unworkable, an SCA located at (or about) 92KHz (not with 4-4-4 quadraphonic, of course) could provide quite acceptable performance. Such an SCA channel would be about 3Db worse than the SCA now commonly in use at 67KHz. A 92KHz SCA also would be more subject to multipath cross talk and pulse type noise interferences than the one at 67KHz, and would require more careful receiver and transmitter design and adjustments. However, it still could be a practical service, albeit not as good as at 67KHz. I had actually proposed using 87KHz, initially, during my engineering research on the subject of quadraphonic effects, but then my friend and collegue, Mr. John Kean (formerly from N.P.R.) observed that 92KHz may be a preferable frequency due to intermodulation relationships which could occur. He might be correct in that view, although to date no one has fully evaluated this subject. He then also went on to conduct some field measurements to verify that this concept of a second SCA channel was in fact valid. Some engineers, and I am one of them, are naturally more cautious than others. I am not completely ready to "buy" 92KHz SCA's as being a completely practical concept. I strongly believe in the concept, in the mathematics and theoretical predictions, but I also know that it is a more "sensitive" system than the 67KHz SCA due to it's location further out in the stations baseband. I want to observe it in "real world" use more before I can comfortable fully endorse it's applications. But, what about that baseband limit! Like in the quadraphonic proposals, the FCC will have to agree to extend the FM station's baseband from 75KHz to 99KHz to use this proposed new SCA. Then, in addition, I believe that the FCC should authorize "Public Radio" FM stations to apply FCC rule 73.593 to SCA's at 67KHz and rule 73.293 to the new SCA placed at 92KHz. This keeps public non-profit SCA services protected on 67KHz SCA channels and allows "Public Radio" FM stations to also conduct "for-profit" SCA services on 92KHz SCA's. This, it seems to me, is a proposal from which everyone will win! THE FCC REACTS ("Nobody's Perfect!") On April 7, 1983, the Federal Communication Commission met to consider Docket Nos. 82-1 and 82-536, new rule proposals relative to FM broadcasting of SCA. During that meeting the Commissioners agreed to adopt Docket No. 82-536 essentially as it was proposed. In so doing, all FM broadcasting stations may utilize a newly expanded baseband. The previous limit of 75 kHz was changed to 99 kHz. In addition, the stations may use that portion of their spectrum space not used by the main channel for virtually any purpose that they choose. Eventually the FCC ruled that the FM Quadraphonic petition, Docket No. 21310, was made moot and was dismissed. The FCC Commissioners also agreed to adopt Docket No. 82-1, the commercial use of SCA by Public (Educational, Non-Profit) FM Broadcasting stations. However, they included considerable acknowledgement of the need to protect the Radio Talking Book services to blind and handicapped people. The Commission specifically stipulated that Public FM Broadcasting stations are "OBLIGATED" to provide for the continuation and the future development of these Radio Talking Book services. And, the Commission stated that although no station is required to use its SCA capacity, if the station did elect to make commercial use of an SCA then it must provide an SCA channel, on a not-for-profit basis, to serve Radio Talking Book service if so requested. Public FM Broadcasters must either reserve an SCA channel, recognize a priority status by Radio Talking Book services to use an SCA channel on their station, or provide some other alternative SCA channel for the transmission of this service upon request if the station engages in any commercial uses of its SCA capacity. In addition, if a move or a relocation of a Radio Talking Book service is desired by the station than, the station must pay the entire costs for any such moves. Additionally, the FCC ultimately decided to allow FM stations to increase their modulation levels, up to 115%, if engaged in SCA transmissions. This was to remove the perceived loss to the main channel performance that so many station managers felt occured, and therefore encourage more stations to make use of their SCA capacity. These FCC decisions are less than perfect for Radio Talking Book, but were probably the best that the Commission could do to fullfill their obligations to all parties and to the public. 1986 UPDATE However, now that a few years have passed since the FCC actions on these issues, some interesting results have occured. Most noteable is the demise of several Radio Talking Book services, and a dramatic decline in the rate of development of new Radio Talking Book services! Several sources have reported that they were met with disinterest by the Public FM station managers when they inquired about using an SCA of the station for Radio Talking Book service. The reason being that the station wanted to reserve its commercial options before considering any non-commercial Radio Talking Book operation. In addition, several Radio Talking Book services have found themselves confronted with a demand for increased charges for use of the SCA channel. Charges which rival, and in a few cases exceed, the charges for SCA lease on commercial stations in the same community. At least one of those cases will probably end up in a court action. The FCC policy and rules division is supposedly investigating this problem, but it has been going very very slo-o-o-o-w! The Association of Radio Reading Services has also filed a petition for new rulemaking with the Commission to address this problem. But as of now, November, 1986, no action has been forthcoming from the FCC. It is apparent that since the passage of Docket No. 82-1 many Public FM Broadcasting station managers have the impression that they can charge commercial rates to Radio Talking Book services for the use of their SCA channels. CLOSING COMMENTS: With ever increasing demands for innovative uses of SCA's, the commercial pressures on our "Radio Talking Book" SCA channels continues to rise. You must be aware of these actions and help to preserve and advance these SCA services to our listeners who are depending on people like us to deliver to them their entitlements. SCA has proven to be an effective means to deliver Radio Talking Book services to many blind or handicapped people who need them. However, it is becoming clear that SCA alone cannot fullfill the entire need throughout the nation. Not only are there not enough FM stations to deliver Radio Talking Book programs to every community, (don't forget, the SCA does not cover anywhere near the distance that the FM stations main channel does) but, in addition, most station managers do not want to allow the use of their SCA for this purpose. It is my belief that this important service will never fully mature, and expand to serve all the people in need and waiting for it, untill it becomes an independent transmission entity. I have proposed that a channel allocation for Radio Talking Book services in the 150 MHz to 300 MHz region is a necessity to meet these goals. That system should be an FM service, using upto 8 kHz of program audio fidelity, deviating to 16 kHz peak at 100% modulation, and thus occupy a channel bandwidth of 50 kHz. This service should operate at a power level of 1 KW ERP with a vertical antenna at 1000 feet HAAT, or at equivalent field strengths. The Association of Radio Reading Services supports this concept, and after their attempts to get a spectrum allocation from the Federal Government - (Commerce Department) was flatly refused, they have petitioned the FCC to allocate a small portion (10%) of the 220 MHz to 225 MHz band for this purpose. The Commission has yet to respond with rule making notice on this as of November, 1986. (But -- we are still working on it and, remain hopeful!!) This "Technical Primer" on SCA as applied to Radio Talking Book operations has attempted to assist you in understanding the "big picture" of how this system works and some of the problems faced by it. For more in-depth information please feel free to write and I will certainly assist you within the limits of time and technical knowledge available to me. Robert D. Watson (Bob)