Representative W.J. Tauzin  Chair of Subcommittee on Telecommunications,  Trade and Consumer Protection  Committee on Commerce  C/o Cliff Riccio  2125 Rayburn House Office Building  U.S. House of Representatives  Washington, DC 20515

From: Christopher Maxwell  Secretary/Treasurer  Virginia Center for  The Public Press  Radio Free  Richmond Project  1621 W Broad St.  Richmond Va. 23220  Wrfr@aol.com  804-649-WRFR

Dear Honored Representatives of the House,

My name is Christopher Maxwell. I was invited to accompany Mr. Don Schellhardt of the Amherst Alliance to provide testimony regarding the claim by NPR and the National Association of Broadcasters (NAB) that the LPFM stations would cause unacceptable levels of interference.

The title of the hearings actually suggested a much broader related issue, "Radio Spectrum Management." As a potential future LPFM broadcaster, it is certainly in my interest that my listeners be able to hear me. Contrary to suggestions otherwise, we are not devoting thousands of dollars of our own money, time and trouble just to jam the signal of the nearest Rock station. We also want to have an effective signal unhampered by significant interference.

Therefore we also hope that you will be as informed as reasonably possible as you are empowered to help express the needs of the American Public through your vote.

The HR3439 hearings held January 17th, 2000 quickly bogged down into a discussion as to whether the testimony of the FCC or the testimony of the NAB was the more realistic and believable.

The Federal Communication Commission (FCC) engineer testified that they measure potential interference of a new proposed set of rules under laboratory conditions using harmonic distortion as their measure.

The NAB testified that the proper measure of interference is dB of crosstalk. The NAB engineer then played two soundtracks mixed so that one audio track was 1% of the volume of the other, and purported that this represented what 1% crosstalk interference would sound like.

This went on for slightly over an hour as the audience grew agitated at what is widely perceived to be misleading testimony until Dr. Rappaport nearly jumped from his chair exclaiming, "That's not how FM radio works!"

At this point the Chairman of the hearings, Mr. "Billy" Tauzin (R-La) adjourned the meeting with no resolution to the issue.

Thus this counter-reply testimony focuses on the issue:
whose testimony is the more believable?

Is the NAB's testimony using crosstalk as a keystone to their argument the more believable, or is the FCC's testimony, using harmonic distortion the more believable?

The reason this is of paramount importance is not just because of the obvious difference in their motivations the NAB gains or loses money if LPFM stations create competition.

The reason that we want to decide whether the FCC's testimony is more or less credible than the NAB's is twofold:

1. In general, if you can show that misleading testimony was given in one part of an argument, this then calls into question the rest of their argument.
2. In general, a group that stands to gain a lot of money by convincing congress to act on the group's testimony is more likely to give misleading testimony than those who don't have anything to gain one way or the other. This puts the burden of proof firmly on those who do stand to gain money.

It is our contention that the testimony of the
National Association of Broadcasters
(NAB) IS MISLEADING.

How? Let us count the 3 ways :

1) The NAB themselves defended LPFM spacing (third-adjacent) broadcasting in 1996 for full power stations.

You can verify the results for yourself:

WAVA105.1 in Northern Va. is one of the "Short Spaced Grandfathered" stations cited by the NAB in their comments in the FCC's official record (docket 96-120). [Enclosed]

The NAB cited (see attached page) stations such as 40,000watt WAVA105.1FM and the lack of any interference complaints in the official record for that or any of the other 300+ "short spaced" stations.

The NAB claimed that the increased quality of FM receivers in the last 30+ years since the spacing rules were instituted made the rules "overly restrictive". Since there were no complaints of interference in the 30+ years since the tightening of spacing rules caused these stations to be in 'violation', the FCC agreed.

The FCC allowed the "Short Spaced" stations such as 40,000 watt WAVA105.1FM in Arlington VA. to continue broadcasting in violation of the spacing rules that made WAVA "Short Spaced" to the other relatively local station 3^rd adjacent frequency, 50,000 watt WQSR105.7 a mere 43 miles away in Catonsville MD.

Without this past (case-by-case) harmless bending of (the FCC admits in 1996) "overly restrictive" spacing rules, Washington area listeners would not get the Christian viewpoints of WAVA, the evening Techno (a rare format outside of college stations) on WRQX, the talk shows on WJFK, the all-news on WTOP. Without the creation of space on the public airwaves for this competition, the Washington area radio dial would be far less compelling. Washington area residents would then be urged to more quickly move to technically inferior and expensive and geographically irrelevant alternatives to the FM Broadcast Band such as Music Choice, Internet audio (MP3 or streaming audio) or the new mobile satellite broadcast services such as XM and Sirius.

Grandfathered "Short Spaced" stations such as those in the table seen above and in the NAB's own supporting documentation [See attachment list] are close on the dial and are very near each other. Do they interfere significantly with each other? A drive through test has shown that they do not. Compare their large signal wattage with a 100 watt LPFM station. Would you expect any interference in that case? Under these circumstances, it's obvious you would not.

If we were to take the NAB argument seriously; that HR3439 is designed to prevent a disaster that would result from allowing radio stations to broadcast with only a 400kHz buffer in-between ... then HR3439 also should retroactively ban WAVA, WTOP, as well as hundreds of other short spaced stations and hundreds if not thousands of translators as well!

Furthermore, if the alleged interference caused by less-than-600kHz buffers between station signals are really the issue, HR3439 should also ban the proposed In-Band On-Channel Digital Audio Broadcasting proposals that are already causing interference and reduced buffers! (see item #3). For that reason you may hear some interference between WJFK106.7 and WRQX107.3 because of the additional bleed-over from the IBOC digital carriers. Try some of the other short spaced pairs of stations listed in the table and attached documents. Also try listening to the effect of the digital IBOC-DAB carriers from WETA90.9FM on WJYJ90.5FM. For more information on this interference, see item #3.


Looking at the graphic representation of the NAB's rhetorical gymnastics over the last four years, we see that not only do reduced buffers not appear to be the NAB's real motivation (since the buffers have not changed!) but the NAB themselves are pressuring the FCC to reduce buffers to nearly zero, and even pressuring to allow overlapping signals with a "negative "buffer in some cases. (see item #3 for more information on a new proposed technology called "IBOC-DAB".).

In 1996, in FCC Docket # 96-120 (enclosed) , the NAB argued that due to advances in receiver technology, the current rules were "overly restrictive." While the NAB is not as glowingly supportive as broadcasters who serve more diverse audiences, such as WCPE, the NAB notably did not suggest that their own existing short spaced stations be taken off the air either! 

Public broadcaster WCPE also stated in 96-120 (enclosed) support for the proposed relaxation of third adjacent restrictions to simply let the rest of us use the bent rules have allowed hundreds of stations such as WCPE to cooexist peacefully on third adjacent frequencies. 

Then in 1998 (since the FCC agreed there was no problem in 1996) activists for greater democratic efficiency (more different voices on the public airwaves) argued we should also be able to use third adjacent frequencies. We even offered to come down from WAVA's 40,000 watts to under 3000 watts! LPFM was further bargained down to 100 watts.

Only two years later in 1998 and the NAB claims the behavior they defended in 1996 will be a disaster if someone else (LPFM) does it.

And now two years again later (2000) than that and the NAB is arguing that buffers are beside the point with Digital Audio Broadcasting  IBOC technology. (see below for more information).
 
 
 

Dr. Rappaport is the James S. Tucker professor of electrical engineering at Virginia Tech, Blacksburg, and has been on the faculty for 12 years. In 1990, he founded Virginia Tech's Mobile and Portable Radio Research Group, one of the world's first research and education centers to specialize in the field of wireless communications. He also serves as Chairman of Wireless Valley Communications, Inc. in Blacksburg, VA.

Dr. Rappaport testified that :

"My analysis concluded that LPFM will not cause unacceptable levels of interference to existing FM broadcast stations or their listeners. My computer simulations demonstrate that under the conservative proposal adopted by the FCC, in the absolute worst case, if all new LPFM stations used 100 Watts, then at most, 1.6 percent of listeners who could hear a new LPFM station might be unable to receive a currently existing broadcast station.

"More importantly, the large majority of the affected listeners would actually be able to receive all current stations, and other affected listeners would be able to receive an incumbent station by simply moving their radios a few feet or by rotating them on their nightstands.

"My analysis found that, by using worst case interference assumptions and by relaxing the second and third adjacent channel protections, 626 new LPFM stations could be added in 60 US cities. My recommendations would have allowed over 81 million new citizen-channels on the FM airways, with a worst case potential interference of 1.2 million citizen-channels (however, since the analysis was worst case, only a small fraction of the 1.2 million citizen-channels actually would have experienced interference of some kind).

"However, the FCC adopted a more conservative approach, and insisted that all LPFM stations must obey the existing second adjacent channel projection rule, which reduces the number of new LPFM stations to 247 in the same 60 US markets. This reduces the number of citizens-channels by almost 300%, and decreases the number of potential interference events by the same factor."

So Dr. Rappaport agreed in limited part with NAB testimony that there would be some extremely limited interference under extremely limited circumstances.

And in spite of that very limited agreement, Dr. Rappaport expressed very strong opposition to the misrepresentation of what interference sounds like as provided by the NAB engineer. Dr. Rappaport nearly stood up in the proceedings from his chair, interrupting the NAB engineer only after it became amply obvious that the hearings would not politely allow a competent technical challenge to the NAB testimony. Furthermore others who would NOT gain money from ending the LPFM competition were not allowed to properly address this issue, as Mr. Tauzin adjourned the meeting.

SO THE QUESTION STILL REMAINS. Does the NAB testimony accurately reflect the performance of real FM receivers actually picking up two FM signals simultaneously?
 

I invite the Congressmen to test whether FM interference is smooth or distorted for yourselves. Does the real world sound anything like the NAB "samples"?  [NOTE: This file is 9mb]

Once again, as with WAVA105.1FM, if you drive west on I-66, and turn south on I-495, you can pick up two stations for this test.

WPLC94.3FM is a very small station at only 2,000 watts in Warrenton VA. WARW94.7FM in Bathesda is 20,500 watts. This test radio only experienced interference for a few hundred feet along I-495 at the Highway 50 exit.
 

This recorded sample of actual interference experienced by a radio is available by clicking the speaker. [NOTE:] This sample was taken from a $25 flea-market purchased third-party car radio tuned to 94.3FM in a moving car heading south on I-495 at the Hwy 50 exit.  [NOTE:] This radio's performance is way below that of most name-brand car radios, and about that of a regular boom box. So a normal car radio would not experience this interference and a boom box user would simply alter the angle of the antenna to tune out the incurring signal. Anything less than a boom box would not be sufficiently sensitive to hear 94.3FM at all thus making it a moot point for radios like walkmen.  This station had been continuously monitored from the Centreville VA exit of I-66 and south of this location and the brief incursion of classic rock (starting at 37 seconds into the clip) you hear on the clip was the only significant interference recorded during the entire time monitoring the station, even after continuing south on I-495.  Note that the signal is so weak, it often cancels itself, or falls just below the threshold of the radio to detect and creates the intermittent hisses. Those periods of drop-out are not interference, that would happen regardless of any other stations in the area at the limits of the signal's reach. Version.

As you listen to this sample of actual FM interference in the real world, notice a few things:

Is the interaction of the two signals a smooth clean mixing of the two audio tracks like the NAB testimony?

Our target sample station, the one that the radio is tuned to, the distant 94.3 is playing the Modern Contemporary Music (the foreground music, the guitar strumming).

The strong local station 94.7 is playing the Classic Rock song you hear only briefly.

Notice that the pop music is replaced in brief bursts by the distorted oldies rock soundtrack. The first recorded incursion appears at 37 seconds into this clip.

This demonstrates the "capture effect" of FM demodulators. The FM receiver will lock onto one signal until the other signal absolutely overwhelms it and "jumps" to decoding the other signal, not both signals at the same time.

This jumping can also be rapid like the vibrato on a musical instrument creating a "shimmering" effect that shows distortion, not a smooth crosstalk.

This sample does not sound anything like the "evidence" sample that the NAB provided. You can see from this example (which we urge you to go out and verify with your own radio) that there is significant distortion.

Note that it is levels of harmonic distortion that the FCC used as their measure of alleged interference.

Notice the samples provided by the NAB were smooth like a studio mixture as if both signals were of equal strength, AND as if both signals were coming from down the block. NOTE: This MP3 by the NAB is 9mbytes in size ... go get a snack!

In this real example, our target station's signal, the pop music (strumming guitar) on 2000 watt 94.3FM 30+miles away is so weak as to be nearly unlistenable even without the brief incursion of signal bleed over from 94.7FM..

This also speaks to one of the questions asked by the Congressmen and never answered, "What is 'acceptable interference'?"

Nature is not a binary world, it is not day and suddenly completely night. Nature is not completely "on" or "off". Radio is no different.

If you then accept that there is no such thing as "no interference", then it is always a matter of levels of "acceptable interference".

This recording shows that our favored signal, the weak contemporary music station at 94.3FM was so weak and full of noise as to be unlikely to have any significant audience at the point on Highway 495 where 94.7's signal briefly interfered!

And indeed, nobody is is on record complaining of interference between short-spaced stations to the FCC!!

Therefore since Warrenton VA's 2000 watt 94.3's signal was already too weak to maintain a consistent delivery regardless of interference from Bethesda MD's 94.7FM, the geographically very limited interference you hear on this clip constitutes an example of "acceptable interference". This demonstrates the "Politics Of Interference" where what is acceptable is determined by the reactions of the people affected, in other words, what is acceptable interference is not a technical question with a nice mathematical answer ... what is acceptable interference depends on the politics of the situation.

This clip also illustrates that the NAB testimony involving two sound tracks mixed in a sound PC was misleading, that indeed, "that's not how FM radio works" does best describe the best thing you can say about the NAB testimony.

As you will see (and hear) in the graph and sound recorded from actual signals from WJFK106.7FM in Northern Virginia, this is exactly what is happening.  WJFK106.7FM as well as WETA 90.9FM in Northern Va. is a test station for a new kind of broadcasting called IBOC-DAB (In-Band, On-Channel Digital Audio Broadcasting).  This new kind of broadcasting sends out sound the same way a fax machine sends out a picture, by converting the sound into little blocks that are on or off. The acronym "IBOC" describes a plan to "hang" the digital signals like saddlebags on the two outer sides of an existing station.  These sideband saddlebags are depicted graphically as the red blocks on the right.     NOTE: Between 2/17/00 and 3/22/00 WJFK has ceased broadcast of the IBOC-DAB sidecarriers. However, WETA 90.9FM still is transmitting their IBOC-DAB carriers with similar effects on WJYJ 90.5FM from Fredricksburg, Va. [NOTE:] Analog LPFM stations would never cause this interference because it would be required to operate no closer than the third adjacent FM frequency or "channel" on the FM dial. Note that a "channel" is not a point along the electromagnetic spectrum. When I say that I listen to 106.7 FM, what I am really saying is that I am listening to an FM signal that is centered within a range of spectrum 200kHz wide whose "spectral real-estate" goes from 106.6-106.8Mhz The New IBOC technology would expand that real-estate to a range of 106.485-106.915mHz.  That Baltimore station (WWMX106.5) that you used to pick up in downtown Washington? The one that used to be centered at 106.5mHz? Gone, overlapped, totally overwhelmed and jammed by the overlapping signal from then new expanded IBOC version of WJFK. Don't forget that listeners in the NorthEast section of Washington DC will lose WJFK similarly to WWMX's new expanded size. LPFM would never do that because they have to provide a huge buffer space of 20 miles and 400kHz in between them and any local stations. The closest an LPFM could be would be 107.3 ... except that instead of a 100 watt LPFM on 107.3, there is already 34,000 WRQX. So if 34,000 watts is not a problem now, why would 100 watts have been a problem with even more miles in-between??

I urge you to test this for yourself, drive West on I-66 again. While in downtown DC, tune your radio into 106.5FM (90.5FM) from Baltimore .  At first you will just hear WJFK (WETA90.9) occasionally stomping the Baltimore 106.5 signal (Fredricksburg 90.5 signal). Then as you go west, you will hear a distinct "buzz saw" sound. Now from 106.5 (90.5) tune the radio up past 106.7 (90.9) to and through 106.9FM (91.3FM). You will notice very distinctly that it sounds as if two fax machines were transmitting on two new stations on either side of WJFK (WETA90.9).  Actually, that is almost exactly what is happening. There are two digital transmitters (the red blocks) that are transmitting on the immediate adjacent frequencies of WJFK. The analog portion of the signal is represented by the green triangle).  You can hear for yourself what this already means for listeners of WWMX106.5FM out of Baltimore. If you do not hear that buzz ... inquire as to whether the test has been terminated or paused at the time you listened. .....................................

You can hear the square waves of IBOC on-off-on" carriers as represented by the red blocks as you tune up through WJFK and through to the other side. By Clicking The Speaker Here, you can also hear a recorded clip of a radio tuning through the three stations: Starting at 107.3FM playing contemporary music  and through the upper IBOC "saddlebag"  then 106.7's analog signal (the talk program)  then though the lower IBOC digital "buzz saw" sounding "saddlebag"  to 105.9FM  and back up through WJFK returning to the contemporary music on 107.3FM.  [NOTE: What to listen for.] This was recorded several miles west of the intersection of Hwy 66 and I-495 where the digital IBOC carriers are extremely strong and destroy 106.5 WWMX completely so you are hearing stations on each side that would normally have empty buffer space in between them and WJFK's signal. Instead you hear their signal is now nearly contiguous to WJFK's spread-out signal.  version

Even more amazing, what you are hearing is only the tip of the  impending NAB-sponsored interference iceberg of IBOC-DAB! The NAB coalition is pressuring the FCC to allow that buzz saw to EXPAND, to double in size to 430kHz in bandwidth. But the sample you hear and the buzz you will hear if you yourself repeat the test mentioned above is only the 70kHz version that theoretically stays within the currently allowed 200kHz bandwidth!

Please realize the vitally important point here that WJFK is testing the absolute most minimal version of the IBOC sideband digital carriers comprising only 70kHz of bandwidth and supposedly positioned to exist within the space on the FM dial normally legally allowed WJFK. Wait until the full 430kHz bandwidth version is rolled out!! Those stations above and below WJFK are going to have a rough time reaching anyone.

Not only will you never hear WWMX106.5FM from Baltimore again you may not even hear several DC stations either! What is to happen to the listeners of WRQX and WJFK in downtown Washington? WRQX-DC and WJFK-VA are only 9 miles apart geographically. And if a buffer space of only 400kHz is going to be a disaster for 100 watt LPFM stations and listeners, imagine what a disaster the 22,500 watt WJFK and 34,000 watt WRQX stations will be with only 170kHz of buffer in-between.

For this reason, the Virginia Center for the Public Press has submitted a request for extension of Reply-Comment period in the FCC Docket 99-325 (impact of IBOC-DAB) proceedings. We requested a full publicized test of the full 430kHz IBOC test signal on both WJFK106.7 and WRQX 107.3FM with proactive involvement of the population of listeners.
 

In other words, the LPFM as well as the other already existing 300+ "Short Spaced" third adjacent stations (like WAVA105.1FM and like WRQX-WJFK) must maintain a "buffer" of two channels in between themselves and other stations on the local FM dial. Thus an LPFM would only be allowed at 106.1FM or 107.3 and then only if there are another two unoccupied buffer spaces on the other outer sides of those two slots as well.

This means that Washington DC listeners of WWMX106.5FM from Baltimore would still hear their station with LPFMs, but not with the NAB's proposed IBOC-DAB in place.
 
 

In Conclusion:

Thirty percent of the CDs sold are of musical genres rarely heard on most radio stations such as Techno, Jazz, Classical, Folk. There are more moderate and liberal listeners of news-talk, yet most talk hosts are conservative. Thirty percent of our interests are heard provided by the small independent commercial, noncommercial college, religious and community radio stations that account for 20% of the listenership. Thus 20% of America stands to lose access to the smaller stations that would be utterly destroyed by the brain-child of the NAB (IBOC-DAB) ... reducing the variety of choices for consumers ... while LPFM would open vistas of new programming opportunities. The tradeoff under the worst case scenarios show a loss of about 1% of access in exchange for nearly DOUBLING the number of choices.

The NAB is willing to create misleading testimony and "samples" of hypothetical third adjacent stations when there are plenty of real-world third adjacent stations right there in your neighborhood.

Furthermore there are a plethora of options that the NAB could have counter-offered. The NAB and NPR could have suggested a law requiring the incumbent broadcasters to open their multiplexed channels such as FM Subcarriers and TV SAP (Second Audio Program) Channels (or the upcoming multiplex channels on Digital TV signals) to nonprofits such as are done for many cable companies with "Cable Public Access."

But did they make these suggestions and offers?

No.

Instead they cook up a harebrained scheme to sell us something we don't want (IBOC-DAB) by forcing it upon us in the form of "mandatory sunsetting of analog" broadcasting that would destroy listener's access to small business and small nonprofit church, college and community radio programming outlets.

DAB has been a market FLOP in Europe where they have a choice, and yet ironically in America, supposed land of the free, we may lose that market choice and about half of the smaller niche market stations available now!

Even while NAB and NPR stations transmit on third adjacent frequencies thus creating room for themselves, they would deny us equal treatment under the law and regulation guranteed by the 14th Amendment.

Their only answer is "There's No Room At The Inn."

Attachments:

1) NAB July 22, 1996 Motion for Extension of Docket 96-120.
Look on page 2 where the NAB cites, " ... progress in radio receiver design that, in some cases, provides better rejection of second and third-adjacent channel interference."

2) WCPE (classical music public broadcaster entirely funded by listeners only) comments received August 1, 1996. Look on page 2 where WCPE notes, "yesteryear's vacuum tube sets pale to today's receivers and their ability to tolerate very strong second and third adjacent signals. Forty years of advancements provide greatly improved performance." WCPE also notes on page 3 that they are already operating in two short spaced situations with no apparent problems. One of these is a SECOND ADJACENT CHANNEL station.

Also in WCPE's statements on page 5, the FCC is quoted: "We believe that licensees of certain classes of FM stations should not be unnecessarily constrained by an inconsistent technical standard, while others, operating under a less restrictive standard, do not appear to have experienced any significant problems over the years."

ALSO in a conversation on 3/17/00 with Christopher Maxwell of the VCPP, Deborah S. Proctor, GM of WCPE said that "WCPE also is supporting a power upgrade for a nearby short spaced station in Chapel Hill NC." Proctor also stressed the need for a serious study of ways to "optimize" the FM spectrum for the equitable addition of new radio stations. Proctor suggested that she could offer a fleet of five stations for just such a detailed test.

Proctor recommended strong public involvement where the public is alerted and then surveyed as the stations change power levels for the tests. Proctor also suggested that in some cases, moving a constellation of stations up or down frequencies, like moving parallel parked cars, could also create new opportunities as well.

3) NAB October 4th, 1996 Comments:

Page 3 in i Executive Summary, "The current rules as they relate to these affected stations, are in certain instances overly-restrictive."

Page 7 "NAB commissioned the first study to explore the thesis that improvements and refinements to radio receiver design have resulted in better rejection of second and third adjacent channel interference."

Page 8 "And though NAB would support improvements/modifications of facilities that might resulting some increased short-spacing to second and third adjacent channel stations (footnote 9), it is our expectation that such increases would be minimal -- and that many modifications actually would result in a net decrease in the interference caused to these other stations.

Footnote 9 shows the NAB's double standard that it is only interference when somebody ELSE does it stating, "NAB's support of granting measures of needed modification flexibility to certain grandfathered, short-spaced stations blocked by second-adjacent and third-adjacent channel operations does not stand for the proposition that second and third-adjacent channel protections should be revisited for purposes of station allocations in general. "
In other words, we have already broken the law, but we can't let you break the law, even if the law is "overly restrictive."

Page 12 NAB admits that their study is fatally flawed for the current consideration of THIRD adjacent LPFM stations, "Due to limited time and resources, including the fact that second adjacent-channel data -- but not third adjacent-channel data-- were readily available, Mr. Keller's analysis does not include 3rd adjacent channel interference tests."
No-one is currently supporting second adjacent transmitting, although the NAB defends current second adjacent stations ... and their tests did not even cover third adjacent situations!
Therefore if they support conditions far far worse than anything suggested this year as being OK in 1996 ...

Page 15 (22 in Adobe version second collection) and Page 35 (17 of 25 in Adobe version, third collection) show 13 instances of short spaced station in the Washington DC area that could be directly sampled by the Members of Congress with various radios they own to see for themselves. KEEP IN MIND that these stations are MUCH MUCH MORE POWERFUL THAN 100watts that LPFM is restricted to.

4) VCPP request for extension of Reply-Comment period for FCC Docket 99-325 due to failure of ECFS system and the lack of tests of the full 430kHz bandwidth version of the IBOC-DAB system promoted by the NAB-CEMA coalition. As of 3/17/00, the ECFS system still does not display our submissions for February 2000 on IBOC-DAB.

5) Sound File 1 of 2 attached in electronic version. A sample of the brief interference recorded from a lower-performing car radio on I-495 at the Hwy 50 exit. Please see body of text for more information. Demonstrates that interference involves DISTORTION, not a smooth mixing of signals. This throws the validity of the NAB testimony samples in doubt. This sample also demonstrates the "capture effect" of FM technology that prevents a smooth mixing of two audio tracks as the NAB sample suggested.

6) Sound file 2 of 2 attached in electronic version. This sample is a recording of the IBOC digital carriers (minimal 70kHz version) showing what it sounds like and that it spreads the signal of WJFK further out on the dial, utterly destroying 106.5FM from Baltimore's signal and using up much of the buffer between 105.9 and 107.3FM. The thing to ask as you hear this is, what happens to those surrounding stations when the IBOC sidecarriers expand to DOUBLE the bandwidth (430kHz bandwidth station)??

7) Remainder of NAB's full list of commercial potential short spaced grandfathered stations in two files, A and B.