A group of major U.S. broadcast owners is using strong language concerning the possible impact of some of the AM band rule changes being considered by federal regulators.

The recently formed AM Radio Preservation Alliance has submitted 147 pages of suggestions, comments and exhibits, arguing that some of the Federal Communications Commission’s recent proposals would be a “potentially irreversible step toward extinction” for most licensees on the AM band. The broadcasters also responded to comments from other filers that some of its earlier interference descriptions were “overstated” and “incorrect.”

The AM Radio Preservation Alliance includes many of the country’s largest and most familiar radio companies: iHeartMedia, CBS, Cumulus, Alpha Media, Townsquare, Cox, Bonneville, Entercom, Family Stations, Grand Ole Opry (WSM), Greater Media, Hearst, Hubbard, NRG, Scripps, Tyler Media and Tribune.

In its reply comments — filed as industry leaders gathered here in Las Vegas at the NAB Show — the alliance focused on interference protections for Class A stations and on reducing protected daytime contours for Class B, C and Ds. It reiterated its earlier comments that changes suggested in a Further Notice of Proposed Rulemaking, as well as variations suggested by certain commenters, will do more harm than good. “If adopted, [the FNPRM proposals] would undermine the efforts to revitalize the AM radio service.”

The alliance said that protecting Class A AMs only to their 0.1 mV/m groundwave contour from co-channel stations and eliminating critical hours protections for Class A AM stations would deprive potentially tens of millions of listeners — especially those in remote and Native American areas — of access to quality programming and emergency information.

Not only that, the changes would weaken key links in the nation’s IPAWS EAS emergency networks, deny listeners access to favored sports programming carried on Class A stations, and undermine the already-tenuous economic underpinnings of AM broadcasting.

While the changes may be well-intentioned, it argued, they threaten to diminish useful Class A service while offering little real-world improvement to other stations’ signals. The alliance noted similar recent comments by FEMA Project Manager Alfred S. Kenyon, listeners who tune in to Class A stations from afar, and professional and collegiate teams with a Class A AM fan base.

“Notwithstanding the unsupported speculation of some commenters that Class A AM distant listening is a myth, the Alliance Comments demonstrated quite the contrary, substantiating a current audience of nearly one-half million Class A AM listeners, tuning in for a collective 8.6 million hours of radio listening each month, in the zones that would be subject to interference under the FNPRM Class A proposals.” It included 75 pages of comments from skywave listeners outside of the 0.5 mV/m groundwave contours of 19 Class A stations, signals such as WGY, WLW, KOA, WHO, KXEL, WHAS and KEX. There are 57 total Class A stations in the lower 48 states, and the alliance says their distant listeners would be subject to “devastating” signal interference.

The group pressed the commission to reconsider any elimination of skywave and critical hours protections for Class As.

When it comes to reducing protected daytime contours for Class B, C and D AM stations, the alliance urged the commission not to adopt its proposal to reduce the contour to the 2 MV/m contour. While one AM might obtain power gains and some population gains under this proposal, “it would be at the expense of neighboring AM stations and their audiences and the integrity of the AM band as a whole,” the group stated.

In short, it said, the FCC should stick with the path it set out for itself with its First Report and Order. “It should not diverge from that path by adopting nonconsensus reductions in interference protections that would cause more harm that good to the listening public,” the group said. “While the proposals, and variations thereof, ... might well lead to some short term revitalization of business for AM engineering consultants and equipment manufacturers, for the vast majority of AM licensees, it would be a potentially irreversible step toward extinction.”

The alliance also answered concerns raised by other commenters over its earlier comments about interference and desired-to-undesired (D/U) signal ratios. Commenters such as the engineering firm of du Treil, Lundin & Rackley and Crawford Broadcasting raised concerns over the alliance’s initial interference descriptions, with the latter calling the group’s predictions “overstated.”

The alliance agreed that its comments appear to have “created some confusion,” and in response relabeled its disputed Exhibit Q studies. “The alliance is taking this opportunity to confirm that the Exhibit Q studies are based on prohibited contour overlaps, and do not reflect ratios of desired-to-undesired signal as less than the level specified by [FCC rules].”

But in any event, the alliance said, “when a desired/undesired signal analysis is performed on the representative stations studied at Exhibit Q … the analyses show that each upgrading station will incur substantial new areas of received interference from the also-permitted power upgrades of its neighbors …”

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