Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554
In the Matter of MM Docket 99-25
Creation of a Low
Power Radio Service RM-9208
RM-9242
Digital Radio Express, Inc. (DRE) a California Corporation developing AM/FM In
Band-OnChannel (IBOC) Digital Audio Broadcast (DAB) technology wishes to
register its support for the MOTION FOR EXTENSION OF TIME OF
COMMENT AND REPLY COMMENT DEADLINES as requested by the National
Association of Broadcasters et al dated 5 March, 1999.
Although DRE supports the request for extension of time, as outlined, DRE believes
the Commission would find DRE’s IBOC DAB field test data valuable in this case.
However, DRE will require additional time to provide complete data that includes
the impact of LPFM on its IBOC system. DRE believes it could provide extensive
field test data before the end of Q4 of 1999.
With regards to DRE field testing of its AM/FM IBOC DAB system, DRE supports
the NRSC approach of defining a test plan and procedure for IBOC DAB testing
and has been an active participant in this process. DRE would commence
laboratory and field testing according to the NRSC defined procedures. DRE owns
and operates a fully equipped van which is capable of precision testing in a field
environment and has been used for such purposes in the past. Based on previous
testing experience, DRE would commence testing in the San Francisco area which is
a relatively harsh environment. Using this as a baseline other select areas would be
chosen to expand the data base. We anticipate 5 to 10 major market areas would be
tested so as to include the numerous environments representing the radio coverage
profile of the U.S. The field testing would follow the guidelines as outlined above (for details refer to
NRSC subcommittee IBOC test groups test guidelines in process), but in addition
would include a test procedure to determine the impact of LPFM on the IBOC
performance. The DRE IBOC DAB system is in a very advanced state of
development and current test results are very positive; however, it is DRE’s opinion
that before LPFM service is authorized its impact on IBOC DAB must be
investigated thoroughly to insure that IBOC DAB, now nearing successful
demonstration, is not jeopardized. The fundamental laws of physics cannot be
denied; additional energy in the spectrum will create some measurable interference.
Just as with an IBOC system where some deleterious effects of the additional energy
within the spectrum will be measurable, likewise LPFM will have some impact
accordingly. However, with proper design these effects can be minimized such that
there is significant net advantage overall to the listener and the industry at large.
Only with proper data can the impact of LPFM be determined and therefore it is
critical that the Commission allows sufficient time accordingly. DRE requests that
the Commission extend the comment period deadline to December 1, 1999.
Respectfully submitted,
N.J. Miller, President
Digital Radio Express, Inc.
1130 Wrigley Way
Milpitas, CA. 95035
Dated: March 17,1999