We do not believe that stations that are proposed for these areas should be approved without substantiating evidence from the CBC as to the signal deficiencies. In this regard, we would recommend that, as a minimum, signal tests be undertaken, and that the Corporation be required to document actual listener complaints.
In its response, the CBC reiterated that it prefers not to show the Eu contours on the Long Range Radio Plan maps when their levels are below 5 mV/m. The CBC's position is based on its claim that a field strength of at least 5 mV/m is required as the basis for its national coverage planning for AM service. The CBC argued further that the DOC rules define the Eu for Class B and Class C, but not for Class A AM stations, which are protected against interference from other stations over much larger areas.
Nevertheless, the CBC agreed with the position taken by the CAB that, where new FM transmitters are proposed for areas lying between the 5 mV/m and Eu contours of AM transmitters with Eu levels below 5 mV/m, these new transmitters should not be approved "without substantiating evidence from the CBC as to the signal deficiencies". The CBC also accepted the CAB's proposal regarding the minimum requirements as to the nature of such substantiating evidence; i.e. comprehensive subjective tests and field strength measurements, preceded by confirmation that the existing AM transmitter is operating in accordance with the Broadcasting Certificate issued to it by DOC.
The Commission notes that the CBC's claim that a field strength of at least 5 mV/m is required as the basis for its national coverage planning for AM service is not supported by DOC, by the CBC/CRTC/DOC Tripartite Committee Report of November 1984 or by general practice in the broadcasting industry. In addition, this claim is at variance with the following statement by the CBC in its January 1989 submission: The daytime coverage of an AM station is defined by the 0.5 mV/m contour; the night-time coverage area is defined by the 0.5 mV/m contour or the Night-Time Interference Limitation (N.I.L.) contour, whichever is greater. This is an accepted technical definition of coverage.
The Tripartite Committee Report confirmed that an AM station provides adequate service throughout the coverage area enclosed by the Eu contour, even when the Eu level is below 5 mV/m. Only in exceptional cases do areas between the 5 mV/m and the Eu contours experience signal deficiencies. It is to deal with such exceptional cases that the Tripartite Committee recommended signal tests. An advantage of plotting both the 5 mV/m and the night-time interference-free contours (where the latter are below 5 mV/m) is that it facilitates the identification of areas where exceptional circumstances may warrant such signal tests.
In Decision CRTC 79-320, the Commission stated:
The CBC ... should ensure that the design criteria for its stations do not exceed commonly accepted standards used throughout the broadcasting industry.
The DOC rules define the Eu contour for Class B and C AM stations; the Eu is not defined for class A stations, also known as "clear channel" stations. The night-time interference-free level, however, can be easily calculated and plotted for the Class A stations, using the same formula used for Class B and C stations.
In view of the foregoing, the Commission concludes that it is the Eu or night-time interference-free contour that truly represents the actual night-time service area of an AM station, rather than the 5 mV/m contour chosen by the CBC. Therefore, the Commission will require the CBC to make use of the Eu or night-time interference-free contour, including cases where its level is below 5 mV/m, as the criterion for CBC AM coverage planning.
Consequently, within twelve months of the date of this notice
, the Commission expects the CBC to provide it with amended Long Range Radio Plan maps showing the Eu or night-time interference-free contours of all its AM transmitters. In cases where the Eu level is below 5 mV/m, the maps should show both the 5 mV/m and the Eu or NIF contours. In addition, the actual Eu level should be indicated on the maps.
In its Long Range Radio Plan submission of January 1989, the CBC stated that it accepts the Commission's guidelines for minimizing coverage overlaps outlined in Public Notice CRTC 1983-22. In its submission, the CAB also expressed support for these guidelines. Consequently, the Commission reaffirms its guidelines for minimizing coverage overlaps outlined in Public Notice CRTC 1983-22 as follows:
3.1 Based on the DOC definition of the FM 3 mV/m and FM 0.5 mV/m contours, it is the Commission's view that the criteria for the design of CBC FM transmitters should include the following guidelines for minimizing coverage overlaps:
3.1.1 The overlaps of coverage areas as defined by the FM 0.5 mV/m contours of transmitters belonging to the same network should be minimal.
3.1.2 The FM 3 mV/m contour of one transmitter should not overlap the FM 0.5 mV/m contour of another.
3.1.3 Where an FM transmitter is adjacent to an AM transmitter, the FM 0.5 mV/m contour should not overlap the AM Eu or night-time interference free (NIF) contour, including cases where the Eu or NIF level is below 5 mV/m.
4.PARAMETERS OF FM TRANSMITTERS
Public Notice CRTC 1989-64
raised as a concern the operating parameters proposed by the CBC for some of the FM transmitters in the revised CBC Long Range Radio Plan. In some areas, the CBC proposes to use several FM transmitters in close proximity to each other, with very modest operating parameters in respect of their Effective Radiated Power (ERP) and Effective Height Above Average Terrain of the antenna (EHAAT), whereas it appears that the areas could be served as well or better by a single transmitter operating at or near maximum parameters for its class.
In other cases, the proposed transmitters would utilize higher class channels with parameters near minimum for the class, whereas lower class channels with maximum parameters could provide adequate service to the intended areas. An example would be a proposal to use a Class B channel (which is permitted a maximum power of 50,000 watts) with 4,000 watts, when a Class A with 3,000 watts would suffice. Such under-utilization of frequencies can be very wasteful, particularly given the DOC's rules, which accord FM channels protection for the maximum parameters, with the relevant distances to other transmitters maintained accordingly.
The CAB indicated in its comments that, in those cases where the Long Range Radio Plan proposes the use of several FM transmitters in close proximity to each other, corrective changes should be made to the plan in the interest of conserving spectrum and reducing coverage overlaps. The CAB suggested that some such transmitters can be eliminated and service can be provided by an increase in the operating parameters of adjacent transmitters. In its response, the CBC stated that it agrees entirely that, wherever possible, its Long Range Radio Plan should use one transmitter operating at or near maximum for its class, rather than several less powerful transmitters in nearby communities, in the interest of better spectrum management and more efficient and effective delivery of its services.
The CBC also indicated that, due to conflicting objectives and special circumstances, these guidelines were not followed in the design of 30% of its transmitters. The CBC added, however, that if it "can further modify the Plan to achieve still greater spectrum efficiency, without sacrificing other objectives, it will certainly do so".
Given the stated support by the CAB and CBC for efficient utilization of the spectrum, and the CBC's undertaking to modify further the Long Range Radio Plan, where possible, to achieve this objective, the Commission has established the following guidelines:
4.1 Wherever possible, the Long Range Radio Plan should use one transmitter operating at or near maximum parameters for its class, rather than several less powerful transmitters in nearby communities. 4.2 Wherever possible, the Long Range Radio Plan should use channels of lower class which, when operated at or near maximum parameters, would provide adequate service to the intended areas, rather than channels of higher class with parameters just above minimum.
5.AM VERSUS FM FOR MONO-RADIO
The proposed use of FM instead of AM transmitters to provide the Mono-Radio service was an issue raised in Public Notice CRTC 1989-64
mainly in the context of the possible establishment of new transmitters in such major urban centres and provincial capitals as Regina and Victoria. Comments received and other developments indicate the need for a more comprehensive review of this matter. The current guidelines were set out in Public Notices CRTC 1983-22, 1985-86 and 1985-142; it now appears that some of the rationale that led to their development may have been misunderstood. In addition, the Commission is of the opinion that some clarification in this area is desirable.
5.1 EXTENSION OF SERVICE
The CBC indicated in its January 1989 submission that the revised CBC Long Range Radio Plan is predicated upon the continued use of the AM band for the basic radio service, insofar as existing AM transmitters are concerned. With regard to the establishment of new transmitters, however, the CBC wishes to consider both AM and FM options, even in major urban centres, such as Victoria and Regina. This would be clearly contrary to the statements of Commission policy contained in Public Notices CRTC 1983-22 and 1985-86.
Public Notice CRTC 1983-22 stated that the CBC basic radio service should remain essentially an AM service. To this end, the CBC basic radio service should be provided on the AM band wherever possible. This applies both to existing AM transmitters and to transmitters proposed for the future extension of service.
Following the recommendations in the 1984 Tripartite Committee Report, the Commission announced in Public Notice CRTC 1985-86
that it would be prepared to consider favourably the use of FM channels for the extension of the CBC basic radio services in all areas other than the following: Vancouver/Victoria, Montréal and surrounding area, Southern Ontario, all major urban centres and areas where FM channels are in short supply.
The guidelines in Public Notice CRTC 1985-86
contemplate exceptions to the generally more restrictive guidelines in Public Notice CRTC 1983-22. The Commission considers that this approach still conforms to the principle that "the CBC basic service should remain essentially an AM service" by requiring the use of AM frequencies in major urban centres, where the overwhelming majority of Canadians live, as well as in those other areas where FM frequencies are in short supply. The Commission is satisfied that this approach also addresses, in a meaningful way, the difference in costs between AM and FM transmitters, and takes into account the funding restraints faced by the CBC, by allowing the use of FM channels in all areas other than those mentioned above, where the bulk of new transmitters have yet to be established.
In view of the fact that neither the CBC nor the interveners have requested that the current guidelines on extension of service be amended or rescinded, the Commission reaffirms these guidelines as follows:
5.1.1 After considering all the factors involved, the Commission has determined that the CBC basic radio service should remain essentially an AM service and be provided on the AM band wherever possible.
5.1.2 In all major urban centres and in areas where FM channels are in short supply, including Vancouver/Victoria, Montréal and surrounding area and Southern Ontario, AM frequencies should be used for the extension of the CBC basic radio service. FM channels may be used for this purpose in these areas only if no suitable AM frequencies can be found now or in the future.
5.1.3 As an exception to item 5.1.1, and with a view to reducing extension of service costs, the Commission would be prepared to consider favourably the use of FM channels for the extension of the CBC basic radio service in all areas other than major urban centres and other than areas where FM channels are in short supply, including Vancouver/Victoria, Montréal and surrounding area and Southern Ontario.
5.1.4 Any exceptions in cases such as Victoria, Regina, etc., would be resolved by way of case-by-case consideration at individual public hearings.