Making Waves Commentary: Gonsett Fights Satellite Receiver Makers

(Commentary) The popular industry email bulletin CGC Communicator published by Communications General Corporation consulting engineer Robert Gonsett ran a series of summary articles this year on the emissions of what he terms “mini-transmitters” used for getting audio from satellite receivers to automobile FM radios. At question was the power and frequencies chosen for the job.

Sometimes taking on entrenched forces of big business and big government becomes a hopeless morass of stonewalling and legal manuevering; the one with the most expensive den of attorneys wins. At other times, the system works. Follow along as we piece together the story of how one person can shed enough light on foul activity to make a difference.

This story began nearly two years ago, shortly after I took the job as Chief Engineer at the XETV Fox 6 studio in San Diego. Disclosure: XETV retains well-known consulting engineer Robert Gonsett specifically to deal with matters of interference, be they intentional or incidental. The actions taken by Bob were largely done by his own initiative, though I am left personally grateful and somewhat astonished from the lesson of power in process and persistence.

The Punching Bag of TV Spectrum

Pity the poor channel 6 over-the-air viewer in San Diego. First of all, the signal’s low band VHF, which means viewers must contend with urban electrical noise and the visual blight of a large antenna, if they bother at all. Then there’s the distance from the transmitter in Mexico to viewers north of Mission Valley. Add that the XETV’s power is split between horizontal and vertical polarization so that unless you have a special circular polarization receive antenna, you can’t receive the full signal. And then we deal with the adjacent band noncommercial FM broadcasters who want nothing worse than to improve coverage for their deserving listeners. The latest assault, however, comes from the proliferation of little FM modulators people use to transfer without wires the audio from their file players and various satellite receivers to a stock automobile FM stereo radio.

Those FM modulators are termed by the FCC “intentional radiators,” which means that their radiation is intended, in contrast to the unintended radiation from, say, your computer’s switching power supply. Under FCC regulation 15.209(a), such intentional radiators must have a fundamental signal within the FM band measured at no more than 150 uV/m at 3 meters distance, and they’re just plain not allowed on TV channels 5 and 6.

The  Journal

2005 – I begin receiving occasional calls from viewers who say that they are watching us when the colors  flash and they can hear music or voices unrelated to the video emanating from their TV speakers. Their interference comes and goes as do their neighbors. Obviously, this must be occurring with other channel 6 outlets around the country.

December 2005 – Gonsett’s newsletter, the CGC Communicator, relays a report from an LA radio chief engineer that a pirate broadcaster he picks up on his car radio is actually an XM satellite receiver FM modulator. “It amazed me how far I could hear the FM modulator….at least 250 feet if not further. This is the second time that this has happened to me while driving around…I strongly question whether these XM modulators are Part 15 compliant because they are able to radiate signals over 250 feet….”

March 11, 2006 – The Philadelphia Inquirer runs a story about the interference to non-commercial FM stations caused by satellite radio receivers. By this time, it is common knowledge that the default frequency on many of those receiver modulators is 88.1 MHz, much to the dismay of stations like KKJZ in Long Beach. Mike Starling, NPR Director of Engineering and Operations in Washington, promotes using 87.9 MHz as a default frequency—understandable in light of the fact that many, if not most, of these mini-transmitters come equipped to transmit only on non-commercial frequencies at the lower end of the FM band.

March 29, 2006 – Bob Gonsett writes a detailed letter to Sirius Radio Public Relations officers, with copies sent to various FCC contacts. In it, he asks that the satellite radio companies provide proof that they have received from the FCC a specific waiver that allows them to market satellite radios with FM modulators, “intentional radiators,” operating outside the FM broadcast band on 87.7 and 87.9 MHz.

March 30, 2006 – TV Technology magazine, in Doug Lung’s RF Report, highlights the FM modulator issue as a result of correspondence with Fred Lass, director of engineering at WRGB channel 6 in Schenectady, N.Y. Doug names the names of several modulator manufacturers that advertise illegal modulators and clarifies the FCC rules regarding continuous intentional radiation either misunderstood or ignored by those manufacturers. Doug reveals that Lass has notified the FCC Office of Technology about these transmitters. Lass tells Lung, “All that is required to find [illegal transmitters] is to do a Google search of ‘87.9 MHz’ to get a list of manufacturers and retailers selling these devices in the U.S.”

April 8, 2006 – Bob Gonsett “gets the ball rolling” by filing a complaint with the FCC in Washington against Sirius Satellite for incorporating 87.7 and 87.9 MHz into the intentional radiator mini-transmitters that are built into many Sirius consumer satellite receivers. He chooses to focus the filing on a single high profile case in order to simplify the process, shed light on the problem, and hope that the FCC would itself broaden the investigation.

April 27, 2006 – XM Radio files an 8-K form with the SEC in which it reveals to investors that it has received an inquiry received from the FCC OET on April 25 regarding the emissions of the Delphi SkyFi2 radio. The company states that it is making an internal review and anticipates “responding to the letter shortly and cooperating fully.”

May 8, 2006 – Bob Gonsett posts on his CGC Communicator an anonymous comment from a Los Angeles FM broadcast engineer favoring modulators operating below the FM band. “My feeling on any small transmitter for an XM, Sirius, HD or MP3 players is that they SHOULD use these out of band frequencies. Currently, FCC Rules do not allow this, but the situation deserves careful examination and consideration. Given the interference these devices cause to mobile on-channel reception of legitimate stations, we should give them out of band authorization (but not above 107.9 MHz). As a user, I cannot find a clean channel to use in Los Angeles for my XM receiver. As a licensee, I would not want them on my channel.” A sort of spectral NIMBY statement, but who wants mass transmitters on his frequency?

May 16, 2006 – Reuters reports that Audiovox Corp. suspends shipments of its Xpress Model XMCK10 XM satellite radio receiver after the FCC says the unit “did not comply with either operating bandwidth or related emission specifications.”

May 30, 2006 – XM Radio files another Form 8-K with the SEC in which it reveals to investors that it has suspended marketing of radios made by Delphi and Audiovox in order to comply with an inquiry received from the FCC on April 25. XM says it will modify the radios in question and submit them for Part 15 compliance testing. “We plan to have modified devices shipping to retailers in the near term.”

May 31, 2006 – Orbitcast.com quotes Sirius Radio EVP/CFO David Frear as saying that “all SIRIUS Satellite Radio receivers are in full FCC compliance. Some letters were sent regarding some Sirius devices that were out of spec. Frear stated that they then went to the receiver manufacturers and took care of the problem a while ago. All SIRIUS Radios are in full FCC compliance. Case closed.” Phewww.

Like the Whac-a-mole amusement at your local Chuck E Cheese, getting a couple of vendors to change their ways through FCC inquiries will inevitably result in another vendor producing a replacement product. After all, consumers demand a convenient way to transfer audio without wires. And none of this activity has yet dealt with the multitude of transmitters out there designed to transmit Apple iPod audio over FM. Some of those mini-transmitters are reported to put out suspiciously high signal levels. The work continues.

June 2006 Meeting – Statmon Technologies

Last month’s meeting at MediaFLO headquarters not only introduced the concepts involved in a graceful degradation of digital mobile TV signals, but of new ways of integrating hardware, including monitored rack outlets and personal laptop docks in the giant Network Operations Center. Their impressive graphic realtime U.S. map of operating metropolitan transmitter sites calmly glowing green was driven by this month’s presenter, Statmon Technologies.

Statmon introduced a couple of years ago the next generation of transmission site remote control hardware and software–highly scaleable, readily networked, web accessible, and customizeable. Ken Dillard visits us on June 21 at TV Magic and will give a presentation on their technology. He’ll inform us about both the EIF-32 embedded control product line and its large scale environment known as the Axxess control and facilities management system.

Join us Wednesday, June 21, at TV Magic, 8112 Engineer Road, at 6 PM for a social hour and snacks, then the 7 PM meeting and presentation. Guests welcome.

June 2006 Open House – Grass Valley

TV Magic hosts an open house June 28th from 9 AM till 3 PM with Grass Valley products, including Turbo, Kayak, K2 server, Canopus, and RevPro drives for the Infinity news gathering system. The open introduces TV Magic’s new role as integrator and dealer of GV products.

Snacks, soft drinks, and coffee will be served. Please notify TV Magic of your plans to attend to sales@tvmagic.tv. TV Magic is located at 8112 Engineer Road in San Diego.

FCC Cites San Diego Radio Pirate…Again

FCC inspectors recently revisited the Golden Hill pirate station calling itself Free Radio San Diego at 96.9 MHz. An FCC Notice of Unlicensed Operation document signed by Bill Zears of the San Diego field office details an April 3 trip to the new 33rd Street transmitter site that found field strengths measuring over a thousand times Part 15 allowances. Station equipment, including the transmitter, was confiscated last summer in an FCC raid. Apparently this latest notice means that enforcement processes have started anew.

The website normally associated with the pirate station is down. The station normally plays a variety of free form music not heard on local commercial outlets, as well as community information and political talk.

We posted an interview with the station manager known only as Bob Ugly in July 2005.

May 2006 Meeting – Qualcomm’s New MediaFLO

Come see the birth of a revolution this month. May 17, Qualcomm’s MediaFLO hosts SBE Chapter 36 for a presentation and demonstration of their new mobile TV system. Find out how and and where it’s done. Meet Fred Baumgartner, project  Chief Engineer and nationally known SBE education advocate. If your station generates local content, this presentation may represent a future revenue stream.

One of the reasons we put up with the oppressive ankle and knee fatigue we all seem to get at the NAB Convention is that we get to catch up with old friends and acquaintances. We gray, swap jobs, put children through school, have tragedies–these little dramas connect our past to our present and life seems more interesting.

This year I came across an ex-coworker who had just joined Qualcomm’s MediaFLO project. His experience and computer programming skills make this job swap look like a particularly good fit. And for the first time, I got to see part of our future. He dialed in CNBC on his cell phone and showed it to me. Yeah, the cable channel. I couldn’t really read the ticker, but otherwise, this was a perfectly usable TV signal. You have to view the quarter VGA (QVGA) monitor, 320 x 240 pixels, sideways. Here, deep within the Las Vegas Convention Center’s Central Hall, was mobile TV without ghosting or dropouts. The relatively low power transmitter was far away on a mountaintop near Las Vegas. You probably wouldn’t want to watch Lawrence of Arabia on such a screen, but it might be a great way to catch up with sports highlights or breaking news.

MediaFLO engineers in Sorrento Mesa are busy designing metropolitan transmission sites across the U.S. And in San Diego, they are installing a Network Operations Center here, where they will do commercial and local content insertion.

Qualcomm has invited SBE Chapter 36 to the heart of the revolution. Come to our May 17 meeting and find out what all the fuss is about. We’ll meet, share a snack, then get a presentation on MediaFLO at a technical level broadcast engineers should be able to understand. This will be essentially the same presentation Tom Mikkelsen made at the NAB Convention. Then you can take the facility tour.

SBE members and guests are invited Wednesday, May 17 at 6:00 PM for the usual social hour with snacks, then our regular 7:00 PM meeting and presentation, then a tour of Building E. We’ll meet at Qualcomm Building G located at 4755 Eastgate Mall. From I-805, take La Jolla Village west to Towne Center Drive. Turn right and go north to Eastgate Mall Drive. Proceed to 4755. If you get to the bridge, Fred reminds us, you’ve gone too far. Note that there are card entry points—you will need to buzz security to get in.

Society of Broadcast Engineers, San Diego