MEMO TO THE FCC: REVIEW iBiquity FOR FAILING TO SERVE THE PUBLIC INTEREST WITH HD RADIO

Today I filed an informal complaint with the FCC asking them to review the performance of iBiquity in reference to HD Radio. After almost 13 years of stewardship of US digital radio, it is clear that iBiquity’s plan and method of digital broadcasting is failing to serve a reasonable number of people to call it “broadcasting in the public interest.”

As evidence, I submitted yesterday’s post showing HD listening is most likely FM translator listening. One of the folks who responded to my post is John Garziglia, a DC based attorney who knows a lot about HD and radio translator issues from personal experience. Here is John's take on the situation:

Several years ago, I challenged iBiquity on their claim that HD sub-channel stations (HD2s and HD3s) were “getting ratings” in major and large markets.  I pointed out to iBiquity that, to my knowledge, all such HD2s and HD3s that showed in the ratings books were being carried on FM translators, and that I was not aware of one HD2 or HD3 station that, without an FM translator, was achieving sufficient audience numbers to achieve the minimum threshold for being shown in the PPM ratings.  At first iBiquity pushed back on this but I never heard back from them one example to the contrary.

Learn more about John Gaziglia at http://www.wcsr.com/Professionals/Lawyer-Bios/Garziglia-John-F
NOTE: John Garziglia is not involved in my FCC complaint.

NIELSEN AUDIO MINIMUM REPORTING STANDARDS

PPM MARKETS: Station must embed NA “digital watermark” into its signal or audio stream to be eligible.  To be included in NA reports, an eligible station must have a minimum Weekly Cumulative Rating of 0.495 among Persons 6+, Monday – Sunday 6am – Midnight during the survey period.

DIARY MARKETS: Station, via signal or audio stream, must be reported in 10 In-Tab Metro diaries, have a minimum Weekly Cumulative Rating of 0.495 and an Average Quarter Hour rating of 0.05 among Persons 12+, Monday – Sunday 6am – Might during the survey period.

This is NOT very tough criteria.  Depending on market size, a station needs to have more than a handful of listeners to show up in the book.

In the past iBiquity has been challenged for its mind-numbing technical standards and exorbitant licensing fees.   

My complaint is based upon their system’s failure to serve enough listeners to qualify for “broadcasting in the public interest.” The FCC needs to say TIME OUT to iBiqiuty and explore other digital radio ways to serve the public.

I am also sending a copy of the complaint to the National Radio Systems Committee (NRSC), a non-profit organization that studies and recommends technical standards for radio broadcasting. The NRSC was established by the National Association of Broadcasters and the Consumer Electronics Association.