And sooner than expected: the FCC will soon open a comment window for a plethora of proposals to assist beleaguered broadcasters. Paul Riismandel at Radio Survivor has a decent breakdown of the agency’s primary suggestions, and also notes that there’s "nothing on the all-digital question." If only this were true.

Just because the all-digital idea is not sharply delineated in the FCC’s Notice of Proposed Rulemaking doesn’t mean the agency’s not interested in it. Policy studies necessitate close reading. For example, the agency notes its permissiveness with all-digital AM-HD experimentation as one of several "discrete changes" it’s made over the years "designed to further enhance the AM service" (p. 5).

Furthermore, the FCC acknowledges that an all-digital transition doesn’t fit the bill as a "concrete" proposal "that can be implemented expeditiously"; rather, it is a "complex" idea that "would require additional comment, research, and analysis. We therefore encourage parties to submit comments in this docket for the purpose of advancing…other specific proposals to revitalize the AM service," of which an all-digital transition is explicitly mentioned (p. 20).

That’s all the green-light action that HD Radio proponents need to start the regulatory campaign toward an all-digital transition.

Such behavior actually fits the policymaking trajectory that got HD this far. The 1990s were a decade of furtive development for the system, as two primary developers struggled to make the coexistence of analog and digital radio signals actually work. They spent a lot of their time not on research and development, but on jockeying with each other for the position of "frontrunner" in the digital radio space.

In 1998, one of them (USA Digital Radio, of which iBiquity Digital Corporation is a direct progeny) filed a Petition for Rulemaking with the FCC hoping it would declare its technology the formal digital radio standard for the United States. Even though neither technology actually worked as its developers claimed at the time, the FCC issued a Notice of Proposed Rulemaking based on the petition, and from that the HD Radio system was ultimately born and sanctioned for rollout, half-baked as it was.

A tired quote about the doomed repetition of history comes to mind here, but perhaps things might turn out differently. I take a (microscopic) smidgen of hope from freshly-installed FCC Chairman Tom Wheeler’s first official blog post, in which he emphasizes the necessity of taking risks and not being afraid to fail at them:

The first book I wrote was about leadership lessons from the Civil War. The first chapter of that book is entitled "Dare to Fail." It is a philosophy that has been at the heart of the venture capital business from which I come; the majority of a VC’s investments don’t work out as intended, but without taking those risks there can be no big rewards. The industries with which we work are always taking reasonable risks; I hope we won’t shy away from a similar approach….We cannot sit around and wait for others…to come up with ideas and alternatives.

Given Wheeler’s long history as Top Shill for the cable and wireless phone industries, his actions must speak louder than his words—but it does suggest that there may be the possibility of having a legitimate debate on the future of digital radio. The next three months (or so) will tell the tale.