Just a couple of days after prognosticating on the policy future of all-digital AM-HD radio broadcasting, one of the key players in the industry’s testing regimen issued his own reality check: for digital radio to succeed, all over-the-air broadcasting must migrate to FM.

Andrew Skotdal is the owner of two AM stations the NAB et al. used to test all-digital AM-HD in Seattle this fall; he presented on these tests at the NAB Radio Show. In prior trade coverage, Skotdal has been upbeat about the future of digital AM broadcasting, though cognizant of its uphill climb. His latest missive shatters many illusions.

Although Skotdal is convinced that AM-HD Radio has merit, he’s worried that station and listener adoption trends have all but doomed it. In the Seattle market, only around 5% of radio listeners have access to an HD receiver, and there are none to be found in the stores. Furthermore, many AM stations will never be able to adopt HD because of their directionality and/or inadequate transmission facilities — investing six figures in making infrastructure upgrades to broadcast a digital signal nobody listens to is a non-starter. What’s worse, Skotdal predicts that the “rising tide” of electromagnetic interference on the AM band will eventually “wash away the coverage and signal improvements of digital” in the long run. Therefore, all-digital AM is perhaps best thought of as a short-term solution to the AM band’s problems.

For the long-term, Skotdal advocates a dual strategy of migration and mandates. Ultimately, all of radio broadcasting will migrate to FM; this is already happening through the rush for FM translators, which is really nothing more than a land-grab for the last remaining potentially lucrative crumbs of existing FM spectrum left today. To accommodate all AM broadcasters would most definitely involve expanding the FM dial. Not a new idea: LPFM advocates suggested it many years as a way to expand public access to the airwaves, and it’s something that at least one Commissioner is on record in support of.

The most commonsensical expansion would involve adding spectrum to the lower end of the FM dial, which currently starts at 88 MHz; going down to 70 MHz or even lower could add dozens if not hundreds of new available channels to the dial. Problem is, that spectrum has historically been utilized by VHF television broadcasters, who would be forced to migrate themselves if the FM band were expanded. [In a separate proceeding, the FCC is seeking to repack DTV stations which might free up this spectrum, but there’s no guarantee.] And an expanded FM band would also initially suffer from a lack of an installed receiver-base.

That’s where the mandates come in. Skotdal thinks forcing a digital conversion on the AM band would make for a great culling, eliminating 85% existing stations – those with facilities too technically and financially strapped to make the switchover. He suggests these broadcasters should be subsidized for surrendering their licenses, perhaps in the form of tax incentives or other “meaningful compensation.” He also thinks the few hundred AM stations that remain after the band is culled should receive “some kind of low-cost industry financing” to equip them for all-digital HD broadcasting.

Silenced AM broadcasters would also be offered channels on an expanded FM band, and all FM broadcasters would be required to go digital as well. Such a mandate would clear up the pesky problem of HD’s shunning by receiver manufacturers, though it would set off a Congressional fracas the likes of which the broadcast industry is ill-equipped to counter successfully. HD Radio’s proprietary nature would also make any mandate to use its technology a license to print money, which is precisely why the FCC decided the marketplace would decide HD’s fate more than a decade ago.

Such is the logic of a neoliberal regulatory paradigm: industry will fight attempts at regulation unless it directly benefits them. Broadcasters are quick to decry the FCC – except in this case, when the agency is being cast as a radical last hope for jumpstarting radio’s lifeless digital transition. Combined with iBiquity CEO Robert Struble’s contention that the future of digital radio is analog, in the end, the FM dial stands to become the new AM dial: overcrowded and functionally diminished.

Curiously, Digital Radio Mondiale is name-dropped in the thick of the commentary, as “a topic for a later discussion,” though (it would seem) to be confined as a potential all-digital AM alternative.

I salute industry thinking outside of the box, but abhor the notion that the solution is just another box. All-digital FM-HD is attractive because, relative to AM-HD, FM-HD is functional, robust, and extensible (though it has never been substantively tested). But since the bar for what constitutes “improvement” in digital broadcasting was set so low during HD’s technological and policy development, is it really a viable end-state for all of U.S. radio broadcasting? Unless regulators completely reverse their direction and substantial changes are made to the transparency of HD Radio technology, mandates and migration will be a hard sell, to put it mildly. But if this represents the best industry thinking on radio’s digital future, then the situation must indeed be dire.