In addition to gearing up to scrap with the FCC over its definition of journalism, I found the time last week to file some Reply Comments in the agency’s AM Revitalization proceeding.

I kept my comments confined to the FCC’s suggestion that AM stations might begin to adopt the all-digital version of HD Radio. The whole thing (10 pages) is worth a read, but the high points are:

Big decisions about digital radio should be made in the FCC’s ongoing digital radio proceeding. This is a procedural argument that asserts the proper venue for advancing HD-related policy is not the AM revitalization docket. In other proceedings tangential to digital radio where the issue has been raised, the FCC’s deferred all discussions to the digital radio docket, and should maintain that precedent here.

HD Radio is in the throes of market malaise. In its Comments to the AM revitalization proceeding, iBiquity Digital Corporation asserts that the commercial potential of HD Radio is "well established," and cites adoptive figures to make its case. These figures are inflationary at best, and since the agency made marketplace adoption the primary mechanism by which radio’s digital transition would evolve, the actual story is not that rosy.

The bottom line is you can’t make good policy on bad data, and I would argue that right now the FCC has no realistic idea what the marketplace really is for HD Radio.

There’s a growing hunger to explore alternatives to HD on the AM dial. I was surprised by the number of Comments filed in the AM proceeding that suggested exploring Digital Radio Mondiale—a system unencumbered by the software-like and extremely closed intellectual property model of HD Radio, which most broadcasters have rejected on principle. DRM is finding traction on the AM dial elsewhere, particularly in countries that are projected to drive global economic growth in the 21st century.

At this point in the U.S. digital radio transition, what is there to lose by learning a bit more about DRM? Perhaps even the threat of competition may inspire HD’s proponents to address the system’s fundamental detriments.

The hardest things about writing documents for policy purposes are keeping an even tone and buying into the marketplace paradigm that pervades modern policymaking. Now that I’m between books, I plan to devote more time to participating in stuff like this—it’s something communications scholars in general don’t often do, but should do a lot more of.