As part of the Revitalization of the AM Radio Service Proceeding, the FCC has pulled all the stops, considering a proposal from Bryan Broadcasting Corporation to migrate AM broadcast to all-digital. On November 22, the Commission voted to adopt a Notice of Proposed Rulemaking to solicit comments for the public and broadcasters to completely replace AM analog broadcasts wtih HD Radio in-band on-channel (IBOC) mode known as MA3. MA3 is licensed by Xperi Corporation, which charges an initial $10,000 plus a licensing rate to each participating AM station.
The proposal is not without controversy. While completely migrating to digital will allow superior fidelity, permitting AM broadcasters to better compete with music programming, it is estimated 20% of the vehicle radios out there are equipped with the capacity to receive AM IBOC. Would it be worth giving up the other 80% of possible listeners to pursue an audience eager to hear higher fidelity music on AM? And given the less-than-tepid response to HD radio in general, is the expensive of AM retrofitting worth it? The quality of AM radio, ignoring the possible noise, is entirely suitable for talk formats in analog. Given the popularity of talk podcasts, there is already a wealth of programming already suitable to resonate with new audiences. Also, with the accelerating popularity of mobile streaming, is AM IBOC just too "Boomer" of an idea for any younger music listener to care -- at the expensive of cannibalizing older demographics that would listen to analog AM?
The addition of IBOC "fax noise" to the FM band really has already compromised the excellence of FM analog broadcasting. It is impossible to fathom bleeding fax noise infecting the AM band, possibly making the analog AM listening situation potentially loss viable?
IBOC digital radio has been argued to be short-sighted. DAB, or DAB+, (Eureka 147) has been implemented for digital radio migration in other counties instead of IBOC. The system spectral efficiency of DAB is greater than 3 times that of analog FM (the amount of channels packed within the spectrum). DAB has been a success in some countries (such as UK and Denmark), but not successful at all in Canada.
You may file comments regarding MB Docket 19-311 at FCC's ECFS. The Comment and Reply Comment deadlines have not been published in the Federal Register yet.