REPORT ON AM BROADCASTING

POSSIBILITIES IN THE GREATER

TORONTO AREA

Contract U4240-0-0034Douglas R. Forde

FINALApril 17, 2001

TABLE OF CONTENTS

1. Executive Summary

2. Acknowledgements

3. Historical Perspective

4. Rules and Agreements4.1 Rules needing review

5. Overview of all AM Channels

6. Review by Channel

Appendix 1. Letter from Gordon Elder on sharing Toronto Island sites

Appendix 2. Studies required to assess feasibility of second adjacent channel co-siting

1. Executive Summary

This report relates to AM broadcasting aspects of Industry Canada’s response to CRTC PublicNotice 2001-10, “Report to the Governor in Council on measures to ensure that the residents ofthe Greater Toronto Area receive a range of radio services reflective of the diversity of theirlanguages and cultures”. It contains the author’s analysis of the engineering report which theCRTC commissioned from Imagineering Limited on this topic, as well as the results of his ownstudies.

The Imagineering report reviews all current radio broadcasting bands and providesrecommendations on each. The following table contains a summary of the possibilities in theAM band identified by Imagineering or the author:

Channel Potential Coverage(km in max. dir.)

Comments

Day Night790 70 11 Suitable site unlikely to be found. Could operate at lower

parameters if colocated with existing station near market.940 70 2 Requires exception to night-time protection rules. Siting

would be difficult. Could operate at lower parameters ifcolocated with existing station near market.. Mutuallyexclusive with 950.

950 80 30 Former Barrie station. Needs access to port lands site.1100 50 0 Day only. Mutually exclusive with 1110.1110 120 2 Can share Toronto Island site1190 90 0 Day only. Mutually exclusive with 1200.1200 80/120 10/35 From Oakville site/ from port lands site1280 0* 0* *Protection requirements preclude operation near

lakeshore or serving downtown Toronto. Could operate ator slightly above LP parameters to serve communities notnear Lake Ontario, but would displace LP station CFYZserving Pearson Airport

1470 ** 25** Formerly used by CHOW Welland and fully equipped siteavailable for sale. Serves most of GTA daytime, butsubject to interference at night. Moving closer to Torontois possible if CHKT’s Toronto Island site can be shared. **From Island site, cannot serve west part of GTA day. Could use 1480 or 1500 day.

1480 40 3 Formerly used by CKAN Newmarket; site dismantled. Difficult to serve much of GTA at night. Mutuallyexclusive with 1470 and 1500.

1500 85 6 Siting difficult for night operation. Day can site anywhereand could have 60 km non-directional service.. Mutuallyexclusive with 1480.

1580 70(ND) 4 Requires exception to night-time protection rules.1610*** 70 12-25 LP station CHEV would be displaced. Markham

application would serve only NE corner of GTA night

1630*** 70 12-25

1650*** 70 12-25 May be incompatible with application on 1670.

1670*** 70 12-25 East York application could switch to 1650 or 1690 toensure availability of third channel

1690*** 70 12-25 May be incompatible with application on 1670.***There is a possibility that five stations could be cosited 20 kHz apart from 1610 to 1690 kHz. Two relatively simple studies, outlined in Appendix 2, are required to determine if this ispractical. In case the 20 kHz cositing is not practical, it is recommended that the 1670 kHzapplicant be requested or required to revise his application to 1650 or 1690 kHz to permit anadditional station in the GTA.

Siting Considerations

Good coverage of the GTA, particularly downtown Toronto, requires a lakeshore or TorontoIsland site for the high AM channels. Multilingual stations CHKT on 1430 kHz and CHIN on1540 kHz currently use Toronto Island sites, which could potentially be shared with new stationson two other channels. (See Appendix 1, a letter from J. Gordon Elder, P. Eng., who designedand built these two stations.) In addition, the port lands and Leslie Street Spit area shown inFigure 2.3c of the Imagineering report would be a very good location for at least two otherchannels below 1600 kHz, as well as any or all of the five available channels in the expandedband.

The white box in the map below shows the approximate boundary of the GTA.

2. ACKNOWLEDGEMENTS

I wish to acknowledge and thank Jean Alain of the Broadcast Applications Engineering Divisionfor the excellent technical support, especially the provision of the maps included in the report.

Thanks are also due to Paul Vaccani and Kirit Mehta for their excellent constructive commentsand ideas, and to both Kirit and Jean for ensuring that I had the necessary software and materialsto carry out this project.

I also acknowledge with thanks the contribution of Gordon Elder, whose expert analysis of thepossiblity of sharing the existing Toronto Island facilities which he designed and built, are shownin Appendix 1.

3. HISTORICAL PERSPECTIVE

AM broadcasting has existed since the early 1900s, the first commercial station being CFCFMontreal on 600 kHz. The first international agreement was the 1937 North American RegionalBroadcasting Agreement (NARBA), revised in 1950 when the top of the band was moved from1550 to 1600 kHz. This agreement included, though not all at the same time, Canada, USA,Mexico, Bahamas, Dominican Republic and Cuba. It included basic protection criteria which arestill mostly applicable today. It also included a division of channels, with some “clear” channelsdesignated for national coverage, a good number of regional channels which generally werecapable of serving large metropolitan areas and a few local channels intended for simpleinexpensive operations to serve small cities and towns.

In 1982, with the signing of the ITU Region 2 Agreement (Rio 1982 Agreement), the channeldesignations in NARBA were replaced by class designations. The “clear” channels werereplaced by class A which have substantial, but not national, service contours. The local channelstations became class C, mostly 1000 watts non-directional, and everything else became class B. Simultaneously with ratifying the Rio 1982 Agreement, Canada abrogated, i.e. officiallywithdrew from, NARBA The Region 2 agreement was complemented in 1984 by a bilateralagreement between Canada and the USA which elaborated the technical criteria somewhat andadded a number of allotments which made use of the relaxed protection of the former clearchannel stations. Many of these allotments were quickly taken up by existing stations to improvetheir coverage. For example, CFGO Ottawa improved day and night service moving from 1440to 1200 kHz, and CFGM (now CFYI) Richmond Hill, which had fairly good day service and verylimited night service on 1320 kHz, now serves the entire GTA, day and night, on 640 kHz. Figures 1 shows the present coverage of this station, which is typical of the low frequency, highpower Toronto stations located south of Lake Ontario. Of these former clear channels, only 1200kHz and possibly 1500 kHz still offer the possibility of new service both day and night in theGTA.

In 1988 another Region 2 agreement expanded the AM broadcasting band upwards from 1600 to1700 kHz. This agreement divided the ten new channels equally among neighbouring countriesin border areas, eg. 1610, 1630, 1650, 1670 and 1690 kHz for Canada and 1620, 1640, 1660,1680 and 1700 kHz for the USA. On its “priority channel”, a country can put a 1 kW non-directional station anywhere within the area designated in the Agreement or can increase powerup to 10 kW provided that interference would be no worse than could be caused by a 1 kWstation at the border. This “expanded band” has hardly been used in Canada with only a few lowpower stations, mostly on 1610 kHz. It offers good possibilities for ethnic broadcasting in theGTA and includes two current applications.

A practice in the 1990s by AM stations with modest service who were also looking for the higherfidelity available in the FM band was what the CRTC referred to as AM-FM flips. This has alsoleft a few AM channels which can provide a degree of service in the GTA. Most notable is theformer CBC channel of 740 kHz, which has superb GTA coverage. This channel has been takenover by a new operator, who is leasing the CBC facilities and using them exactly as before. A bi-product of this is that the new operator, who already operated an ethnic station in the GTA has

increased the ethnic programming on that station Three other interesting channels, which arestudied in detail, are 950 kHz from Barrie, 1390 kHz from Ajax and 1470 kHz from Welland.

Figure 1 The outer (black) contour is the official day coverage of CFYI. The inner contour isthe official night coverage of CFYI.

DAY

NIGHT

4. RULES AND AGREEMENTS

Industry Canada’s main regulatory document pertaining to AM broadcasting is BroadcastProcedures and Rules 2 (BPR2), supplemented by general provisions in BPR 1. However, mostof the technical criteria to be met by AM applications are found in the 1984 bilateral agreementbetween Canada and the USA which is referenced in BPR 2.

With propagation being much more complex in the AM band than in the VHF and UHF bandsused by FM and TV broadcasting, separation distance tables are impractical and protection frominterference is obtained using protected contours and ratios. There are two propagation modes inAM broadcasting, groundwave, where the signal travels along the surface of the earth andattenuation varies with the type of terrain, and skywave, where the signal is reflected off theionosphere. Groundwave propagation occurs day and night and varies with frequency as well asterrain. Skywave propagation occurs only at night because of the sun’s affect on the ionosphere. Thus rules differ from day to night, although the same protection ratios apply. The protectedcontour day-time is generally 0.5 mV/m and is noise limited. The protected contour night-time isgenerally interference limited and is calculated for each station.

As mentioned in the Historical Perspective section, there are three classes of station:

Class A, 50 kW maximum power, protected to 0.1 mV/m contour day and 0.5 mV/m skywavecontour nightThere are very few class A stations and most use 50 kW with either a non-directional or simpledirectional antenna. Coverage generally exceeds 100 km day and can exceed 1000 km at night.

Class B, 50 kW maximum power, protected to 0.5 mV/m contour day and 2.5 mV/m or existinginterference level at night, whichever is greater.There are many class B stations with powers ranging from 100 watts to 50 kW, some with verycomplex directional antennas. Some, mainly in the USA, operate only in the day because theycannot meet protection rules at night. Coverage can range from about 20 km to well over 100 kmday, and from a few km to 50 km or more at night.

Class C, 1 kW maximum power, protected to 0.5 mV/m contour day and 4 mV/m or existinginterference level at night, whichever is greater.There are many class C channels, most with 1 kW non-directional power on the former NARBAlocal channels. Coverage ranges from about 10 to 50 km day, and from about 2 to 15 km atnight.

Protection ratios are:co-channel: 20 dB1st adjacent: 0 dB2nd adjacent: -20 dB

There is a 0 dB protection ratio for image interference (900 to 920 kHz apart), but exceptions areoften made to this rule with little impact. It should be reviewed with modern receivers. There is

also a prohibition of overlap of 25 mV/m contours for third adjacent channels.

As noted in the Historical Perspective section of this report, the “expanded band” 1610-1700 kHzis subject to a different agreement, which brings in the concept of “priority channel”. Theparticulars of that concept are described in that section. Other than that difference, the rulesabove apply. Stations in this band are treated as class C, although they can raise power to 10 kWprovided they would not cause more interference than a 1 kW non-directional station at theborder.

4.1 Rules Needing Review

Imagineering notes three rules which should be reviewed:

1. Night-time protection of Class A stationsSince no protection of skywave service has been required of adjacent channel stations, erosion ofthat service has resulted. This rule can be looked at from two aspects, both of which could beadopted:a) Class A stations should be protected only to their interference-free contour.b) Protection from adjacent channel interference should be added.Even if the rule is not changed, it can be waived on a case-by-case basis where circumstanceswarrant.

2. Image interferenceExceptions to the image rule rule have been made frequently, accompanied by a commitment toresolve interference complaints. To the best of my knowledge, such complaints are rare, if theyoccur at all. Receivers should be tested to see if this rule can be deleted.

3. Third adjacent channel 25 mV/m overlap ruleExceptions to this rule have been much less common, but again they have not created seriousproblems. Again receiver testing can provide an indication whether the rule should remain or beamended. This criterion may be frequency sensitive, a factor to consider in the testing.

I recommend that a B-TAC subcommittee look into these rules. Even if the rules are retained,exceptions should (continue to) be granted when circumstances warrant.

5. OVERVIEW OF ALL AM CHANNELS

CHANNELkHz

STATIONS PRECLUDING USE OF CHANNEL

CO-CHANNEL ADJACENT

530 CIAO Brampton540 CBEF Windsor 530 CIAO Brampton550 WGR Buffalo NY560 CFOS Owen Sound570 CHYM Kitchener580 590 CJCL Toronto590 CJCL Toronto600 590 CJCL Toronto610 CKTB St Catharines620 610 CKTB St Catharines630 640 CFYI Richmond Hill640 CFYI Richmond Hill650 640 CFYI Richmond Hill660 WFAN New York NY670 680 CFTR Toronto680 CFTR Toronto690 680 CFTR Toronto700 710 CJRN Niagara Falls710 CJRN Niagara Falls720 710 CJRN Niagara Falls730 740 CHWO Toronto740 CHWO Toronto750 740 CHWO Toronto760 WJR Detroit MI770 WABC New York780 790 Brampton790 can use 790 Brampton800 CKLW Windsor 790 Brampton810 820 CHAM Hamilton820 CHAM Hamilton

830 820 CHAM Hamilton840 WHAS Louisville KY850 860 CJBC Toronto860 CJBC Toronto870 860 CJBC Toronto880 WCBS New York NY890 900 CHML Hamilton900 CHML Hamilton910 CKLY Lindsay 900 CHML Hamilton920 CKNX Wingham930 WBEN Buffalo NY940 can use950 can use Barrie allotment960 Cambridge970 WNED Buffalo NY980 CKRU Peterborough990 WDCZ Rochester NY1000 1010 CFRB Toronto1010 CFRB Toronto1020 1010 CFRB Toronto1030 WYSL Avon NY1040 1050 CHUM Toronto1050 CHUM Toronto1060 1050 CHUM Toronto1070 CHOK Sarnia1080 WUFO Amherst NY1090 CKKW Kitchener1100 can use day-time1110 can use with limited night operation1120 WHTT Buffalo NY1130 WBBM Chicago IL1140 1150 CKOC Hamilton1150 CKOC Hamilton

1160 1150 CKOC Hamilton1170 WWVA Wheeling WV1180 1190 Mississauga1190 can use 1190 Mississauga day-time1200 can use Tillsonburg allotment 1190 Mississauga1210 WPHT Philadelphia PA1220 WKNR Cleveland OH1230 WECK Cheektowaga NY1240 1250 CJYE Oakville1250 CJYE Oakville1260 1250 CJYE Oakville1270 WHLY Niagara Falls NY1280 LP CFYZ Toronto Airport-see 1280

in Review by Channels1290 CJBK London1300 WXRL Lancaster NY1310 1320 CJMR Oakville1320 CJMR Oakville1330 1320 CJMR Oakville1340 1350 CKDO Oshawa1350 CKDO Oshawa1360 1350 CKDO Oshawa1370 WXXI Rochester NY1380 CKPC Brantford1390 can use Ajax allotment1400 WWNS Buffalo NY1410 CKSL London1420 CKPT Peterborough 1430 CHKT Toronto1430 CHKT Toronto1440 WJJL Niagara Falls NY 1430 CHKT Toronto1450 CHUC Cobourg1460 CJOY Guelph1470 can use 1470 Welland allotment;

CJOY limits day coverage in west1470 night combined with 1480or 1500 day

1480 can use 1480 Newmarket allotment1490 WBTA Batavia NY1500 can use day-time1510 CKOT Tillsonburg1520 WWKB Buffalo NY1530 1540 CHIN Toronto1540 CHIN Toronto1550 1540 CHIN Toronto1560 WQEW New York NY1570 WBUZ Fredonia NY1580 can use day-time, night use

questionable; may conflict with 16101590 WASB Brockport NY1600 Simcoe1610 LP CHEV Toronto, Markham

application*1620 US channel1630 *see below1640 US channel1650 can use if 1670 kHz application

moves to 1690*1660 US channel1670 application (should move to 1650 or

1690)*1680 US channel1690 can use if 1670 kHz application

moves to 1650*1700 US channel

*If appropriate combining and filtering equipment can be obtained, using all five expanded bandchannels at the same site is possible. See Appendix 2.

The shaded channels are available to serve all or part of the GTA. The type face used indicatesroughly the value of the channel as follows:Type face Bold Italics Normal

Day coverage all GTA all or most of GTA majority of GTA

Night coverage majority of GTA city core part or none

6. REVIEW BY CHANNEL

790 kHzThis channel was formerly used by CIAO Brampton and Imagineering notes the difficultiesassociated with operation at the old site, as well as finding an appropriate new site. They notethat this channel has some potential as a very small one or 2-tower operation co-sited with anexisting Toronto station close to the intended market. I concur that there are too manyconstraints, both day and night, to rebuild a 5 kW station. However, with the relatively lowfrequency and Eu, the possibility of serving part of the GTA at reasonable cost exists.

940 kHzImagineering notes that use of this new channel would require relaxation of day-time protectionrequirements to an adjacent channel allotment in Barrie and night-time protection requirementsto CINW Montreal. My analysis of these possible rule exceptions is shown below. Imagineeringalso notes that day-time coverage would be limited by interference from WBEN Buffalo NY on930 kHz. The corollary to this is that the new station would wipe out existing reception ofWBEN in the GTA. Such reception is, of course, not protected, but loss of it presents a potentialpublic relations problem. Add in the very limited night service, even if the rules are relaxed, andthis is not a desirable channel, but I would not rule it out because of the high demand.

My analysis of night-time interference to CINW shows that the border points in southern ON -the 0.5 mV/m contour extends beyond the border - are subject to some co-channel and adjacentchannel interference. Along the southern QC border, CINW’s signal is strong enough that it isprotected on a ratio basis. In eastern Canada, adjacent channel interference is severe from strongsignals on 930 kHz and there would be no usable service. Also, the western limits of theskywave contour are subjected to both co-channel and adjacent channel (950 kHz) interference ofsignificant magnitude. It would be reasonable to permit an applicant to establish an interference-free contour for CINW, skywave or groundwave, whichever extends further, and protect that.Concerning the adjacent channel allotment in Barrie, I would favour relaxing day-time protectioncriteria for these reasons:1. A station is more valuable than an allotment in terms of service to the public.2. The Barrie allotment was abandoned by CKBB because a good FM channel was available. This is not the case in Toronto.

950 kHzAn alternative to using 940 kHz is moving the 950 kHz Barrie allotment to Toronto. The 3-tower 2.5 kW night pattern formerly used at Barrie would need only a minor adjustment toprotect CKNB Campbellton NB. The Eu drops from 22 to 18 with the move south, quite ausable value. This does not appear to be possible using existing towers The port lands and LeslieStreet Spit area shown in Figure 2.3c of the Imagineering report would work with the Barrienight pattern rotated four degrees counterclockwise. A 1 kW day operation is also possible fromthis site, though it would conflict with the 960 kHz allotment at Cambridge. Alternately, astation could use 940 kHz day-time and 950 at night. If a 1200 kHz operation is also built at thissite, the 950 kHz could probably be designed to share the same towers. (The reverse is not truebecause the constraints on 1200 kHz are more severe.)

The following map shows the predicted day and night coverage for these parameters.

Figure 950.1 Coverage from possible 950 kHz operation in port lands

1100 kHzImagineering notes that this would be a day-time only operation, with interference-limitedcoverage because of class A station WTAM Cleveland OH. This channel is even less desirablethan 940 kHz, except that it does not require rule-bending.

1110 kHzAn alternative to 1100, this channel was formerly used at Sarnia ON and can be used day-time atany existing site with a day-time power up to 50 kW. Night use would be severely limitedbecause of protection requirements to two US class A stations. Possibilities are a multi-toweroperation with 1 kW or less and a directional antenna (DA) pattern aimed due north or lowpower in the order of 10 watts. I could not find an existing site which could accommodate thenecessary DA. Figure 1110.1 shows possible day coverage using two towers from CKHT’sToronto Island site. Figure 1110.2 shows day urban coverage (25 mV/m) and coverage from a 20watt night operation using the same towers.

Figure 1110.1 Possible day coverage on 1110 kHz from CHKT site

Figure 1110.2Urban strength day coverage and night coverage on 1110 kHz from CHKT site

DAY 25 MV/M

NIGHT

1190 kHzThis day-time only channel was formerly used in Mississauga and provided good day service. Itcan be co-sited with any station north of the lake.

1200 kHzAn alternative to 1190 is 1200 kHz. This channel was intended for day-time station CKOTTillsonburg ON, but the latter has not filed an application despite the availability of a reasonablenight-time operation and a day-time operation comparable to or better than its current 1510 kHz. This channel would not be quite as good as 1190 day-time, but could serve part of the GTA atnight.The ideal location to serve Toronto with 1200 kHz would be Toronto Island, but the antennaarrays there are not suitably oriented to provide necessary protections with reasonable power. The best antenna array from that aspect is that of CJMR/CJYE Oakville. I have designed a 700watt night pattern whose coverage is shown in Figure 1200.1. I could only meet day-timeprotections from that site with a 4 kW operation, coverage also shown in Figure 1200.1. If anapplicant wants more extensive day coverage, 1190 kHz is available.

Figure 1200.1 Possible coverage on 1200 kHz from CJMR site. Day - outer black contour; night - inner red contour

DAY

NIGHT

Since the 950 kHz night pattern is similar to the pattern required for 1200 kHz at night, I triedusing the towers which produced the coverage shown in 950.1 from a site in the port landsidentified by Imagineering as a good location, if available. This was unsuccessful, so I triedmoving the array from the Tillsonburg 1200 kHz allotment to that site. With an adjustment ofphases, this worked and the possible coverage from this 10 kW operation is shown below. A dayoperation at 25 kW with the same antenna pattern is possible.

Figure 1200.2Possible coverage on 1200 kHz from port lands siteDay - outer black contour; night - inner red contour

DAY

NIGHT

1280 kHzThis channel was formerly used in Hamilton and is now used by low power information stationCFYZ at Pearson Airport. Imagineering concludes that this channel cannot be used near thelakeshore because of co-channel protection requirements to WHTK Rochester NY. This meansthat only communities away from the shore could be served and I doubt whether coveragesignificantly superior to what CFYZ has could be obtained. In summary, this is not a viableoption for an ethnic broadcasting service.

1390 kHzThis Ajax allotment is based on the operation of former station CHOO. Since the main day-timeconstraint is to the southwest (CKPC Brantford), a suitable site southwest of Toronto was sought,with the site of CJMR/CJYE Oakville seeming appropriate. A 3 kW night pattern was designedusing four of the towers in the 7-tower array. Unfortunately, this site is too close to the protectedcontour of adjacent channel station CKPC Brantford to provide day service. A 3 kW dayoperation from CHKT’s site on Toronto Island is possible using 4 existing towers and twoadditional towers located between them. Unfortunately, this array is not as well suited tomeeting night protections and I could only obtain a 1 kW operation using a different 6-towercombination. However, most applicants would still consider it a more desirable coverage thanthe 3 kW possibility from the western site. The three contours are shown in Figure 1390.1.

Figure 1390.1Possible day and night coverage from CKHT site and night from CJMR site

DAY

NIGHT FROM ISLAND

NIGHT FROM OAKVILLE

1470 kHzRecently used by CHOW Welland, Imagineering states that the site and antenna array are intactand for sale. They would provide an applicant with deep pockets instant day-time coverage ofmuch of the GTA while he looks into moving the operation closer to Toronto for full-timecoverage. Imagineering notes the conflict with the 1480 kHz Newmarket allotment if 1470 ismoved north. I note, however, that the previous user of the Newmarket allotment was neversatisfied with his service, particularly the very limited night service, and eventually shut down. Thus, if faced with a choice of keeping 1480 or getting a good GTA service on 1470, my choicewould be the latter. Imagineering did not think that co-siting on Toronto Island would bepractical, but I consulted Gordon Elder, P. Eng., who designed and built the two existing AMoperations on the island, and his response is given in Appendix 1. Mr. Elder comments that 1480kHz could provide better day service to the western part of the GTA. A possible option, maybetoo costly, is to use 1480 or 1500 day-time and 1470 at night. A precedent for such a twochannel operation existed in Leamington where a station operated on 710 kHz day-time as CHIRand switched to 730 kHz at night as CHYR. This twin operation carried on from the 1970s tillrecently when the station switched to FM. Possible night parameters, using CHKT’s existingantenna array at 3 kW follow. Figure 1470.1 shows predicted coverage with these parameters. Figure 1470.2 shows the overlap between CJOY Guelph on 1460 kHz and a day operation usingthe night parameters at 10 kW, confirming Mr. Elder’s comments.

Figure 1470.1Possible night coverage on 1470 kHz from CKHT site

Figure 1470.2Overlap of possible 1470 kHz day contour with CJOY Guelph on 1460 kHz

1470 day

CJOY

1480 kHzImagineering points out the limitations of this channel and do not see it as a practical alternativefor serving the GTA, especially since it would preclude use of 1470 kHz. My initial reaction wasto concur, but due to the comments in the appended letter from Gordon Elder about 1480offering better day-time service, I decided to look more closely and my analysis follows.

The best location for 1480 kHz to serve the GTA from is Toronto Island. With the limiteddesign software available at Industry Canada, I came close to meeting protection requirementswith a 1 kW night pattern using CHKT’s towers. With an Eu of 30 mV/m, this will not providemuch service and I do not consider this to be a practical option.

1500 kHzImagineering suggests this as a day only channel. This could work with 1470 kHz, if cosited orif we waive the third adjacent channel protection rule. It would probably not work with 1480kHz unless day coverage were limited to what is available on 1480. An alternate possibility is touse 1470 kHz at night and 1500 in the day-time.

1580 kHzImagineering notes that use of this new channel would require relaxation of night-time protectionrequirements to CBJ Chicoutimi QC. My assessment of that proposal is shown below. Sitingneeds to be chosen with care to avoid image problems with CFTR on 680 kHz and third adjacentchannel problems with 1610 kHz. If it comes down to a choice between 1580 or 1610, the latteroffers much better night service and is preferable.

1610, 1630, 1650, 1670 and 1690 kHzIt is theoretically possible to use all five channels if they are co-sited and use nearly identicalparameters. Currently, there is an application on 1610 kHz at Markham ON with 10 kW day and5 kW night, 2-tower directional antenna, which appears to meet the bilateral agreement criteriaand would provide fairly good GTA coverage day-time, but only serve the north-east part of theGTA at night. There is also an application in East York on 1670 kHz with 10 kW day and 1 kWnight, non-directional, which may meet the bilateral agreement criteria, and would provideadequate GTA coverage day-time and downtown service at night. If suitable filtering andcombining equipment could be found, the East York site could be used for a 5-station operation. While it would be costly to combine the five signals and may require some compromise inbandwidth, the cost savings of a single site operation would be significant. This option definitelymerits further study. See appendix 2.

If it is not practical to combine signals separated by 20 kHz, the 1670 kHz applicant should beasked, perhaps required, to apply for 1650 or 1690 kHz instead. This would at least allow threeexpanded band stations in the GTA.

Optimum service to the GTA on these channels could only be provided from Toronto Island orthe port lands using a simple directional pattern and 10 kW day and night. If these areas are notavailable, the East York proposal mentioned above is a fairly good second choice.

APPENDIX 1

LETTER FROM GORDON ELDER ON SHARING TORONTO ISLAND SITES

APPENDIX 2

STUDIES REQUIRED TO ASSESS FEASIBILITY OF SECOND ADJACENTCHANNEL CO-SITING

1. Filtering and combining equipment

Vendors of filtering and combining equipment for AM broadcasting should be surveyed todetermine whether it is technically feasible to design and build equipment to combine up to fivesignals 20 kHz apart in the 1600-1700 kHz band. A first approximation of cost to build andinstall should also be obtained.

2. Receiver testing

A sample of current receivers should be tested to determine whether the existence of multiplesignals would create destructive beats across the AM band. The tests should use signal levels ashigh as practical to simulate conditions near the broadcasting site. DGSE’s laboratory is capableof undertaking such tests.