I doubt you have the data to substantiate the first two points, and you're dead wrong on the third. 64kbps s enough to deliver decent audio equivalent to an FM radio stream, and it's doable over EDGE.
On the other hand, adding an FM radio adds another antenna to the mix (or you could leave it out if you want the receiver to be unreliable except for the strongest of stations) would require yet another app on the home screen to control it whether you want it or not, and adds battery drain in addition to the 3G radio which will run concurrently with the FM and WiFi gear.
It's also not a valid argument that FM radios are scarce. I have FM radios, in my house and in my car. I don't listen to them, and haven't deliberately done so in years.
This isn't about public safety in the least. The NAB is trying to legislate the foisting of old technology on electronics vendors in the vain hope that it will compel people to listen to FM stations, without their constituency having to make an effort. Where should this type of nanny-state legislation stop? How about we pass laws that require every US resident to subscribe to a minimum level of cable TV service, since Over-the-air or satellite TV might be subject to weather conditions or transmitter failures due to terrorists attacks, and FiOS/UVerse are simply too new? How about we also mandate that every household subscribe to copper POTS wirelines phone service (again, Fiber is "too new" and untested) and connect rotary corded phones to that service?
What the NAB don't understand is, people like me aren't listening to FM not because we don't have FM radios, but because the stations we can receive on those radios provide us with no reason to listen. Perhaps if they innovated, and provided compelling programming, and didn't play the same 6 songs over and over between 20+ minutes of a commercials per hour, their audience numbers would grow.
What's worse, most of these FM radio stations no longer have news departments of their own, and are not equipped to provide news and information on their own in a serious crisis or emergency. In fact, during past crises, since September 11 on, many have tended to cut over to the audio of CNN or similar news feeds. So... what's the point? A potential listener like me could just go to CNN to get the video that goes with the audio.
There are entities like satellite radio, online broadcasting stations and online music stores that don't mandate by law that everyone be forced to own equipment capable of receiving their content, and yet they do just fine. The NAB could learn from their example.
There is never a good reason to force regulatory inclusion of obsolete technology that delivers irrelevant dreck. If you want lawmakers to make laws, then lobby them to focus on enforcing strengthening current and relevant technologies to have the reliability they should have.
decided not to implement on theirs...
