The FCC has opened MB Docket 19-193 for comments. In this Notice of Proposed Rulemaking, the FCC has tentatively rejected LP-250 claiming there's not any new information to support it. REC's position is that there has been plenty of new information given to support it through the testimonials and case studies in RM-11749.
The LP-250 that REC proposed in RM-11749 was very simplified using the existing distance separations for co- and first- adjacent channel, increase the second-adjacent spacing requirements and reintroduce intermediate frequency (+/- 10.6 and 10.8 MHz) spacing for stations more than 100 watts ERP. RM-11810 proposed a more complex plan that used a "hybrid" of contour overlap and reduced distance separation (using the former "LP-10" distances making an LCRA argument that they could be used). Both proposals had "foothill protections" for stations that are in higher elevations but with lower HAATs. RM-11810 also included an interference remediation scheme similar to the one used by FM translators.
REC's current position is that a simplified version of LP-250 be reintroduced in 19-193 as a Further Notice of Rulemaking as to not delay a new filing window. REC is currently studying a concept of LP-250 that still addresses the basic need for increased power while addressing some of the concerns raised by the opposition. REC's goal remains to implement this service and this may be our only chance to do so.
Under the revised LP-250 plan:
- A 250 watt at 30 meter HAAT (7.1 km service) contour service.
- LP-250 would only be available as an upgrade to existing LP-100 stations (including those established after a future filing window).
- Once implemented, the FCC should open a filing window that permits LP-100 stations to upgrade to LP-250. To do this, a minimum distance spacing of LP-250 to LP-250 must be met only during the filing window, even if the other station does not upgrade during the window to LP-250. After the initial upgrade window, requests to upgrade or downgrade between LP-100 and LP-250 should be handled as a minor change.
- Distance separation remains the same as LP-100 for co-channel and first-adjacent channel (thus reducing the buffer zone).
- Second adjacent channel distances are increased slightly to reflect the increased LPFM service contour size. LPFM stations currently second-adjacent channel short-spaced to a full-service station will be required to make a showing of lack of intereference at the higher power (larger interfering contour). LPFM stations short-spaced to previously or subsequently authorized broadcast translators on second adjacent channels would not be required to consider the translator in a waiver study.
- REC is currently evaluating the number of stations that would be impacted if a third-adjacent channel requirement was added. Under the third-adjacent channel requirement, any LP-100 station that does not meet the second-adjacent channel distance to a third-adjacent channel full-service FM station would need to make a showing similar to that used for a second adjacent channel waiver. LPFMs would not be required to protect third-adjacent channel FM translators.
- Intermediate Frequency distance separation is required for LPFM facilities with 101 watts ERP or greater. IF can't be waived.
- LPFM stations seeking to operate at LP-250 must include a contour study which shows that there is no contour overlap between the interfering contour of the proposed upgraded LP-250 station and the protected contours of incumbent facilities on co- and first-adjacent channels. This is the so-called "foothill rule". In the event of overlap, the LPFM station may reduce power to the equivalent of 101 watts at 30m HAAT utilizing a nondirectional antenna in order to protect the other station(s).
- LP-250 stations would be subject to the same interference remediation rules that apply to FM translators in §74.1203(a). In the event of a valid showing of interference, the LP-250 station would be required to downgrade to LP-100. There would be no change to the interference policy for LP-100 stations.
More information will be posted soon.