In our discussions with FCC staff, both sides agree that the addition of a new class of service would have no impact on a future filing window as existing and new LPFM stations would be able to upgrade in the future. It is REC's position that LP-250 not be made available for new stations during a filing window. Instead, original applications should be limited to LP-100 in order to guage demand for new stations and to reduce the size of competitive (mutually exclusive) groups.
RM-11909 REC "Simple 250" Petition for Rulemaking
