REC opposes any kind of geographic restrictions on LP-250 availability. Several years ago, some groups did ask for geographic restrictions on LP-250 in order to promote a 10 watt LPFM service that no longer exists.
Simple250 permits stations to upgrade to LP-250 as long as the facility meets minimum distance separations and if second-adjacent channel short-spaced, is still able to prevent interference to the short-spaced second adjacecnt channel stations.
Because of spectrum crowding in many metro areas, there will not be many opportunities for upgrades in urban core areas, however if distance separations are met, the upgrade should be allowed.