FAQ: What is REC's "Viable Time Sharing" proposal?
As a result of the Commission's proposal in MB Docket 19-3 which would have clarified that time sharing groups can be pre-planned, even before the filing of applications, REC testified before the Audio Division prior to the release of the NPRM that such a proposal encourages gamesmanship through "point stacking" thus giving these groups an unfair advantage over other groups that are intending to play fair and square. This Commission proposal is the only item on 19-3 that REC has a strong opposition to.
During that presentation to Staff, REC counterproposed a Viable Time Sharing concept that is intended to bring groups together and facilitate a more proper sharing of a very limited resource. Under the Viable Time Sharing concept:
- All time share proponents must propose at least 36 hours of operation per week (current rules only require 10 hours).
- Each proponent must specify a minimum of 5 contiguous hours per day, 5 days per week between 6AM and 12 Midnight.
- All proponents must operate from separate transmission facilities. No co-location is permitted.
- All time between 6AM and 12 Midnight, Monday through Saturday must be scheduled to a time share proponent.
- By design, time share groups would not be able to exceed three proponents (this meaning a maximum of 15 points).
- In the event of a tie, the time share proposal with the most aggregated community presence would be awarded the grant.
It is also important to note that in the NPRM, the FCC is considering a change in policy of reapportioning time in the event that a time share proponent has their permit or license cancelled after it was granted. Current rules allow the surviving station(s) to reapportion that time to their stations. The FCC is proposing a "mini-window" concept where in the event that a permit or license of a time share proponent is cancelled, the time is reserved and then made available to a new entrant through a mini-window. REC supports the concept of mini-windows however such a mini-window would not be viable for the applicant and would be burdensome on staff if the time available is only 10 hours, especially if it is in the middle of the night. Viable Time Share makes sure that any time offered in a mini-window is substantial and worth the 5-figure investment that many organizations would have to make in order to build an LPFM station.
REC's Voluntary Time Sharing concept appears in Docket 19-3 as an ex parte presentation and we invite interested parties to address it in their comments and reply comments.