REC Networks has filed Reply Comments with the FCC today in MB Docket 18-119 relating to proposed changes to the rules regarding interference by proposed or newly constructed FM translator stations to existing broadcast stations including LPFM stations.
In REC's reply, we have aligned with many of the comments filed by the LPFM Coalition in regards to various issues including:
- Opposition to a minimum number of LPFM listener complaints required for action by the Commission - This is due to the much smaller service areas that LPFM stations have in comparison to full-service stations and other reasons such as listener privacy concerns.
- Definition of "disinterested" and "interested" parties. - Who can and can't be a complainant listener.
- Opposing the requirement for a statement that a listener is a "regular listener" and listens at least twice a month. - What if they only listen for a city council meeting that airs once a month?
- Opposing an outer limit based on contours where a complainant listener can be located in order for action to take place. - The LPFM Coalition clearly demonstrates how many LPFM listeners who may be outside the FCC designated contours can still receive a station with an adequate field strength.
REC opposed the LPFM Coalition's proposal to require an anti-preclusion study or other showing that future LPFM opportunities will be taken away if an existing FM translator needs to change to a non-adjacent channel citing Section 5 of the Local Community Radio Act (LCRA). REC's position is that Section 5 of the LCRA only relates to new FM translators and not to changes made by existing translators. REC supports rulemaking that would put LPFM stations and FM translators on a level playing field where it comes to channel changes.
REC also opposed proposals to hold off on this proceeding until after the FCC makes a decision on RM-11810, REC's LPFM restructuring petition for rulemaking. REC also opposed calls for FM translators carrying AM stations to be afforded primary service and for FM translators carrying AM stations to be given priority over translators carrying "HD" FM services (as these would be statutorily prohibited under the LCRA), and for fill-in FM translators for smaller FM broadcast stations to increase their service contour sizes for fill-in areas to be comparable with AM stations.
The LPFM Coalition consists of Prometheus Radio Project, Common Frequency, Media Alliance of the Pacific Felt Factory and dozens of LPFM stations, mainly from the Cause-based and Community Media segments. Since their original comment filing in MB Docket 18-119, the LPFM Coalition has grown to over 100 LPFM stations in multiple segments.
Corrected to remove reference to LPFM Coalation's involvement in the Informal Objections filed against nearly 1,000 translators. That filing was not made by the LPFM Coalition but instead was made jointly by Prometheus Radio Project, Common Frequency and Center for International Media Action. REC apologizes for this error.
Reply comments on MB Docket 18-119 are due by end of day today, September 5, 2018.
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About REC Networks: REC is a leading policy voice supporting a citizen’s ability to access radio spectrum. The advocacy side of REC was responsible for the writing of RM-11749, the 250-watt LPFM proposal and RM-11810, the LPFM improvement petition. Other REC advocacy initiatives include alternate spectrum for community radio expansion in areas where FM spectrum is not available, driving changes to the FCC rules to allow more flexibility for LPFM stations while remaining compliant with the Local Community Radio Act. REC serves all six segments of LPFM including cause-based organizations, public sector agencies, micro radio stations, community media organizations, secular educational organizations and faith-based organizations. REC also provides consulting and filing services for LPFM stations, FM translators (including FM translators related to smaller AM broadcast stations) and full-service FM stations. REC operates several radiocommunications related websites and REC-FM, the official audio stream of REC Networks in conjunction with the Riverton Radio Project. More information about REC is at our website http://recnet.com.
