REC Networks has identified 75 LPFM stations (which represents less than 4% of all licensed LPFM stations) in where the LPFM station does not meet the §73.807(c) minimum distance separations to these newly filed translators. This does not mean that the LPFM stations have been "displaced", it only means that in the case of new co-channel and first-adjacent channel short spacing, an LPFM station can not move in the future to a location that is closer in distance to the translator (very short moves closer in may be possible as distances between stations are rounded to the nearest kilometer). For LPFM stations that are now second-adjacent channel short spaced, it will mean that a move to a different location may require an interference study and a showing that the proposed moved LPFM station would not cause any interference to any listeners or potential listeners of the short spaced translator.
This report only addresses impacts to an LPFM station's §73.807(c) status and not necessarily the impact of a new FM translator that is where the translator is properly spaced to the translator following the prohibited overlap rules that translators use to protect LPFM stations. Despite the contours not overlapping, interference may be possible because of terrain. LPFM stations that are already licensed and on the air prior to the filing window may have some recourse if they can provide documentation that they have bona-fide disinterested listeners (e.g. those who do not work for the station or their families) within the 60 dBu contour of the proposed translator.
LPFM stations should go to FCCdata.org and enter their community name in the search. This will show all of the stations in the general area. The new translators will normally have "NEW" as the call sign and the call sign of the AM station will also appear on the FCCdata dialscape. Click on that station record to see the estimated 60 dBu protected contour of the proposal.
REC reminds LPFM stations that this FM translator window is currently only in the short-form stage. This means that translator applicants only had to provide very minimal information to the FCC so the FCC can determine which proposals do not have any conflicts and which do. Those without conflicts will eventually go on a public notice which will give the translator applicant 30 days to fill a "long form" to make the formal proposal for the station. Once that long form application passes the normal FCC muster, it will be placed on public notice and put in "Accepted for Filing" status. This will open up a 30 day window in which any affected party can file a formal Petition to Deny or an informal objection against the grant of the translator. At a time after the 30 days runs out and when any objections have been resolved, the FCC will grant the translator applicant a construction permit for a period of 3 years.
Until a translator application has been "accepted for filing", it would not be appropriate to file an objection.
For translator applications that will go to auction, the long form applications will not be filed until the applicant won the auction. Those that lose the auction will be dismissed.
During this process, FM translators will be allowed some opportunity to make minor changes. This means that they can change a channel to one that is 1, 2, 3, 53 or 54 channels away. FM translators do not enjoy the same flexibility to change channels that LPFM has based on reduced interference. An FM translator may also change locations as long as the 60 dBu protected contour of the current location has some kind of overlap with the 60 dBu protected contour of the proposed site.
REC recommends that LPFM stations monitor REC's FCC.today for application activity (and acceptance for filing) as well as the FCC Daily Digest for public notices declaring FM translator applications as singleton.
REC's list of §73.807(c) impacted LPFM stations can be found at:
http://recnet.net/fcc/amfx1_new_shortspace_lpfm.pdf
More information on how FM translators protect LPFM stations can be found here:
https://faq.recnet.net/index.php?sid=126662&lang=en&action=artikel&cat=2&id=102&artlang=en
