REC Networks has filed comments with the FCC in MM Docket 99-25 in response to two comments that were recently filed. The comments were filed by a group of 21 broadcasters who have pending applications for translators under the Auction 83 window. The other comments were filed by religious broadcaster Educational Media Foundation (K-Love & Air-1) who also has pending Auction 83 applications.
While there was a previous agreement between Prometheus Radio Project and EMF, REC offers an alternative plan that may be more compliant with the stipulations of the recently passed Local Community Radio Act.
REC's plan calls for the translator applications to continue if throughout the translator's service contour, the area that consists of at least 70% of the contour's population can apply for at least 2 LP-100 channels. LP-10 channels and second adjacent waivers would not satisfy this requirement.
In comments, REC also raises disapproval for the speculation in this window that has resulted in millions of dollars of profit being made by various speculators who filed for free non-commercial applications.
In comments, REC has asked that applicants who had no broadcast holdings prior to the 2003 window be excluded from further consideration, that all translator applications be screened and those that are defective (such as 250 watt stations in Los Angeles on mountaintops) are dismissed and for the remaining applications, priority is given to AM and FM fill-in services before given to nearby and distant FM stations. REC also asks for a "one per customer" rule for translators that cover the same significant area.
To bring LPFM to a closer playing field, REC recommends removal of IF channel protections, increases the number of "sub-classes" of translators from 3 to 8, modifies protections to LPTV stations to open more channels below 92 MHz and look at doing a study to determine the feasibility of using 3 channels below 88 MHz for LPFM services.
While we continue to support the efforts of other organizations such as Prometheus, we want to bring alternative ideas to the table for consideration by the FCC, LPFM proponents and translator applicants.
A copy of our filing is available at:
http://www.recnet.com/fcc/99-25_0111.pdf
