REC Networks filed comments in Engineering and Technology (ET) Docket 10-235 which related, in part, to the improvement of the VHF television broadcast service.
In the filing, we reinforced our position due to the minimal number of new opportuntiies for LPFM stations in major urban areas despite the passing of the Local Community Radio Act that the spectrum of TV Channel 6 (or Channel 5 in some areas) be allocated to LPFM secondary to full power DTV stations but primary to LPTV stations.
In comments, REC notes that an area of a metropolitan area can be serviced by a dozen simultaneous non-commercial local radio services and that such usage of spectrum is a more efficent use of spectrum than a single LPTV station, even if it is multiplex broadcasting.
To view REC's comments:
http://www.recnet.com/fcc/10-235.pdf
