REC Networks has filed comments in the FM translator interference proceeding, MB Docket 18-119.
In comments, REC points out the distinct nature of LPFM stations as well as Class D educational stations and even smaller Class A full-service FM stations that are the most susceptible to interference by new and modified FM translator facilities.
REC supports the proposal that FM translators be able to change to any in-band channel upon a technical showing of reduced interference. This would bring FM translators on a more level playing field with LPFM stations while complying with statute, a primary policy goal of REC. Support of REC’s position was confirmed in a constituent survey.
REC opposed the proposal forwarded by the National Association of Broadcasters (NAB) that a minimum of 6 listener complaints would be required to file a complaint against a translator as it would relate to victim LPFM, Class D and small Class A FM facilities. The high threshold is further frustrated by listener reluctance to file complaints due to the lack of privacy afforded to complainant listeners. Based on data from previous LPFM complaints against new and modified FM translators, REC proposes that the threshold be decreased to 3 bona-fide complaints if the victim station is an LPFM, Class D or small Class A FM stations. Small Class A stations are defined by REC as those with an average service contour of less than 13.5 kilometers or an equivalent of 0.3 kW at 100 meters HAAT.
REC supports the FCC’s moves to take the complainant listener out of the resolution process. In light of the recent events in Houston involving a translator for Centro Cristiano Vida Eterna where letters were sent to complainant listeners threatening litigation if they do not participate in the resolution process, REC has proposed that the Commission require that personal identifying information regarding the complainant listener be submitted confidentially to the Commission and that a redacted copy of the complaint be placed in the public record and served on the FM translator applicant. The information available for public view will be limited to that necessary to show the general area where interference is taking place. The Commission will have the full information on the complaint, so the validity of the complaint can be verified. Constituents participating in the survey have stated that listeners are reluctant to complain knowing that their personal information will appear in a permanent public record.
Overall, REC opposes the 54 dBu “outer limit” proposed by the FCC for which translator complaints would be valid. For an average LPFM station, the extended area past the 60 dBu protected contour to the 54 dBu is approximately 3 city blocks. REC acknowledges that many LPFM stations are offering “unique” programming, especially to minority and under-represented groups that are not available through other sources. REC also noted our constituent survey where we have demonstrated that out of the stations participating in the survey, only half of the stations are streaming their audio over the internet. Between that, and the fact that some LPFM stations reach demographics that are less likely to subscribe to internet access or a mobile broadband plan, the programing provided by LPFM stations are vital.
REC has proposed that until there is additional rulemaking or waiver opportunities to permit LPFM stations to use contours to protect FM translators on modifications, that the current rules stay in effect where the new or modified translator is already in or is already §73.807(c) short-spaced with the victim LPFM station meaning that for a translator that has already constructed, it does not matter where the location of the listener is as long as there is interference. If the FCC decides to proceed with an outer limit, REC has recommended to the FCC that the outer limit be extended to 48 dBu. This value was selected based on the response of constituent LPFM stations that are not streaming when asked about the farthest distance from their transmitter to any group of more than 10 listeners.
REC has called upon the FCC to better enforce rules requiring proofs of performance on directional antennas and has made an LCRA argument supporting an interim waiver process to allow LPFM stations with non-directional antennas to use contour overlap to move facilities while protecting FM translators. A more permanent process, which includes the ability for LPFM stations to use directional antennas was proposed by REC in RM-11810.
Comments in MB Docket 18-119 are due by August 6, 2018 with reply comments due by September 5.
# # # # #
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.
