In reply comments to the FCC on MB Docket 11-83 (Economic impact of LPFM to full service broadcasting), REC affirms the position that the economic impact to full service broadcasting stations by LPFM broadcasting stations would be extremely minimal. REC goes on to mention that the economic impact faced by LPFM broadcasters due to the actions of full service broadcasters such as facility moves to improve market share and make the full service station more profitable far exceeds any perceived economic "harm" caused by LPFM stations. REC feels that the funds paid out by LPFM stations to respond to encroachment should offset any perceived economic "harm" caused by LPFM stations to full service stations.
While REC acknowledges that LPFM is secondary to full service radio and LPFM stations must give way, there is also predatory activity taking place involving FM translators. FM translators are also on a secondary status to full service stations but due to the operating service rules, especially the recent rules that permit FM translators to rebroadcast AM stations, their positioning is superior to LPFM. REC cites the recent case of KDRP-LP in Dripping Springs, TX who is facing encroachment by a recent translator metro move-in.
REC agreed with the comments of Don Schellhardt and Nickolaus Leggett who gave an analogy that the radio dial is like a shopping mall and that LPFM stations can enhance the dial like niche specialty stores can enhance the attractiveness of the mall. REC further stated that LPFM stations may bring users of competing devices back to radio which may benefit not just the LPFM station, but all of the full service stations on the dial. Schellhardt and Leggett were the co-authors of RM-9208, one of the two petitions for rulemaking that created today's LPFM service.
REC disagreed with the National Association of Broadcasters request that full service "niche stations", those that broadcast music genres rarely heard on the radio or minority languages should be considered separately. Citing the advertising trends in minority language markets, a full service station's right to change format as well as the FCC's established "hands off" policies where it comes to decisions made based on entertainment format, REC feels that niche format stations should be on a level playing field as other full service stations in the evaluation.
REC's comments can be viewed at the following URL:
http://recnet.com/fcc/11-83_reply.pdf
