REC has filed comments today in two FCC rulemaking proceedings.
First, in MB Docket 19-310 which called for an elimination of a rule which prohibits two commonly owned stations in the same service (AM or FM) to simultaneously run more than 25% of programming within generally the same area, REC has told the FCC that it opposes the repeal of this rule as it would destroy any hope for broadcast diversity and localism especially in light of the recent layoffs at iHeartMedia. REC does support a limited exemption of the broadcast duplication rule in cases where the duplication involves an AM station operating analog and the other operating MA3 all-digital. REC also supports extending the area where the population is considered for the duplication rule from the 70 dBu "city grade" community contour to the 60, 57 or 54 dBu service contour. REC closes by stating that the spectrum belongs to the people of the United States and is only entrusted to the licensees and that the public interest is not served by allowing more than 25% duplication especially when there are other organizations waiting for their turn at the microphone.
In the refresh of the record for MB Docket 03-185, REC performed an extensive analysis of what rules would need to be put in place for both Franken FM stations (which we also refer to as "FM6") as well as full-service and secondary FM broadcast stations on 88.1, 88.3 and 98.5 MHz. Our analysis would show that if there was harmonization between FM6 stations and FM broadcast, most of the FM6 operations would be displaced due to a "one and three quarters-adjacent channel" interference. REC proposed a new 71.5 dBu interfering contour that can be used to demonstrate a lack of interference between an FM6 and a FM station operating on 88.1 MHz. FM stations on 88.3 would be protected through the existing 100 dBu interfering contour. For LPFM, this would mean that in order to propose operation on 88.1, the LPFM station would have to show that its 71.5 dBu interfering contour would not overlap the 60 dBu contour of the FM6 operation. Currently, there are 8 LPFM stations operating nationwide on 88.1 MHz. REC has also told the FCC that any liberalization of interference protection requirements between an analog service operated by a FM6 TV station and an FM station should eventually be reflected in the FM broadacst rules. REC proposed a "waiver" policy between an FM6 and an 88.1 FM station if it can be demonstrated that the population in the "overlap" zone is either less than 0.5% of the "victim" service contour or 3,000 persons, whichever is less. This is consistent with the second and third adjacent channel short-space policy REC has proposed for small NCE stations in RM-11846. The analysis also shows that in the areas where the major FM6 operations are located, there is no LPFM availability due to full-service stations on 88.1 and 88.3 MHz. Because of those full-service FM stations, it is also very likely that if these proposed rules are followed, most of the FM6 franken-FM stations would be displaced by primary FM broadcast stations, mainly on 88.1 MHz.
In comments, REC told the FCC that these rule complexitites are just that, too complex and not worth it and called for an elimination of all analog LPTV service (including FM6/Franken-FM) on the LPTV analog sunset date, July 13, 2021.
