REC Networks (REC), a leading advocate for spectrum access with special focus on promoting and maintaining the integrity of the Low Power FM (LPFM) radio broadcast service has currently been engaged in responding to the active COVID-19 coronavirus pandemic.
REC Operational Status
At this time, REC is operational but with a delay. This delay is due to the added workload in response to the declaration of the pandemic and the research necessary to provide information. As a result of the current situation, the amount of inward e-mail has increased drastically from various discussion lists and direct e-mails inquiring about operations under this pandemic situation. REC's operations are starting to return to normal after the "initial shock". We are continuing to accept renewal applications for LPFM stations in Kentucky, Tennessee and Indiana through our EZForm as well as for all classes of radio stations through direct contact.
Please be patient as I sift through the many e-mails.
STA Requests, "Pop-Up" Stations, Emergency Operations, etc.
REC is starting to receive inquiries regarding requests to increase power and so far, we are aware of one attempt to "revive" a station that was forfeited due to operating from an unauthorized location. With that, let's focus on emergency operations.
§73.1250 of the rules addresses the broadcasting of emergency information. This rule mainly addresses weather and seismic related emergencies (tornadoes, floods, earthquakes, etc.) and industrial emergencies (discharge of toxic gasses, industrial explosions, etc.). Paragraph (g) of this section makes it clear that "broadcasting of emergency ifnromation shall be confined to the hours, frequencies, powers and modes of operation indicated on the station license." This does not give FM stations of any class any justification to operate at higher power. The only exception to the rule, which is technically "higher power" is that AM stations are permitted to use their daytime facilities in very extenuating circumstances to deliver emergency information. Again, this is not justification for an FM power increase.
§73.3542 is a rule that permits "emergency authorizations" in situations including "emergencies involving danger to life and property; a national emergency proclaimed by the President or Congress; the continuance of any war in which the United States is engaged, and where such action is necessary for the national defense or security or otherwise in the furtherance of the war effort." Such a request is made on an informal basis.
While many state and local governments have delcared a state of emergency due to the rise of COVID-19 cases in their jurisdictions, neither the President, nor Congress has declared a formal state of emergency. Even with that, potential emergency operations will face a very high hurdle, because unlike a weather emergency, there are no power failures or anything that is causing other stations to go off the air. Choices made by stations in programming (i.e. language) does not necessarily justify such operations as existing facilities may also choose to provide programming in other languages.
Katrina Radio's authorized temporary high-powered operation was justified because at that time, many of the full-service broadcast facilities had failed and there was a true lack of service in the area.
The applications for "pop-up" stations that we are starting to see (i.e. Foundation for a Better Life, DKQEK-LP) are in areas that are well served by other broadcast stations and therefore, there is no justification for such operations.
Such requests place a burden on FCC staff, who are already operating under differing conditions as a result of directives regarding travel, commuting and workplace location. This only makes our case for an authorized 250-watt LPFM service as well as additional relief and flexibility in the protection disparity vs. translators much more difficult to achieve.
What LPFM stations should be doing at this time
Stations need to focus on the safety and wellbeing of their own staff and volunteers. Take measures that prevent exposure while still rendering service. Take this time to provide emergency information on resources available within the community and if possible, reach out to your community's minority communities and when possible, in the languages they speak. Please document the work your station is doing and keep us informed with your biggest success stories. We can use this to help in our effort to elevate the awareness of LPFM as a needed service for our community.
We also invite your station to use the LPFM Voluntary Public Inspection File (VPIF) system. LPFM stations are not required by the FCC to maintain a public inspection file but some choose to do so. VPIF is the perfect platform to do this. Within VPIF, your station can upload quarterly issues lists and tell the public what your station is doing to serve the community.
Thank you for all that you are doing. REC has a dedicated COVID-19 web page where we are adding information and resources as we receive them. You may also follow REC Networks on Facebook as that is where information from REC appears first. In addition, you can also subscribe to Michelle Bradley's YouTube channel in the event of any updates.
Please stay safe and stay informed. If there is anything REC can help with, please let us know!
