REC Networks has filed comments with the FCC to express conditional support for the proposed A10 Class of Service as part of a much larger expansion of rural broadcasting. Class A10 was proposed by Commander Communication Corporation to be an intermediate service class between A and B1 or C3, depending on the location of the FM station. Class A10 is specified as 10 kilowatts at 100 meters height above average terrain with a service contour of 32 kilometers.
As a part of the comment filing, REC performed several extensive studies in order to determine the actual impact to existing FM Translator stations, LPFM stations and recently granted construction permits from the 2023 Third Generation LPFM Filing Window. These studies have determined that:
- The number of Class A stations being able to upgrade to Class A10 from their current location will be limited. At the outset, just over half of the stations will have a path to upgrade. This number can be further reduced because for most Class A stations with a path to upgrade, it will involve the use of expensive directional antennas and stations will need to determine whether a modification to get a mere 2.2 dB power increase is worth the expense. The number may be further reduced due to mutual exclusivity between applicants. Two Class A stations spaced at a particular distance will not both be able to upgrade.
- The distance separation studies for LPFM show that in a worst-case scenario, over 20% of stations may experience some kind of an impact. Most of these impacts take place outside the LPFM station’s primary service area. The actual impact will depend on how many Class A stations actually upgrade.
- The contour overlap studies for both LPFM and FM Translators show that in the worst case scenario, up to 10.6 percent of LPFM and 12.7 percent of FM Translators may experience new or increased contour overlap within their service contour as a result of upgraded stations.
- Contour overlap studies also showed that some LPFM and FM Translator stations may receive a benefit from the upgrade if the upgraded station is on their second-adjacent channel (also third-adjacent channel for FM Translators).
- The upgrade of Class A FM stations to A10 will have a very minimal impact on the upgrading of LPFM stations to LP-250 as proposed by REC in RM-11909.
Regardless of REC’s overall position on Class A10, REC has identified several issues and made counterproposals in the event that Class A10 was to be adopted:
- REC proposes adjustments to the §73.207 minimum distance separation tables identifying errors made on Commander’s original petition.
- REC disagrees with some of Commander’s proposed short-space distances under §73.215 of the rules.
- REC adds proposed §73.807 distance separation values for LPFM (LP100 and LP250), which were not originally provided by Commander.
- REC counter proposes that Class A10 not be available in Puerto Rico or the US Virgin Islands due to the unique nature of how broadcast stations are classified in that region. In addition, REC proposes to split off Puerto Rico and the Virgin Islands into their own FM Zone called “I-B” (one B) and leave Zone I-A to be California south of the 40th Parallel.
- REC proposes that Class B1 and C3 facilities in the non-reserved band (92~108 MHz) which operate within the parameters of Class A10 only be downgraded following the existing policy in place for Class C stations operating at Class C0 facilities.
- REC proposes that Class B1 and C3 facilities in the reserved band (88~92 MHz) which operate within the parameters of Class A10 be automatically downgraded to the A10 service class as to allow the excessively reserved spectrum to be used for future LPFM opportunities.
- REC provides options for handling “day one” applications and identifies the potential for mutual exclusivity between Class A applicants seeking to upgrade to Class A10.
Overall, REC’s support is conditioned on advancing both the A10 proposal and REC’s Simple250 Petition for Rulemaking to a Notice of Proposed Rulemaking as a combined proceeding. Both proposals can provide an overall solution for rural stations to improve their performance both inside and outside of their existing service contours. If the FCC does not move A10 and LP250 together for proposed rulemaking, REC will oppose the A10 service class but will still continue to pursue the elements counter proposed above in the event the FCC does adopt A10 without LP250.
It is important to remember that despite the “MB Docket” number, the Class A10 proposal is not yet at a Notice of Proposed Rulemaking. It is still a petition only, at the same level as RM-11909 for LP250. This is nowhere near a done deal at this time.
REC’s submission to the FCC can be found at the links below:
- Main comment filing plus Appendices A, F, G, H and I
- Appendices B and C detailing Class A station upgradability and mutual exclusivity
- Appendices D and E detailing LPFM impacts based on distance separation
- Spreadsheet supplement for Appendix F regarding contour-based impacts to LPFM and FM Translators (XLSX Excel File)
To check for upgradability of a Class A station to A10 or to check on potential impacts to a specific LPFM or FM Translator station, go to
For more information RM-11909, the Simple250 petition for rulemaking, see
