While we encourage all proponents to support the future development and expansion of LPFM stations in comments, for those who wish to specifically address the issues that the FCC is raising in this second Further Notice of Proposed Rulemaking (FNPRM), REC has complied a list of the questions and issues the FCC is seeking comments on. Our listing is in a bulleted list format for ease of reading. When we file detailed comments, we first prepare a document like this to work off of.
REC encourages everyone to read the Report and Order and Second FNPRM.
Our doucment does not express any opinions. We will be releasing positional information on issues at a later time and for some issues, after consultation with our allies.
When you comment, try to stay in the scope of the proceeding in order to be seriously considered. Items that can be perceived as "out of scope" include:
* A commercial LPFM service.
* LPAM.
* Power levels over 100 watts for distance spacing based LPFM licensing.
* Assignment in the Channel 5 or 6 spectrum (with the exception of having access to Channel 200/87.9 MHz for displacement relief citing the rules for Class D stations and the exception granted to translator K200AA.)
Some REC initatives that we feel are in-scope which we would appreciate support on include:
* Increasing the number of translator protection "sub-classes" from 3 to 8 for LPFM licensed under distance spacing methodology.
* The use of Channel 200 (87.9) as a displacement channel in areas where it is available.
* Eliminating the "subsecondary" status that LP-10 stations have in relation to translators. (Yes, LP-10 stations can be bumped by translators.)
* For LPFMs under distance spacing methodology, eliminating all second adjacent spacing requirements to translators (equal playing field).
* Eliminating the IF channel protection requirements (currently enjoyed by translators with less than 100 watts).
* Use of primary station location for determining the local focus of a translator instead of determining whether the translator is terrestrially fed or fed by satellite.
A copy of our Information Sheet with the list of the questions can be found at the following URL:
http://www.recnet.com/fcc/99-25_2nprm_questions.pdf
