REC Networks has filed comments with the Federal Communications Commission regarding Low Power FM radio and FM Translators. In comments, REC promotes a modified version of the FCC's "Channel Floor" solution for implementing the "community need" aspect of the Local Community Radio Act of 2010.
REC addressed the following:
Counting existing LPFM stations in channel floors
REC opposes counting the existing LPFM stations in computing "channel floors" due to disparity in favor of FM translators.
LPFM will never be an "equal" to translators
REC has stated that LPFM will never have facilities equal to translators due to provisions in the Local Community Radio Act. REC also points out there are changes that the FCC can make to LPFM to make it more on a level playing field to translators but within the statutatory requirements. This includes eliminating IF protection requirements, relaxing TV Channel 6 protections, contour protection to FM translators as well as expanded use of the second adjacent channel process.
Support the LPFM Advocates Assessment of LPFM Availability
REC worked closely with Prometheus Radio Project and Common Frequency on a revised version of the FCC's "Channel Floor" plan. Specifically, the Advocates point out that many urban areas outside the largest markets are far smaller than the FCC's proposed study area resulting in urban areas being denied LPFM service because of availability in rural areas. The Advocates also point out that some of the channels that FCC showed were available actually had no population within all of the areas where the channel was available. To address these shortcomings, the Advocates are asking for a reduction of the study area from 30 degrees latitude bv 30 degrees longitude to 20 degrees by 20 degrees as well as a 25% increase in the channel floors. As a result, the Advocates are proposing to dismiss the remaining translator applications in 106 of the 150+ markets evaluated. This will open the door for new LPFM stations.
Addressing the Great Translator Invasion
REC expressed pleasure with the FCC for addressing the abnormalities arising from the "Great Translator Invasion", also known as FM Translator Auction 83. Calling the abuses that took place a travesty of FCC processes and policies, REC recommends an immediate freeze on all FM translator applications, rules to prohibit the for-profit sales of construction permits and national ownership caps on FM translators with exceptions for statewide public radio networks.
Cross-Service Translators
REC has told the FCC that the use of FM Translators by AM stations has been exploited by large corporate broadcasters. REC recommends only allowing AM broadcast stations with no full power FM station in the market to be able to use an FM translator to rebroadcast their station. REC is also calling for the immediate discontinuance of digital "HD Radio" multicast streams being rebroadcast using analog FM translators.
The FCC has set a reply comment filing deadline date of September 20, 2011.
For more information, visit http://home.recnet.com/theplan.
For a list of the markets proposed under the LPFM Advocates Plan to have pending translators dismissed to make way for new LPFM stations, visit:
http://home.recnet.com/theplan-markets.
