For over a decade, REC has supported a 250 watt at 30 meter HAAT, 7.1 km service contour LPFM service. In many events leading up to last spring's Notice of Proposed Rulemaking (NPRM), there has been a lot of buzz in comments and ex-parte presentations to support a rural 250 watt upgrade.
While we were not surprised that the FCC took the suggestion of Amherst Alliance and the Catholic Radio Association and moved LP-250 forward to this year's NPRM, we were taken by surprise that the proposed distance separation contours for LP-250 were the same as LP-100 on co- and first-adjacent channels in respect to full power FM stations. This method involved reducing the "buffer zone", an additional 20km that was added to the service contours of every full power domestic FM station. This buffer zone was intended to allow the full power station to make changes in their facility location and even facility upgrades with minimal impacts on the LPFM station. Honestly, we were expecting the FCC to create an LP-250 table that would have used the full 20km buffer zone. This would have resulted in the required distances between LP-250 stations and full power stations to be an extra 3 to 4 km in most cases.
After a large amount of persuasive lobbying by both the National Association of Broadcasters and National Public Radio presenting a potential LCRA controversy with creating LP-250 (as well as the usual increased interference argument), the FCC backed off on the idea. They also backed off on our proposed 50 watt enhancement to LP-10 using a similar distance spacing scheme for those reasons and because there has not been a full record on the concept of doing LP-50 stations since we introduced it in comments.
The comments have shown that there is a high demand for LP-250 (7.1km) and LP-50 (4.7km) services. The FCC also expressed noise floor and other "viability" issues where it comes to LP-50.
The FCC is charged with having to interpret a piece of congressional legislation. As you all know, the members of Congress are not broadcast engineers nor should they be making specific engineering decisions. in their bills. The LCRA has some aspects that not just confused us, but they also confused the FCC and we are working on this.
REC is aware of a group of LPFM advocates and other supporters being set up called "The Power Boost Coalition". This group's intention is to file a Petition for Rulemaking after the LPFM filing window next fall to give LP-100 stations a pathway to upgrade.
We feel that how The Power Boost Coalition is approaching this issue is the correct way. REC feels that any attempt to file a Petition for Reconsideration against any aspect of this week's Report and Order that impacts "pre-grant" issues such as eligibility, ownership, second adjacent waiver, comparative review, FM translator culling and availability (e.g. LP-50 and LP-250) would not be supported by REC and could jeopardize the October 15, 2013 filing window target date. If a Petition for Reconsideration for an activity that takes place after the grant (such as interference remediation) is filed, we may support it based on its merits.
While REC supports the efforts of The Power Boost Coalition, we will not be pursuing LP-250 at this time as we are still working on developing our systems, evaluating and addressing any possible LCRA interpretation issues in this weeks' R&O.
Once the dust settles, we will look at the potential for future LP-250 and LP-50 stations. These powers are not off of our radar, they are just to the side.
For more information on the Power Boost Coalition, please contact either the Amherst Alliance or Conexus LPFM Advocacy.
