The goverment shutdown is now going into Day 3 with very little progress from our elected officials in Washington. All government web services that are not directly related to the protection of life an property have been removed from the internet. This has put a serious hamper on those who are planning to file during what has been the October 15 through October 29, 2013 window.
It is REC's concern that even if government services were to resume prior to the scheduled start of the LPFM filing window, those who have been preparing their applications using the FCC's tools such as their channel finder, TOWAIR and Curves programs as well as NOAA's NADCON program have been unable to. Unlike other services the Media Bureau is delegated to regulate, LPFM has been promoted as a "do it yourself" type of service and to support that, the FCC has provided simpler resources where in some cases, the use of a paid engineer or consulting service may not be required.
Now that the FCC has pulled those services, we do not feel that some applicants will be ready if the filing window remains October 15 through 29 or if an abbreviated filing window is started if the government reopens between the 15th and 29th.
Yesterday, REC did meet briefly with our allies who made up the Joint Commeters during the last rulemaking proceedings. We feel that once the government reopens and the FCC will resume daily business that there will be a considerable backlog of other activity. REC feels that at a minimum, there should be a delay of at least one week from the time when the FCC reopens. Others are suggesting a week and then one business day for every business day the FCC has been closed. This way, the staff can catch up on their backlog.
For those who are not familar with the FCC processing, there is a small staff who manually reviews and processes all of the applications that are received through CDBS, the FCC's broadcast filing system. We are predicting considerable backlog. In addition, October 1 was the renewal filing dealine for radio stations in WA, OR, AK, HI, Guam, American Samoa and the CNMI.
While we do not feel that it will impact the window (it wasn't supposed to before the shutdown) , but there is an Order on Recosnideration currently in circulation at the Commission. This order shoud be released anytime soon. It addresses various issues including points, third adjacent channel announcements, eligbility of chapters of larger organizations and LP-10/LP-50. It is our feeling that if the FCC acts on any of these Petitions for Reconsideration, they will be on subjects that would not delay the window under normal circumstances.
We are afraid though that if this government shutdown is allowed to get drawn out for 3 weeks, it will come too close to the holiday season and we could risk having the LPFM filing window delayed until early 2014.
All we ask is that LPFM propoents please be patient. You are going to find out that the FCC is a very much "hurry up and wait" kind of agency. Please be easy on staff after they return to work. They are just as much frustrated about not being paid and then coming back to a ton of work.
Just know that behind the scenes, the LPFM advocates such as REC, Prometheus and Common Frequency are working to get as many of you on the air as we can. While some of our resources are limited right now, we are still working and still fighting.
Regardless of your position on political parties or the Affordable Care Act/Obamacare, please contact your elected officials in Washington to tell them that this government shutdown is also hampering your ability to provide a new voice to your community.
Again, please be patient and I wish everyone the best of luck with their applications.
Respectfully,
Michi A, Eyre Bradley
founder, REC Networks
