In comments to the FCC on RM-11727, REC Networks has analyzed the proposal by SSR Communications to create a new Class C4 FM service in the Zone II areas (areas excluding the northeast, mid-west, mid-Atlantic, Puerto Rico, Virgin Islands and most of California). The proposed Class C4 would permit Class A stations to double their power and operate at 12 kilowatts at 100 meters height above average terrain.
In comments, REC states that approximately 16% of the current LPFM stations will have some form of impact by the new station class. LPFM stations that are currently second adjacent channel short spaced to a an upgraded Class C4 station will experience a smaller interference contour and in some rare cases a power increase or for proposed changes, the ability to operate with fewer bays in order to meet the overlap requirements.
To address the increased noise floor that some LPFM stations will experience, REC proposes the FCC considers taking steps to "maximize" LPFM service. Part of REC's maximization plan includes:
- Increase service contours from 5.6 km to 7.3 or 13.3 km based on geographic location.
- Allow power up to 250 watts, ERP.
- Change LPFM to a fully engineered service by first applying a prohibited overlap requirement and then apply the LCRA required distance separation. This way, LPFM stations that can expand while still not creating interference to full power FM stations and translators.
- Develop a process where existing FM translators that can meet the LCRA minimums can be converted to LPFM stations upon transfer of the license to a LPFM qualified organization.
REC's Maximization Plan will be addressed in more detail in a separate Petition for Rulemaking along with other proposed changes to LPFM.
REC also reminds the FCC that since Class C4 was not on the books with the LCRA was enacted, the LCRA mandate for minimum spacing does not apply to the new station class. REC does recommend however that for co-channel and first adjacent channels, the current Class A minimum separations also apply to Class C4. Second-adjacent would have to be larger due to the increased service contour size of Class C4.
REC's comments can be found at the following URL:
http://recnet.com/fcc/RM-11727.pdf
The comment filing deadline for RM-11727 is September 18, 2014. Reply Comments due October 3, 2014.
