In Reply Comments, REC has addressed a plethora of issues raised by Venture Technologies Group and other proponents who support the retention of an analog subcarrier on 87.75 MHz by channel 6 LPTV stations upon their conversion to digital television. These services are referred to by some in the industry as "Franken-FM". For the purpose of fairness, we refer to them in comments as "FM6".
Some of the key points raised by REC included:
- Since these FM6 services will not be received on television set (especially considering that a part of this proceeding is to remove the analog tuning requirement for new TV receivers), the service would be considered as an anciliary/subsidiary service thus subject to the Electronic Communications Privacy Act as well as subject to the 5% regulatory fee on all revenues.
- REC agrees with EMF and Signal Above that testify that reserved band FM radio services do not interfere with digital Channel 6 stations therefore making the Channel 6 protections by LPFM stations in ยง73.825 of the rules no longer necessary in respect to DTV stations.
- The public interest would be better served by allowing LPFM stations on 87.7 in areas within 500 meters of a LPTV Channel 6 station.
- The "Channel 200" rule should be extended to LPFM stations allowing operation by LPFM stations on 87.9 in non-border areas while still protecting FM operations on 88.1 and 88.3.
- If LPTV licensees wish to operate commercial FM stations, then they should be subject to regulatory fees similar to those of full power stations. Anything less would be unfair to minority-owned commercial FM licenees who are barely surviving.
- Analog FM6 operations by LPTV stations must protect at the minimum, the 100 dBu interference contours of FM stations on 88.1 and 88.3. Because of less than 400 kHz spacing to 88.1, we question whether the interference contour should be larger than 100 dBu.
Overall, REC continues to support the reallocation of Channel 5 and Channel 6 spectrum (76-88 MHz) to create FM broadcast channels and that the FM6/Franken-FM issue is diverting attention away from the much bigger issue which is assuring that television services provided by TV translators in rural areas, especially in those areas outside the footprint of cable television services are sustained.
A copy of REC's Reply Comments can be found at the following URL:
http://recnet.com/fcc/14-175r.pdf
