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FCC Filings
Over the years, REC Networks has filed FCC comments on various communications matters. Here are copies of many of the comments that we have filed with the FCC.

RM 11338 AM broadcast stations carried on FM translators
Comments Due: 8-24-2006 - Reply Comments Due: 8-24-2006
 CommentsRECSupport AM translators for non FM co-owned stations. Translators secondary to LPFM
RM 11331 Petition to allow FM translator licensees to locally originate programming
Comments Due: 6-9-2006 - Reply Comments Due: 6-9-2006
 CommentsRECREC opposes petition
MB 05-311 Cable TV Franchises Sec 621(a) of Communications Act
Comments Due: 2-13-2006 - Reply Comments Due: 3-14-2006
 NPRMFCC
 CommentsEyreSupports video competition even if it means without franchise agreements. Recommends imposing requirements similar to DBS where a percentage of capacity must be dedicated to non-commercial broadcasters.
RM 11305 Elimination of subband for modes in the Amateur Radio Service
Comments Due: 2-6-2006 - Reply Comments Due: 2-6-2006
 Petition for RulemakingCTTCTT wants the amateur radio subbands (for CW) eliminated and allow for self regulation in line with most other world administrations.
RM 11306 ARRL Proposal to regulate by bandwidth
Comments Due: 2-6-2006 - Reply Comments Due: 2-6-2006
 Petition for RulemakingARRLPetiton for changing amateur radio regulation to manage bands by bandwidth
RM 11287 Amherst Low Power AM (LPAM) Petition for Rulemaking
Comments Due: 11-21-2005 - Reply Comments Due: 11-21-2005
 PetitionAmherstPetition by Amherst Alliance, Michigan Music is World Class!, LPAM Network and Nickolaus Leggett
 CommentsRECSupports LPAM as a non-commercial service.
 SupplementRECInformation on LPAM availability in major urban areas
 MapRECLPAM nationwide availability overlapped on LPFM availability map
 Reply CommentsRECRecommended changes to Part 15 AM to mirror the New Zealand LPFM system
MB 05-210 City of License and FM Table of Allotments Issues
Comments Due: 10-3-2005 - Reply Comments Due: 11-1-2005
 NPRMFCC
 CommentsRECOpposes minor changes for city of license changes, supported filing fees and electronic filing.
 Reply CommentsRECSupports REC positions against commercial FM COL change as minor change
MM 99-25 Low Power FM - 2005 FNPRM
Comments Due: 8-22-2005 - Reply Comments Due: 9-21-2005
 CommentsRECSupport many pro-LPFM issues
 ReportRECProposed protection to LPTV/Translator Channel 6 stations
 MapRECLP-100 Nationwide Availability Map
 ReportRECLegacy Translators eligible for protection
 ReportRECLPFM in Metropolitan Areas
 OpposeRECOppose Station Resource Group motion to exntend comment period
 MotionRECMotion to extend reply comment perod
 Reply CommentsREC
 ReportREC(for reply comments) Listing of all translators bought or sold by Radio Assist Ministries and Edgewater Broadcasting
EB-04 BS-111 In the matter of Glenn A Baxter K1MAN
 NALFFCCProposed $21,000 forfeiture
 Motion for Partial ReconsiderationRECAmicus (friend of the court) filing to get clarification on the legality of announcing websites over ham radio even if they may have banner advertising either within or beyond the control of the amateur operator
MB 04-233 Broadcast Localism
Comments Due: 11-1-2004 - Reply Comments Due: 1-3-2005
 CommentsRECExtensive comments on many localism and community access issues
 AttachmentRECListing of distant translators
ET 04-186 Wireless Devices on TV Channels
Comments Due: 11-30-2004 - Reply Comments Due: 12-30-2004
RM 11099 New Jersey Petition to change protections for LPFM and Translators
 CommentsRECOppose petition
 Reply CommentsREC
UNDOCKETED REC Petition to Improve the LPFM Radio Service
 Petition for RulemakingRECREC's 2004 Petition to modify translator protection and make 87.9 available.
 ReportRECCommunities that would benefit from proposed changes
ET 04-140 Amateur Radio Refarming
Comments Due: 6-15-2004 - Reply Comments Due: 6-30-2004
MB 04-224 FM Table of Allotments - Lake Havasu City AZ and Pahrump NV
 CommentsRECTwo mutually exclusive petitions, a C3 and a C for Pahrump. We support the dropin of the C3.
MM 99-325 Digital Audio Broadcasting - Proposed Rules
 CommentsRECOpposes AM IBOC, supports DRM. DAB should not be required. DAB and LPFM. DAB and Translators
 Reply CommentsRECSecond adjacent does not just affect LPFM. Consolidate group stations on a single multicast.
ET 04-37 Amendment of Part 15 regarding new requirements and measurement guidelines for Access Broadband over Power Line Systems
 CommentsRECOppose BPL. Feel that extensive notching is necessary to protect various HF users
MB 03-130 Definition of Radio Markets for Areas Not Located in an Arbitron Survey Area
 CommentsRECMarkets should not be based solely on community of license.
 AttachmentsRECREC proposed market designations for So Cal, AZ, NV
RM 10781 Amendment of Part 97 of the Commission's Rules as they relate to the requirement of Morse code in the Amateur Radio Service.
 CommentsRECSupported maintain 5 WPM code for General and above.
MM 99-25 Low Power FM (LPFM) - MITRE Report
 CommentsRECMITRE Report comments - supports lifting third adjacent restriction
 ReportRECTop 5000 Communities that can gain LPFM
 AppendixRECProposed Rules Changes
 MapsRECMaps of locations where LPFM would be available with third adjacent lifted
ET 03-104 Broadband Over Power Line
 CommentsRECOppose BPL citing interference to and from the Amateur service, International Broadcast Stations, Homeland Security
BNPL 20000608ACW LPFM stations deadlocked due to RBPA (100+)
 Joint Petition for ReconsderationRECPlace all RBPA dismissed applications back into pending status
WC 03-10 Nevada Bell 271-272 for Nevada
 CommentsRECSupported Nevada Bell's application. Cited Pahrump in the Southern LATA
ET 02-380 Additional Spectrum for Unlicensed Devices Below 900 MHz and in the 3 GHz Band
 CommentsRECSupported increasing Part 15 limits and extending to Ch.5-6 spectrum. Convention broadcasting service. Concerned about Ch 14-20 since also used for public safety.
 Reply CommentsRECWireless devices must wait until end of DTV transition, devices must be fixed.
RM 10619 Amendment of the Commission's Rules To Permit Use of "Force Tune" Technology by Digital Wireless Cable Systems
 CommentsRECSupport proposal
RM 10620 Amendment of Part 97 of the Commission’s Rules to allow changes for Novice and Advanced class licensees. (Dale Reich)
 CommentsK7RECOppose petition
RM 10641 Request changes in Retail Point of Sales of all over the counter 2-way voice or data equipment. (Dale Reich)
 CommentsRECOppose proposal
RM 10609 Amendment of Part 74 of the Commission's Rules to Permit Satellite Feeds to Noncommercial Educational FM Translators Operating on Commercial Frequencies
 CommentsRECOpposes proposal
 Reply CommentsRECCalvary's statements have no merit. Agree with NPR on need for distant translator rules.
 ErrataREC
 Additional Reply CommentsRECto Association for Community Education - Radio Nueva Vida
BALFT 20020923ADA K205DK, Yucca Valley CA - Centro Cristiano de Fe
 Petition to DenyRECIssues with commonly owned satellators.
RM 10521 Amendment of the 47CFR97 Amateur Radio Service and/or Amendment of the 47CFR95 Subpart B Family Radio Service to Permit Non-Amateur Radio Non-United States Foreign Nationals Access to the 446.0-446.1 MHz Band
 CommentsRECOppose proposal
MB 02-208 FM Table of Allotments - Buttonwillow CA
 CommentsRECSupported drop in allotment
BALFT 20020715ACM + other translator applications - Centro Cristiano de Fe
 Petition to DenyRECTranslators crossowned with pending LPFM applications
 Informal ObjectionRECIssues with common ownership of satellator, also applicants of LPFM stations
MB 02-159 FM Table of Allotments - Austin NV
 CommentsRECSupport drop in allotment
MB 02-161 FM Table of Allotments - Battle Mountain NV
 CommentsRECSupported dropin allotment
MB 02-162 FM Table of Allotments - Eureka NV
 CommentsRECSupported drop in allotment
MB 02-163 FM Table of Allotments - Fallon NV
 CommentsRECSupported drop in allotment
MB 02-160 FM Table of Allotments - Baker NV
 CommentsRECOpposed allotment. Transmitter blocked from city, city dependent on Ely, transmitter in national park land
 ErrataRECCorrected claim that proposed allotment would provide city grade into Ely.
MB 02-124 FM Table of Allotments - Amboy CA
 CommentsRECSupported drop-in allotment at Amboy. Although Amboy is not in Census, it is a remote community along a major interestate highway in a white area.
 Reply CommentsRECOpposed counterproposal that would have moved a bunch of stations in NV. Affirmed support for Amboy.
ET 02-98 Amateur Radio Service - LF allocation - allocation near 5 MHz
 CommentsK7RECSupports 60m. Supports for General-Extra. Supports small CW subband.
RM 10413 Amendment of Part 97 of the Commission's Amateur Service Rules Governing Operating Privileges
 CommentsK7RECConcerned about the expansion of modes on 220, especially in SoCal. Support 2x1 special event callsigns.
RM 10403 Amendment of Part 90 of the Commission's Rules Governing the Location and Monitoring Service to Provide Greater Flexibility
 Reply CommentsRECConcerned about increased radiolocation impacts to the 33 cm amateur band
MB 02-374 FM Table of Allotments - Tombstone & Douglas AZ Santa Clara NM
 CommentsRECSupported drop-in. Raised concerns about 60dBu crossing into Tucson
MB 02-376 FM Table of Allotments - Sells AZ
 CommentsRECSupported drop in for Sells AZ
 CommentsRECOpposes counterproposal for Davis Monthan AFB. Not in Census. Questionable Tuck analysis. Entirely in Tucson Metro area.
 SupplementRECSupplement to statement by Lakeshore. Reliance on case law to justify DMAFB as a community is flawed
MB 99-325 Digital Audio Broadcasting - iBiquity report and recommendations
 CommentsRECConcerns about AM IBOC, iBiquity royalty fees, Listener's Bill of Rights
 Reply CommentsREC
 Additional Reply CommentsRECDoes not support Eureka in the 220 MHz band to the displacement of amateur radio
 Reply StatementREC
MB 02-277 2002 Biennial Regulatory Review - Review of the Commission's Broadcast Ownership Rules and Other Rules Adopted Pursuant to Section 202 of the Telecommunications Act of 1996
 CommentsRECAbuse of translator ownership, impose NCE ownership limits
RM 10330 Amendment of the Commission's Rules to Shield Electronics Equipment Against Acts of War Or Terrorism Involving Hostile Use of Electromagnetic Pulse (EMP)
 CommentsRECMandatory EMP protection in the private sector is not necessary.
BNPL 20010615AWN Michael Krueger LPFM Applications (7)
 Informal ObjectionRECMultiple filer. Individual. Blocking Pascua Yaqui Tribe (now KPYT-LP)
BNPL 20010611ADY New (LP) - 'Meza' AZ - Iglesia de Cristo Miel (Comcristiana)
 Informal ObjectionRECDefective application. Misspelled city of license. Transmitter nowhere near city of license.
 Petition to DenyRECInvalid city of license. Location issues. Incorporation status.
BNPL 20010611ADW New (LP) - 'Phoenix' AZ - Iglesia de Cristo Miel (Comcristiana)
 Informal ObjectionRECTransmitter nowhere near the city of license.
BNPL 20010611 New (LP) - Tucson AZ - Iglesia de Cristo Miel (Comcristiana)
 Informal ObjectionRECIssues with addresses and history of other applications
BNPL 20010611ADT New (LP) - Nashville TN - Iglesia de Cristo Miel (Comcristiana)
 Petition to DenyREC10 Mile Rule and educational statement issues
BNPL 20010611AAS New (LP) - Belen NM - Iglesia de Cristo Miel (Comcristiana)
 Petition to DenyREC10 mile rule and educational statement issues
BNPL 20010122ALA Comcristiana LPFM Applications (16)
 Informal ObjectionRECVarious violations and defects mostly around compliance with the 10 mile rule.
BNPL 20000605AGY New (LP) - Adelanto CA - Calvary Chapel Community Church
 Petition to DenyRECLPFM short spaced to vacant allotment
 WithdrawalREC
BNPL 20000605AKL New (LP) - San Bernardino CA - Vida Abundante
 Petition to DenyRECMultiple filer
 Motion to StrikeRECVida filed an opposition to our Petition but they did not serve us. We only found out about it from seeing it on a public notice. As a result of this motion, the FCC sent us a copy of the opposition.
 WithdrawalRECBased on Vida's response and who they retained to handle their application, we are impressed that this is an misunderstanding.
 StatementRECWhen you withdraw a petition to deny, you must include a statement that we did not receive any financial consideration for withdrawing. That's what this statement is for.
MM 00-31 Table of Allotments - Nogales & Vail AZ
 COMMENTSRECOpposed metro move of Nogales only on-air FM station to Vail (near Tucson Metro)
 Reply CommentsRECSupports counterproposal that will put drop-in allotment at Vail and keep service in Nogales
MM 99-325 Digital Audio Broadcasting
 CommentsRECSupports DAB but not in-band
 Reply CommentsRECMaintain world harmonization on AM-FM. Use unused TV channels for DAB.
 LetterRECEx-parte presentation about Motorola Symphony Chipset
MM 99-282 FM Table of Allotments - Littlefield AZ
 CommentsRECNot a community for allotment purposes. Nearby vacant allotments.
RM 9673 Request to change Part 97.305 of the Commission’s Rules to limit certain types of transmission on prescribed portions of the Amateur VHF and UHF bands
 CommentsK7RECSupports additional subbands in the VHF bands
MM 99-147 FM Table of Allotments - Congress AZ
 CommentsRECOppose drop-in. Not a community for allotment purposes. Dependent on Wickenburg.
RM 9682 Establishment of an Indoor Sports Entertainment Radio Service
 Reply CommentsRECSupport NHL proposal
MM 99-202 FM Table of Allotments - Mountainair AZ
 CommentsRECOppose Petition - not a community
MM 99-210 FM Table of Allotments - Flagstaff AZ
 CommentRECSupported petition
MM 99-211 FM Table of Allotments - Winona AZ
 CommentsFCCOppose petition
MM 99-25 Low Power FM (LPFM) - Original NPRM
 CommentsRECOriginal LPFM comments
 AmendmentRECSupporting a K-12 school exception on cross-ownership of full power and LPFM. Student run stations.
 Opposition to ExtensionRECREC opposes NAB petition to extend time
 AmendmentRECLPFM should have priority over distant translators
 AmendmentRECRevised distance separation charts
 OppositionRECOppose General Media to extend time of reply comment period
 AmendmentRECTranslator subclasses, TV Channel 6,
 Reply ReconsiderationRECAddresses unlicensed operations, supports directional antennas in some cases, opposes recognizing grandparented superpower commercial stations, LPAM
 Reply CommentsREC
 ReportRECLow Power Radio Nationwide Channel Availbility
RM 9419 To allow certain AM licensees to operate FM translators
 CommentsRECOppose petition

 
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