Amherst Alliance
Supports 250 watt LPFM service in rural areas. Designates some urban clusters as micropolitan areas.
REC Position:
REC supports a 250 watt LPFM service and has conducted much research on the matter. We do not feel that the current NPRM is the forum to ask for LP-250.

Christian Community Broadcasters
John Broomall presents the CCB Plan for the future of LPFM. Eliminate the point system, replace with a 8 hour a day local programming requirement. Mandatory frequency sharing. Permit transfers. Permit multiple ownership. Allow non-contraversial changes as a Minor changes. Keep CP at 18 months but permit tolling to 36 months. LPFMs facing encroachment should be permitted to move within 15 miles, change to any channel (including Channel 200/87.9) and drop to LP-10 to resolve the issue. Restatus translators filed in the GTI. Ban sales and transfers of permits/licenses. Require translators to be commonly owned.
REC Position:
In the original LPFM NPRM, we raised the concept of using frequency coordinators similar to those used in the mobile and amateur services that would manage time share agreements. REC does support mandatory frequency sharing for MX applicants. We agree there should be some controls on GTI translators. We are willing to make exceptions for commonly owned translators that are within the service contour of the primary station (fill-in). REC does oppose any regulations that translators are commonly owned. This prevents municipalities to bring radio services into their community. Instead, we need to look at ownership caps and more verification from non-commonly owned translator applicants that they have permission to carry the primary station.

City Heights Community Development Corporation
One of the many San Diego 105.9 applicants who were dismissed in the St. Patty's Day Massacre of 2003. Wants to know when they can apply again.
REC Position:
We wish them the best of luck. We do note that even if third adjacents were lifted, 105.9 would not be available any more because of both the GTI as well as activity in Mexico.

Colleges of the Seneca - WEOS
Supports non-contraversial aspects of proposal. Does not support LPFMs being able to have translators. Does not support more than one LPFM station per owner but will accept 5. LPFMs should not be carried over non-commonly owned translators. Appears to support REC's defintion of distant translator (only they propose strict 400km limit with no "in-state" exception). Supports protection for fill-in translators out to 54 dBu. Regional translators should be allowed to bump distant translators. Feels that Ibiquity should make IBOC conversion affordable for LPFM stations.
REC Position:
Very supportive comments from a full power station. REC has always sat on the fence on the LPFM over translator issue. Our comments give some cases where we think they are appropriate. Again, REC will reconsider the "fill-in" translator issue.

Cox Radio
Opposes changes to second and third adjacent channel encroachment. Opposes transfer of LPFM stations/permits.
REC Position:
The ability for a licensee/permitee to have a "way out" if their organiziation fails is paramount to the preservation of local radio services provided by the LPFM station. We do support a waiting period of two years before a CP can be transferred.

The Cromwell Group
Supports liberalized changes in site location. Does not feel that LPFMs should be transferred but does support board changes within existing organizations. LPFM should not have preference over translators, especially fill-in translators. Opposes third adjacent channel citing cheap radio receivers.
REC Position:
The ability for a licensee/permitee to have a "way out" if their organiziation fails is paramount to the preservation of local radio services provided by the LPFM station. We do support a waiting period of two years before a CP can be transferred. REC is currently examining the status of LPFM to fill-in translators.

Eastern Sierra Broadcasting
Claims that some LPFM transmitters are "consumer and home made types". Supports a 24 month CP with tolling to 30 months to prevent warehousing. LPFM over FM translators would create "havoc" in the industry in a time of satellite radio competition. Claims LPFM was given plenty of opportunity since their window was before the GTI. Translators are important and should remain equal with LPFM. There are many daisy chained translators and to take one out of the chain can cause problems. Opposes summary dismissal of GTI applications. Supports the conversion of translators to LPFM and vice versa.
REC Position:
REC feels that translators that have a proven track record of service should be eligible for protection from LPFM. This is our "List of 3000". We also need to remind Eastern Sierra that the transmitter certification rules for LPFM are stricter than translators and full power broadcast.

Educational Media Foundation - (K-Love & Air-1)
Opposes LPFM over translator priority. Does not feel that the fact that LPFM can originate programming is a reason for LPFM should have priority over translators, especially since not all LPFM actually originate local programming. Claims one LPFM station is running local origination programming of a loop tape in continuous play. Feels that translators should be permitted to run public service announcements and other local announcements.
REC Position:
REC has recognized that some EMF translators are able to provide a local or regional service because of EMF's structure of having a significant large number of full power stations. Many of them are staffed and have the ability to originate local programming. More importantly, they have EAS capability for a nearby area and not halfway across the country. There are many EMF translators on REC's List of 3000. LPFMs running satellite feeds is a big problem for us too just like translators running satellite feeds. We remind EMF that LPFM stations can be owned by government entities and they are permitted to operate them as traveler's information stations (TIS). In this case, a loop recording is acceptable. I too would be concerned about a non-TIS LPFM station running a continous loop recording all the time. They must have a good reason. REC sees no harm with translators operating a short amount of public service announcements that are specific to the translator.

Galaxy Communications/Desert West Air Ranchers
(We note that we have butted heads against DWAR on several broadcast allotment proceedings here in AZ)
Opposes the summary dismissal of GTI translators. Supports the retention of fill-in translators. All translators should be grandparented. Feels that the heirarchy of FM stations should be (1) Full service FM stations, (2) Fill-in translators, (3) LPFM and "locally oriented translators" and (4) distant translators.
REC Position:
REC also opposes the summary dismissal of all GTI translators. We do not feel that "fill-in" translators should be closer to the LPFM on the heirarchy. REC will be investigating the impact of fill-in translators and their impact on the LPFM service.

KOFI Inc. - KZMN
Broadcaster in Montana. Concerned about dismissal of all GTI applications due to a single translator application still pending.
REC Position:
REC does not support the summary dismissal of all GTI applications, only if the channel is needed for local LPFM use and the only thing in the way are GTI translators. The community in question has room for two simultaneous LPFM stations and this is without displacing any translators.

WHUM-LP - WHUM
Asking for an upgrade from LPFM to Class A.
REC Position:
REC does not support this method to get LPFM primary status. If the station was allowed to "upgrade", it would displace a co-channel LPFM CP 30km away in Shelbyville, IN. As a Class A, this channel is shortspaced by 16km to WACF Paris, IL and by 59km to WRRM Cincinnati, OH.

KVLP-LP - Visalia, CA
Supports dropping second and third adjacent spacing restrictions for LPFM stations. Feels that LP-100 can be filed in LP-10 windows and should have spectrum priority over LP-10. Supports board changes and extension of CPs to 3 years. Supports transfers/assignments as long as there's no financial consideration. Supports multiple ownership within 40 miles of the initial station. Supports sub-secondary status for out of state translators.
REC Position:
REC does not support the dropping of second adjacent channel restrictions. There has been no evidence that dropping a second adjacent can be done without significant interference. Especially with IBOC on the horizon, a second adjacent channel restriction will benefit the LPFM more than it would the full power station. If LPFM ever wants to have a digital future, we must accept a second adjacent channel restriction including between LPFM stations. REC feels that LPFM translators should be allowed to extend the reach of LPFM stations that are otherwise blocked by topography.

LPAM Network/Amherst Alliance/Michigan Music is World Class/Nickolaus Leggett
Proposing a new "post-Baumgartner" proposal for LPAM. This includes an LPAM service that does not duplicate but complement LPFM, multiple ownership of LPAM, simple to administer and unassailable from the standpoint of potential risks of interference.
REC Position:
The document appears to be more intended to be a Petition for Rulemaking on it's own and not necessarily comments in 99-25. REC supports a more community based non-commercial LPAM service with the option of Enhanced Underwritign as well as enhancements to Part 15 of the rules to expand the reach of very low power AM (VLPAM) stations.

Mountain Area Information Network - WPVM-LP -
Technical Exhibit | Petition from Listeners
LPFM station that suffers from interference issues. Supports prohibited overlap contour modeling. Feels that LPFM stations could own translators.

MBC Grand Broadcasting - KJYE / KMGJ / KMOZ / KSTR
Broadcaster on Colorado's Western Slope. Concerned about LPFM having primary status over translators.
REC Position:
KJYE has a significant number of translators. Many of these translators are on REC's List of 3000 Translators that we propose to be protected from LPFM. KJYE exhibits what the FM Translator service was founded for and therefore should be subject to protection. KJYE also has some Invasion Translators. Remember that not all broadcasters had bad intentions for the translator invasion. Some of these communities have available channels available for LPFM without having to displace KJYE translator invasion applications. Please note that REC does not support a summary dismissal of all Translator Invasion applications. We support an investigation into the large filers and reduced protection in order to balance the playing field between Translators and LPFM.

National Association of Broadcasters
Claims FCC can not relieve second and third adjacent channel encroachment due to statute and that it would harm full power listeners. There is no need to change the priority between LPFM and Translators. Full power broadcasters provide community responsive programming and thus enhance localism. Radio programming need not be originated locally in order to best service it's community. Primary status to LPFM stations will greatly harm full power FM stations and especially series translators. The FCC should lift the GTI freeze.
REC Position:
These are the normal comments we come to expect from the NAB about LPFM. They make their point, candy coat it with what their member stations are doing to promote localism and then always make a point that the MITRE report is flawed. Based on the outcome of the MITRE report, the NAB has lost much credibility, especially based on the "interference recording" that was circulated around Congress prior to the passage of the 2001 DC Appropriations Act. Full power radio can only go far to meet the local needs of a community. LPFM fills in as many of the gaps as it can.

National Public Radio - (Attachment with info on grants for translators)
Supports the various "non contraversial" changes such as extension of the CP period. Feels that contraversial GTI applications shoud be investigated and others should not be dismissed and that no changes be made to the status of other translators. Opposes proposed changes to second and third adjacent channel encroachment rule changes.
REC Position:
REC feels that the LPFM service should not foreclose on the existing public radio translator service. Many of these translators have provided decades of service to their communities. REC's specific proposed rules that give legacy protection to translators in the same state as the primary station regardless of the distance between the translator and primary station renforces our support for statewide public radio networks and the essential services they provide. We do not feel that a translator in Key West, FL for a station in Idaho serves the public interest.

NRC Broadcasting -
Operates several stations in the Rocky Mountains and on the Colorado Western Slope. Argues that their translators provide necessary services to the mountain communities of Colorado. Give examples of how the translators have helped relay information. FCC should not change rules that will undermine fill-in translators.
REC Position:
As we stated on the MBC comments above, REC feels that legacy translators do serve a necessary purpose and we propose to protect them. We feel that the LPFM community may need to take a position on "fill-in" translators, including those filed in the GTI. Should fill in translators, those whose coverage area is fully within or significantly within the 60 dBu service contour of the primary station be given protection from LPFM, even if they are GTI applications?

Point Broadcasting/Gold Coast Broadcasting/High Desert Broadcasting
(Note: These folks are right in our California backyard)
Claims that existing LPFM operations already post a significant risk to the integrity of preferable full service operations and that the FCC should not liberalize LPFM rules without increasing protection to full service radio stations. Calls LPFM "unproven". Questions the business model of LPFM stations compared to full power FM and translators as well as internet portals, podcasting and wireless broadband. Raises the second/third adjacent encroachment issue.
REC Position:
Gold Coast lacks credibility in our book. Gold Coast witchunting of LPFM at nearly New Jersey proportions has completely monkeywrenched the 104.7 MX group in Orange County. They have filed a TON of junk shortform applications in the GTI like this one looking for 250 watts on a hilltop and taking their primary station well outside it's protected contour. In Southern California, the problem is not Radio Assist, it's these folks. One of the many contributors of MX situations in SoCal. To be fair, many (but not all) of their translator applications are designed to provide fill-in services and their service contours are within the primary station's contour. But there are a few apps here that are questionable.

Progressive Broadcasting System/Christian Friends Broadcasting
Has GTI applications pending, concerned about them getting dismissed. Claims that translators rebroadcast local stations. LPFM stations should not get priority over translators.
REC Position:
Construction of a translator should not be done as an alternative for building a 250w Class-A station in the reserved band in the area that needs to be served. REC does not support the summary dismissal of all translator applications. Instead, we want the FCC to investigate the contraversial applications and grant the others once the investigation has cleared the other applicants. Those applications would be granted with the subsecondary status for GTI translators we have proposed. We are prepared to re-look at fill-in translators.

Prometheus Radio Project/National Federation of Community Broadcasters/et al
Significantly large number of signatories. FCC should adopt contour overlap methodology and that statute does not prevent it. LPFM should be protected from full power stations. LPFM should be allowed to make major changes when encorached. Local eligibility requirements must remain in effect and non-waivable. Outside the Top-50 urbanized areas, the "10 mile rule" should be extended to 20 miles. Multiple ownership should be prohibited or significantly limited. LPFM licenses should not be transferred until after a hold period and can not be transferred in exchange. Construction Permits should never be transferrable. Transfer of control should be permitted in the case of a sudden change of the board. LPFM windows should be open every 2 years. CP should remain at 18 months with an additional 18 month tolling period. Proposed changes to translator rules: only permit local applicants to apply for translators or LPFMs, applications should be reviewed for speculative filing, LPFM and translators that meet standards of local origination should have primary status. NFCB adopts and supports REC's standards for distant and legacy translators.
REC Position:
As normal, Prometheus comes through again with some very well written comments in support of LPFM. While REC agrees with Prometheus on many things, we remain separate on some issues such as CP terms and transferability and around the change to the "10 mile rule". Otherwise, we hope the FCC seriously looks at a mix of the comments by Prometheus and REC when considering any additional changes to the LPFM rules.

Public Radio Translator Licensees
Many public radio translators have been in service for over 20 years. The NOI incorrectly states that all FM translator services are not local services or are somehow less local than LPFM. Gives many examples of the benefits of public radio translators. Neither the LPFM advocates nor the FCC have provided any evidence that giving LPFM priority over FM translators would resolve the LPFM preclusion problem in large and medium sized communities. There has been significant federal, state and local investment in public radio translators. Opposes summary dismissal of GTI translators. Supports ownership cap of 100 translators per entity and can apply it to the GTI. Adopt more stringent criteria to weed out friviolus applications.
REC Position:
We have noticed a change in attitude for the better by the pubcasters. Even though we can not speak for other LPFM advocates, we do not advocate an approach of dismissing all the remaining GTI applications and starting over. We recognize there are good applications. Applications that will not deeply impact LPFM. At the same time, we need to investigate those who have abused the system by filing excessive applications, especially those that have been sold already. This is why we are reconsidering our position on GTI translators, specifically those of fill-in stations. REC supports the pubcaster's concept of an ownership limit for translators. We believe that 100 is excessively too high. We proposed a "point" system. Each entity would have a 60 point allowance. Commonly owned translators that are not distant translators and any commonly owned translator in Alaska get 1 point, non-commonly owned non-distant translators are 2 points, distant translators (except Alaska) are 3 points.

Public Radio Regional Organizations - (Appendix A) - (Appendix B - Maps)
Many of the same comments as the translator comments above. Feels that LPFM has been given a "fair bite" because LPFM's window predated the GTI window. Supports the 100 translator limit.
REC Position:
See the comments for Public Radio Translator Licensees above..

Radio Training Network
Opposes LPFM having primary status over translators. Claims that LPFM providing service for the local public is a fallacy due to the number of hours an LPFM can broadcast and no restrictions on utilizing programming that is not locally originated. Feels that existing translators should be grandparented if the FCC is inclined to provide primary status to LPFMs.
REC Position:
We feel that translators that have a track record of local service should be grandparented. This is why we created the List of 3000. The RTN translators mentioned in their pleading are all on the List of 3000 and subject to protection by LPFM under REC's proposal.

Radio Assist Ministries/Edgewater Broadcasting - Appendix A - Appendix B - Appendix C
Claims that they are created to "building out a nationwide translator network to provide Christian programming to under-served areas or areas without significant sources of this type of programming. The Ministries use their broadcast facilities to provide news, public affairs, information and entertainment programming...". Primary status for LPFM status is not warranted due the "earlier lack of demand for spectrum". Claims that LPFM has had ample opprotunity to file for LPFM stations on non-reserved channels prior to the GTI. Uses maps to show that their translators or any other GTI translator has precluded the LPFM service. FCC must also not disregard the substantial expectancy interests of FM translator licensees, permitees and applicants who have been fully compliant with the Communications Act. Calls LPFM service speculative. Defends satellators. If the FCC allows primary status to translators, the translator should be allowed to show that the subject translator serves the public interest more than the LPFM or can technically resolve the short spacing by modifying the translator station. Claims a station that serves more people better serves the publci interest. Opposes second and third adjacent encorachment measures. Opposes extension of the freeze.
REC Position:
Remember, this is the organization that forced the LPFM applicants to demand the freeze in the first place. RAM/EB continue to hide behind a smokescreen that their "ministry" is placing stations in underserved areas. Their claims of the lack of demand for LPFM are proposterous. Even though there were only 3,200 LPFM applications filed the 5-windows, many were not granted due to the third adjacent channel restrictions as well as mutual cooperation between LPFM applicants. With that, the LPFM stations were placed where they were needed, unlike RAM/EB that have used various tactics such as use of Census Bureau names of city of licenses instead of commonly used names and using Census Bureau geographic reference points for transmitter locations. This is not to mention the nearly $1 million the organization has made in the transfer and assignment of construction permits for translators acquired during the GTI. All handed to them on a silver platter at no charge by the FCC. RAM/EB has absolutely no credibility in this proceeding due to their disregard for the spirit of the FM translator service.

Sacred Heart University
Opposes LPFM primary over "local (non-alternatively) fed" NCE translator stations. Supports conversions of translators to LPFM stations.
REC Position:
Another pubcaster with reasonable concerns about the future of their translators. Translators which have a track record of service and are not distant translators such as ones operated by SHU are subject to protection via our List of 3000 process.

Saga Communications
Attacks the LPFM service and it's advocates (namely Prometheus' "pirate past"). Uses examples of two LPFM stations. One which they were experiencing interference from and then they eventually settled on. Another example of an LPFM station running commercials. Does not support any primary status over translators.
REC Position:
The actions of a single LPFM station do not represent the entire LPFM movement. Indeed as a new service, there may be some that do not have a complete understanding of the service. We reviewed the copy that was in Saga's comments and we agree, those are blaintant commercial advertising. REC agrees that this is not the appropriate use of an LPFM station but it should not suggest that all LPFM stations carry commercials like the one that Saga noted. Unlike the big owners, we have found that many smaller broadcast owners are more accommodating to LPFM because they do not see it as a threat to their commercial operation.

Simmons Stations
Feels based on reading the NPRM that full power stations has to protect LPFMs. Feels that LPFMs being able to displace full power stations would have devistating impacts in smaller markets.
REC Position:
Primary status for LPFM over full power stations is not even in scope for this proceeding. REC feels that it is not appropriate for any group (either pro or anti LPFM) to address primary status for LPFM in repsect to full power at this time. REC agrees that LPFM stations should be on a more level playing field with full power stations. In previous proceedings, we introduced a "Limited Primary Status" mechanism that is intended to protect LPFMs from drop-in allotments, moves and upgrades from full power stations when no "equal or superior" spectrum can be found to relocate the LPFM station. This is not a part of the current 99-25 proceeding and REC has not brought it up.

Station Resource Group
Supports the development of an LPFM service that complements the existing public radio system. LPFM is new and folks are coming to it with totally fresh perspectives. A lot of experimentation and creativity is going on. Explains how some pubcasters are helping out the LPFM stations. Supports the non contraversial changes. Opposes changes around eligibility and multiple ownership stating it will turn LPFM into super-translator networks. Gives a position where LPFM and public radio can work together and that rules should support that. Opposes the 2nd/3rd adjacent encroachment issues. Sympathetic to the frustration of LPFM advocates over the outcome of the GTI. Has some very strong words about the two applicants who filed a large percentage of the applications for speculative reasons. Feels that the FCC should investigate the applicants who have abused the system. Failure to open regular filing windows exacerbates the problem. Supports grandparenting of existing translators.
REC Position:
We are happy to see that the pubcasters have been more supportive of LPFM lately. SRG does raise some extremely valid concerns in their comments. We continue to feel that our "List of 3000" proposal with a modification to protect fill-in translators will address the needs of the pubcasters. We totally agree with SRG that the applications of EB/RAM need to be set aside for hearing as well as investigations on existing granted applications (including ones that have been transferred to other organizations).

Virden Broadcasting (Duplicate comments under the names Kaskaskia Broadcasting and Miller Communications)
Supports non-contraversial changes. Feels that the FCC should instruct LPFMs that they can not take any programming "from any external programming source, whether it be delivered by telephone, Internet or satellite" and that local LPFM stations were not created to become a repeater of national programming fed from elsewhere. Feels that translators and LPFMs remain co-secondary because they knew about their secondary status when they applied. Feels that translators should be allowed to locally originate up to 50% of their broadcast hours. AM Daytime stations should be allowed to have translators. These changes should be done "in exchange" for allowing LPFM to run on third adjacent.
REC Position:
As an organization that feeds programming to LPFM stations, we take exception to Virden's et al claims that LPFM stations should not be permitted to carry any network content. To get a better position, LPFM stations were allowed to pledge that they would have at least 8 hours a day of local programming. We feel that a successful local LPFM service will include both local programming as well as some network programming. Such programming gives listeners a view of the outside world while still receiving local support. For many broadcasters who reach out to their local minority communities, occasional network programming is a neccessity. Where we hope Virden was going with their comments is that they did not want to see LPFM stations turn into 24x7 satellite networks. We agree with them on that stand only, but we do not feel that a complete prohibition on satellite programming is necessary to maintain the integrity of the local LPFM service. The issue of AM Translators came up several years ago in RM-9419. At that time, REC opposed AM stations from getting translators. The issues that Virden brings up about local origination and AM translators are out of scope for this proceeding. We are concerned because Virden contradicted themselves by claiming that LPFM should not run any network programming at all yet they want to have translators be allowed to run 50% local origination.

New Jersey Broadcasters Association
Filed their Petition for Rulemaking that they filed in RM-11099. Wants it to be included in 99-25.
REC Position:
As we mentioned in RM-11099, this is a witchhunt against the non-Jersey translators at the expense of LPFM. NJBA did not show any proof that any existing or proposed LPFM station will cause any interference to full power Jersey broadcasters. NJBA is proposing a 44 dBu service contour for full power stations in respect to LPFM and translators. This is unreasonable and unecessary since most Jersey FM stations are running at powers much lower than their full class powers that LPFM stations actually already overprotects them because LPFM stations must protect full power stations assuming full facilities (that rule does not exist for translators).