REC files new 250-watt LPFM petition with a strong focus on rural areas.
Riverton, MD (May 28, 2020) : REC Networks has filed with the FCC a new Petition for Rulemaking to create an additional 250-watt class of service for Low Power FM (LPFM). The new “Simple 250” plan addresses the issues that were expressed by the Commission in the Report and Order of MB Docket 19-193 regarding additional complexity to the application process and compliance with the Local Community Radio Act of 2010 (LCRA).
In this new version, proposes an LP250 service that simply overlays the existing LP100 service and has longer distance separation requirements. LP250 would be an additional class of service and does not change the LP100 service. Under the plan, over half of licensed LPFM stations would be able to upgrade to the LP250 level on their own channel with nearly 60% of stations being able to upgrade on the same channel or a first-, second-, third-adjacent or intermediate frequency channel.
In 2000, when LPFM was created, they put a 20 kilometer “buffer zone” in place between all LPFM and full-service stations to allow full-service FM stations to move without causing impact to the LPFM station. When the LCRA was enacted in 2011, it included a provision that minimum distance separation between LPFM stations and full-service stations could not be reduced. In 2012, the FCC first proposed LP-250 with the same distance separation requirements but with the LPFM interfering contour penetrating the buffer zone. After LP250 was first rejected due to a misunderstanding by the FCC about LPFM advocates, hobbyists and social justice organizations, REC reintroduced LP250 in RM-11749, which also included an additional “backstop” to prevent interference at the higher power and RM-11810, which was a more complex technical proposal in response to the influx of translators entering urban areas. On all of these proposals, the “buffer zone” was penetrated to keep the minimum distances the same.
In April, 2020 in MB Docket 19-193, the FCC determined that the previous REC LP250 plans were too complex and any distance separation plan that would penetrate the buffer zone would violate the LCRA.
On May 28, 2020, in response to those concerns, REC files this new petition for rulemaking in order to reopen the LP250 discussion, a discussion that was previously cut short by an administrative rule at the FCC.
The new Petition for Rulemaking will do the following:
- Create a new “LP250” class of service in addition to the current LP100 service with an effective service contour of 7.1 kilometers.
- Establishes a 451 meter maximum HAAT for new or modified LP100 facilities.
- Create a second distance separation table for the new class of service which includes distances up to 9 km longer than the LP100 service.
- Fully respects the 20-kilometer buffer zone.
- Propose policy for upgrades on stations already second-adjacent channel short-spaced.
- Does not add any new process that would involve a contour study.
- Propose to allow class upgrades and downgrades as a minor change as long as all other minor change criteria is met.
- Suggests, but does not require a “launch window” method in order to assure fairness during the initial “rush” by existing LPFM stations wanting to upgrade.
- Propose a simplified radio frequency radiation standard for LP250 similar to the simplified standard for LP100.
The primary focus on this petition is for LPFM stations and communities in rural areas, which account for nearly two-thirds of all licensed LPFM stations. REC proposes LP250 without any specific geographic exclusions. Its availability in urban areas is naturally controlled by spectrum crowding. Despite those natural barriers, REC has identified LPFM stations in various urban areas that may be able to upgrade including some (but not all) in San Francisco, Philadelphia, Seattle, Tampa, Portland OR, Sacramento, Las Vegas, Cincinnati, Austin, Cleveland, Kansas City, Indianapolis, Milwaukee, Nashville, Greesboro and New Orleans.
As of the time of this writing, the FCC has not yet assigned an RM number nor set up a public notice. We anticipate this will come soon.
The other issue the FCC rejected in MB Docket 19-193 was REC's proposals to address the disparity of how LPFM stations protect FM translators vs. how FM translators protect LPFM stations. We will address that issue in a subsequent Petition for Rulemaking in the future.
Michelle Bradley, CBT
A copy of the filings can be found at the following URLs:
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