21-346: REC highlights LPFM/small station capabilities during disasters, opposes mandatory DIRS reporting and backup power requirements, demands non-discrimination during emergencies by State Broadcasters Associations

REC Networks has filed comments with the FCC on the Resilient Networks proceeding, PS Docket 21-346.   The proceeding addresses the availability of communications infrastructure, including wireless services, broadband, cable, satellite and broadcasting during widespread disasters such as hurricanes and wildfires.

REC outlined the service that some LPFM stations have performed during such episodes including WQRZ-LP during Hurricane Katrina and KBUU-LP during the Woolsey Fire of 2018.

In the Commission’s inquiry on integrating broadcasting into the existing Wireless Network Resiliency Cooperative Framework, we had to remind the FCC that unlike current stakeholders, which include telecom giants such as AT&T and Verizon and large industry organizations such as the CTIA, bringing broadcasters into the mix will include the usual large players such as iHeart Media and Audacy, but will also include a large number of small entities in the commercial, full-service noncommercial educational and LPFM sectors.

While REC does feel that the involvement of State Broadcaster Associations (SBAs) are essential to the framework and are likely to best represent broadcasters in general due to their knowledge of the affected area, we reminded the Commission of the decades of discriminatory behavior that LPFM stations have faced from their SBAs.  This includes refusing LPFM stations to become members, LPFM stations only allowed to be “associate” (non-voting) members and in some cases, extreme hostility towards the LPFM service.  REC is not asking that the FCC force SBAs to allow for LPFM membership, but instead, when representing broadcasting in the framework and for any aid and assistance that may come through the framework that SBAs consider LPFM stations as bona-fide broadcast stations and treat them in a non-discriminatory manner.

REC also included the aggregated results of a Constituent Survey where REC asked LPFM stations about their current backup power arrangements and how the LPFM station would operate in the event of an emergency that would result in an interruption of electric power and/or access to the internet.

The FCC is considering rules that would require all broadcast stations in an impacted area to report their station status on a daily basis to the Commission’s Disaster Information Reporting System (DIRS).  DIRS is currently used by broadcast stations on a voluntary basis.  While REC supports and has in the past, proactively raised awareness of DIRS through our disaster page and social media posts, we oppose a requirement that broadcast stations (commercial, full-service NCE and LPFM) be required to make daily DIRS reports.

Unlike the major telecom providers, LPFM stations and small commercial owners may not necessarily have a “headquarters office” or retain engineering or legal counsel outside of the impacted area where access to the internet is available to make these reports.  We also note that because of the design of the DIRS, many users who would need to access the system from inside the affected area would not be able to properly access it, especially when the user is dependent on a narrow screen smartphone in order to access the internet.  We also note that small stations have very limited staff and those stations that are on the air are more focused on getting emergency information out to the public, which should have priority over filling out government forms.   REC does support any Commission efforts to raise awareness of DIRS to small radio broadcast stations through the use of email blasts and other similar methods.

REC also discussed backup power capabilities of LPFM stations, based on the answers made in the constituent survey.  While not specifically proposed, REC went on record to oppose any potential requirement that broadcast stations be equipped with any kind of backup power system where if noncompliance would result in enforcement action.  REC has noted how, because of the requirement of certified EAS equipment as opposed to open source decode only equipment for LPFM stations, these stations are already expending a considerable amount of their funding on equipment and occasional software updates.  Any kind of a requirement that a broadcast station be equipped with a generator would be financially burdensome on some stations.  Instead, the station and the local community are in the best position to determine how a broadcaster should equip themselves in order to handle an emergency involving a power outage.

A copy of REC Networks’ filing can be found at the following URL:

Reply Comments are due in this proceeding on January 14, 2022.