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19-193: Comment Summary

The following is a summary of timely-filed comments in MB Docket 19-193 as interpreted by REC, and can be used as a basis for filing Reply Comments which are due on November 4.  Additional annotations by REC provided where appopriate.  Annotations reflecting REC positions shown in italics.

19-193: REC calls on the FCC to resume consideration of LP-250, LPFM relief due to translators.. supports removal of Ch. 6 protections.. gets frank about EAS.

In response to the FCC Notice of Proposed Rulemaking in MB Docket 19-193, REC Networks, the author of most of the items in the proceeding has filed comments with the FCC to support the various items the Commission has agreed to move forward and has also petitioned to have several items that were tentatively rejected brought back into discussion.

Position of REC Networks: WBAI, New York

REC Networks is aware of the situation that has been taking place at Pacifica Foundation station WBAI, New York including the litigation and has heard from both sides of this issue.

With the exception of the output of the WBAI FM transmitter, REC takes no position in the dispute of the issues that are within the jurisdiction of the State of New York.

Advisory from REC regarding filing LMS modification applications for LPFM.

During testing of the new LMS application entry for construction permit modifications for LPFM stations, we have noticed that LMS is calculating height above average terrain incorrectly.  This can result in the application being given a higher or lower HAAT than what would be appropirate. This has been reported to staff. 

[updated] LMS for FM.. just a little bit late coming out of the starting gate

Updated 9/25/2019 at 5:15PM: REC has received word from FCC Staff that LMS is functional now.  

Whenever a big corporation makes a systems conversion or update, it's their "big day" and sometimes that "big day" turns into a big problem such as what happened in 1990 when a bad release by DSC Communications caused a massive failure in the nation's Signaling System 7 (SS7) network bringing telephone calls to a nearly complete halt or regional issues such as the conversion of an ordering system used by USWEST Communications in the late 90s which prevented customer orders for several days before having to be backed-out and retried at a later date.  

Today, Wednesday, September 25, 2019 was supposed to be the FCC's "big day" in the Media Bureau. 

REC/RRPA position statement on "Pacifica Restructuring Project"

There is currently a petition being circulated to make some major changes on the board of directors at Pacifica Foundation.  This board includes representatives from all Pacifica-owned stations (KPFA, KPFK, WPFW, WBAI and KPFT).  Starting recently, the board also has representatives of the Pacifca affiliates.  These are the many LPFM and full-service FM community stations that promote the Pacifica Mission through the airing of programming and through the submission of programming to other affiliates.  

The current plan would completely gut the board, including those who I know, who are working hard to "fix" Pacifica from the inside.  This current plan also eliminates the local station boards which are the voices who represent the unique cultural needs of each of the 5 Pacifica-owned stations. 

Rant from Riverton: My take on the Saga saga

One piece of advice that I have been giving LPFM stations for quite awhile is to remind them that as renewals are coming up, they need to make sure they are complying with the rules because their dialmates are likely taking notes.

Now with the Petition to Deny period open on the first wave of broadcast renewals, we are starting to see the first signs of that note-taking that I warned about.

More FCC forms for radio broadcast convert from CDBS to LMS effective September 25, 2019

Starting on September 25, 2019, those who file applications for broadcast stations will need to use the LMS system instead of CDBS for filings. This includes the following forms:


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