"I do find it very disappointing that there is not one person on this committee who is representing the 2,186 licensed LPFM broadcast stations, many of which provide very diverse and in many cases, localized content on the fronts of ethnicity, gender, LGBT and religion. In addition, there is no representation of independent LPFM and community based full-service noncommercial educational (NCE) broadcasters at the upcoming symposium on the broadcast industry.

Across the country, community-focused secular and faith-based LPFM stations as well as smaller full-service NCE stations are providing unique and localized content not available elsewhere on the dial or even in the larger media landscape.  Its time for these thousands of broadcast licensees to be taken seriously and properly represented at the Commission as members of the media landscape."

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.

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.

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.

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.