Should FCC Eliminate LP10 Class?
     

Should the FCC eliminate the 10 watt class of low-power FM stations?

That’s a big question in the debate going on now as public comments are pouring into the FCC over how to make more room for low-power FMs and pending FM translators in all markets.

The commission had also asked for public input on whether to eliminate the LP10 class in favor of a class of up to 250 watts at 30 meters HAAT in rural areas as the Amherst Alliance and Catholic Radio Association have proposed.

It has never actually licensed any LP10s, having focused on the 100 watt stations first.

Rather than eliminating the LP10 class, Prometheus proposes an LP50 service “to squeeze-in small stations where they can fit but retain adequate functionality for a small station.” The LPFM proponent also supports increasing the power of current and future LPFMs to 250 watts, though upgrades should not occur until after the upcoming application window.

Common Frequency supports keeping the LP10 service for areas where an LP100 may not be feasible, like urban areas. “With the absence of LP10 service, the immediate central city New York City/Brooklyn area would be deficient of any LPFM service, yet a maximum of 15 translators might be granted to the immediate city,” writes Common Frequency, which considers that an imbalance.

The LPFM advocate agrees with Prometheus that the power level of a 10 watter should be bumped to 50 watts to partially bridge the gap between a 10 watt and 100 watt LPFM, noting the LP10’s main problem is “inability to penetrate ground cover and walls.”

In contrast, the New Jersey Broadcasters Association calls the LP10 class spectrally inefficient, having an approximate 12-mile service area yet with massive potential for causing interference to full-power FMs.

“Using the commission’s current standards, the interference contour for an LP10 ranges from over 126 square miles with respect to Class A stations, to over 244 square miles with respect to Class B stations,” says the NJBA. “In other words, for a service area of a mere 12 square miles, an LP10 carves out an area of interference that is almost 2,000% larger with respect to Class B stations.”

The result would cannibalize existing radio service in New Jersey, according to the association, which adds the FCC’s initial proposal to eliminate the LP10 class was correct. The agency imposed a freeze on the old Class D 10 watt stations in the late 1970s for the same reasons, notes the broadcast association, writing that the FM band is far more cluttered today.

“The commission has resurrected nearly the exact scheme that, over 20 years ago, it determined failed to serve the public interest,” says the NJBA, which also says the FCC has failed to take into account changing listening patterns as the radio audience has embraced mobile devices.

Mobile reception is more challenging. “With an indiscriminate invasion of LP10 stations in New Jersey, the mobile listener will typically drive into one or more large areas of interference. They will not tolerate fluctuating signals arising from squalls of interference, as they drive through the signals of LP10 stations scattered through the service areas of full power FM stations,” writes NJBA attorney John Garziglia of Womble Carlyle.


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