The Low Power FM Advocacy Group believes that without some changes in FCC rules, the entire LPFM service is at risk.
LPFM-AG is a nonprofit with hundreds of LPFM member stations, supported by a volunteer staff of attorneys, advocates and engineers.
In comments filed by its Executive Director David Solomon, the organization says that low-power FM stations in the United States face mounting competition from big tech, just as large groups do, but also unique technical barriers including a 100-watt ceiling and rigid translator restrictions.
Solomon noted that the LPFM universe includes community-based broadcast stations operated by churches, schools, civic organizations, cultural organizations, local nonprofits, public-safety entities and community groups.
Such organizations typically “cannot compete financially for full-power NCE facilities or commercial facilities.”
The 16-page filing is part of the FCC’s biennial communications marketplace review, conducted every two years. That review coincides now with the commission’s latest review of broadcast ownership rules, conducted every four years.
There are about 2,000 LPFM stations licensed in the country. [Related: “Visualizing U.S. Radio Station Counts Since 2000”]
“A 100-watt LPFM station in 2001 did not face the same competitive environment, receiver environment, in-car environment, spectrum environment, cost environment or listener-fragmentation environment that LPFM faces in 2026,” LPFM-AG told the FCC.
Now a listener can choose from streaming music, podcasts, satellite radio, smart speakers, mobile devices, connected vehicles, social video, YouTube and countless app-based audio products.
Solomon believes the FCC must consider changes if LPFM is to survive over the next five to 10 years.
“The commission should not allow LPFM to become a declining, paper-local service trapped by a 100-watt ceiling, crowded spectrum, unequal technical tools, rigid translator restrictions, uncompensated displacement, limited programming access and rules that make local origination harder to sustain than rebroadcast operation,” he wrote.
“The rules governing LPFM leave that service with a diminishing practical ability to remain audible, finance operations, obtain programming, preserve frequency identity, recover from displacement and improve facilities in a marketplace transformed by digital audio, in-car streaming, smart speakers, podcasts, satellite radio, and a far more congested FM dial.”
The FCC must recognize that any local originating radio service should have a minimum practical facility opportunity no smaller than the lowest-powered secondary rebroadcast service used to deliver local programming to FM listeners, Solomon argues.
Yet the current regulatory framework allows FM translators to operate with up to 250 watts ERP where permitted, while LPFM is limited to 100 watts ERP at 30 meters HAAT, or equivalent facilities producing no more than a 5.6 kilometer 60 dBu contour.
LPFM deserves an “equal regulatory opportunity” to compete and survive, he wrote.
LPFM-AG proposes that the FCC adopt a “Practical Survivability Parity” standard for evaluating LPFM and FM translator parity. If the rules “leave one coequal secondary service materially less likely to survive than another, equal status has failed in practice.”
FM translators and boosters outnumber LPFM stations by more than four to one, according to FCC data. However, LPFM-AG says the FCC should not measure LPFM competition by counting licenses alone.
The FCC numbers only prove that LPFM operates within a crowded secondary environment, Solomon wrote.
“The opportunity to improve, relocate or preserve (LPFM) service can be materially affected by translator density and by rules that provide translators greater practical flexibility.”
He says a new regulatory framework should include:
- An interference-safe on-channel upgrade path allowing LPFM stations to elect translator-equivalent technical treatment, including up to 250 watts ERP or directional/contour-equivalent facilities where permitted;
- A service-preservation envelope for LPFM displacement and interference remediation;
- Modernization of LPFM-owned translator rules, including IP or other alternative signal delivery and translator-to-translator links where all facilities rebroadcast the same LPFM primary;
- Relief from LPFM-specific translator restrictions that make translator opportunities nominal in many markets;
- Mitigation and continuity obligations when full-service modifications destroy existing local LPFM service;
- Modernization of LPFM ownership, transfer and continuity rules;
- Examination of a limited local promotional and programming-barter framework that would allow LPFM stations to obtain essential community-serving programming and support continued operation without abandoning nonprofit local control.
Solomon concluded that LPFM “gives the smallest public servants a voice where full-power facilities are unavailable or unaffordable. But a voice that cannot survive cannot serve. Equal status must mean a fair ability to survive. Localism must mean more than counting signals; it must include preserving the ability of local originators to remain audible to their communities.”
The biennial communications marketplace review is ongoing. You can read LPFM-AG’s comments here.
