Educational Media Foundation has been one of several groups lobbying the FCC recently as the agency wrestles with the question of how to carve out enough spectrum for a meaningful low-power FM license auction and protect the rights of FM translator owners at the same time.
In notices filed with the agency about its lobbying efforts, EMF agrees the interests of both are important; however it still opposes the proposed cap of 50 FM pending translator applications to one organization and the one-to-a-market cap. The national cap would harm rural listeners, no matter what actual number is placed on the number of pending translator applications that can be processed, because any limit will result in organizations pursuing the applications that will serve the most people, with the commission dismissing the rest.
WHO'S SAYING WHAT ABOUT LPFM & TRANSLATORS
EMF presumes the majority of those dismissals would be in rural areas. “Dismissal of applications that serve rural areas is of concern, as these areas are the ones that are in most need of diverse services, and translators provide the most cost-effective way” to provide those services, according to EMF. It also doesn’t believe there would be much demand for LPFM spectrum in rural areas
After reviewing its pending FM translator applications to comply with a presumed national cap of 50, EMF has dismissed about 200 applications and has 300 remaining from the 2003 window. EMF also suggested to the commission that concerns about translator speculation have been overstated, especially in connection with the proposed one-to-a-market cap. “While there may have been some applicants who filed multiple applications on different frequencies at the same site, those were probably not filed for purposes of speculation, but instead so that applicants increased their chances of getting at least one translator,” noted EMF, which said it did not do this but understands applicants would want to do all they could to increase their chances of getting a granted FM translator “and this filing technique was not against the rules.
Instead of caps on applications, EMF suggests limits could be placed on granted applications — or, to exempt small and unrated markets from the caps.