REC Networks filed a Petition for Rulemaking with the FCC calling for changes in how LPFM stations are required to protect FM translators. There's a lot to digest here, and for those interested in LPFM and its impact on others, it’s worth a deeper read here.
In the June 13 filing (RM-11810), REC’s Michelle Bradley writes that the petition addresses “various issues that had been precluding a more successful deployment of Low Power FM stations, especially in suburban and core urban areas.”
Specifically, “REC proposes to create a §73.815 Regime of protection for protecting full-service FM, Class D, FM translators, FM boosters and other LPFM stations which is available to LPFM stations that specify locations that do not meet the current distance separation requirements of §73.807.”
According to a summary on REC’s website, “Due to the way the LCRA was worded, REC is making a case that a table of lower distances, originally intended for 10 watt LPFM stations was codified in the rules when the LCRA was enacted and that the Commission can use those numbers.” Bradley also notes that many of the suggestions were previously was raised in the 2017 Media Modernization proceeding (MB Docket 17-105).
Here’s a breakdown of the differences between the current and proposed second regimes:
Current Regime (§73.807)
- 50 to 100 watts at 30 meters HAAT. (up to a 5.6 km service contour)
- Protects full-service stations using specific distance separations.
- Protects FM translators and LPFM stations using specific distance separations.
- Because of distance separation, any interference to other facilities is non-actionable. Full-service stations that file subsequent applications can only legally displace an LPFM station if there is LPFM interfering contour overlap in the city grade contour of city of license of the modified full-service station.
Second Regime (§73.815)
- 50 to 250 watts at 30 meters HAAT. (up to a 7.1 km service contour)
- Protects full-service stations by contours but must also meet a distance separation using reduced requirements from §73.807.
- Protects FM translators and LPFM stations using contours.
- Because of using contours, any interference to or from other facilities is actionable and will be handled through similar rules used by FM translators.
- Second (§73.815) Regime applies only if the LPFM creates a new or increased §73.807 short-spacing of full-service or translators or if the LPFM wishes to operate with a facility that exceeds 100 watts at 30m HAAT (maximum 250 watts at 30m HAAT).
Additionally, the petition suggests a variety of changes that reflect what they consider to be the “maturity” of the LPFM service, and also “allows LPFM stations more options for changes and presents them in a manner that is respectful to Commission policy and decorum and does not put the grant of any existing cross-service FM translator license at risk.”
In the petition’s conclusion, Bradley urges the commission to “adopt this rulemaking and help move LPFM forward to the next generation in a manner that strikes a balance between community need and crowded spectrum while respecting the status quo.”