The head of an LPFM consulting and advocacy group is pressing the Federal Communications Commission to recognize a growing number of performance issues facing low-power FM stations.
REC Networks founder Michelle Bradley filed comments encouraging the commissioners as well as the leaders of the Media Bureau’s Audio Division to take further steps to improve the situation. This recent letter follows a 2015 Petition for Rulemaking by REC to improve the LPFM service.
In the new filing, Bradley pressed the commission to consider upgrading LPFM stations as a means of providing improved signal strength and delivering a higher quality of service in their core three-mile zones. Her proposal would allow LPFMs to upgrade from the equivalent of 100 watts at 30 meters height above average terrain to 250 watts at 30 meters HAAT, for service that she refers to as LP-250.
“In some cases, [it would] help stations reach out to outlying communities that would otherwise not be covered,” Bradley wrote.
She also said that “LPFM stations have no codified recourse” when it comes to interference from direct reception from another station. For example, an FM translator is permitted to use a directional antenna to wrap its interference contour around an existing LPFM station, she said, which can lead to interference and reduced coverage, but “the current rules do not include LPFM stations as being protected from interference to direct reception.”
While REC supports Class D and C AM stations’ access to FM translators to supplement their signals, the proliferation of such translators should not come at the expense of original “hyperlocal” services provided by LPFMs, she wrote. Bradley thinks the problem may be exacerbated when the FCC translator windows widen and Class A and B AMs start to apply.
“We need, at the minimum, assurances that LPFM stations have recourse when actual interference from FM translators takes place.”
She also believes the Audio Division has misapplied the Local Community Radio Act in denying waiver requests from LPFM stations for co-channel and first-adjacent channel FM translator protections. Protections provided by the LCRA in these instances apply only between LPFM stations and full-service FM stations, she said, not translators.
REC also wants the commission to allow LPFM licensees to participate in the second of the two FM translator auction windows scheduled for 2017. “Translators will help some LPFMs, especially in rural areas, better serve unusual geographies and other communities within their counties,” she said.
“We need to make sure that LPFM stations, like full-power FM stations, FM translators, FM boosters and even Class D FM stations (the original LPFM) have a method of recourse in the event of actual interference to direct reception within their protected contours by FM translator stations,” she wrote. “The recent influx of FM translators is starting to encroach into the established LPFM service, including some stations that have been on the air for nearly a decade,” she said.
Comments on the original petition can be filed using Proceeding Number RM-11749.