[grc] [Stubblefield] Request to the FCC to commercialize LPFM

[Michi Bradley]

    Statement of REC Networks in regards to LPFM.AG's Petition for
    Rulemaking filing.

Submitted byMichi Bradley <http://home.recnet.com/user/1>on Mon, 
07/27/2015 - 21:24

Dave Solomon's Low Power FM Advocacy Group (LPFM.AG) has filed their 
Petition for Rulemaking with the FCC.  If the FCC decides to assign a 
rulemaking number and move it forward for comments, it may take a month 
based on how long it took to move REC's LP-250 petition that became 
RM-11749.

LPFM.AG's petition comes from a very important aspect of the LPFM 
service, the "microbroadcast" segment, the segment of LPFM stations that 
are primarily started by organizations created solely for the purpose of 
running LPFM stations unlike other LPFM stations that are operated under 
the auspices of a well established "brick and mortar" organization such 
as a church, ministry, educational institution, government agency or 
service organization.

Unlike the other segments, the microbroadcast segment does not have the 
same funding sources and backing that other LPFM organizations may have. 
  It is very understandable why some of these licensees would desire the 
ability to provide supporters with the ability to get a message out 
without having to be in the confines of Section 399b of the 
Communications Act that codifies the restrictions for non-commercial 
educational (NCE) stations that LPFM falls under.

REC continues to oppose LPFM being in a situation where commercial and 
non-commercial interests would compete for spectrum due to regulations 
and statutes that require auctions to settle mutual exclusitivities and 
puts community ownership at risk.  REC is also concerned about the 
economic impacts of minority-owned and family-owned full-power stations, 
especially in rural areas.

In our initial evaluations of the LPFM.AG proposal, there are some 
aspects of the petition that do warrant consideration.  When reviewing 
these proposals, we must first take into consideration any aspect of the 
rules that was established by statute (such as the Communications Act, 
the Local Community Radio Act, the Balanced Budget Act, etc.) as these 
aspects of our operating environment can not be changed without an act 
of Congress.  We must also review whether the proposals are technically 
sound and how the proposals harmonize with the other broadcast services.

As demonstrated over the past few months on social media, the LPFM.AG 
petition has struck some chords both within the LPFM community as well 
as the full-power community especially over the ability for LPFM 
stations to air commercials.  REC hopes that we can have a civil 
discussion on the issues now that they are in the open.  We need to be 
open to all ideas and allow them to have their due process.

Until the LPFM.AG petition is given a rulemaking number at the FCC, 
comments can not be filed on this petition.  Once it is assigned an RM 
number, there will be a 30-day comment period.

For now, read the petition and form your own opinion and be ready to 
comment. Whether you support all of it, some of it or none of it, your 
opinion will matter.

Michelle Bradley
Founder: REC Networks

_/Related links:/_

Low Power FM Advocacy Group (LPFM.AG) Petition for 
Rulemaking<http://apps.fcc.gov/ecfs/comment/view?id=60001095736>(pending 
FCC processing)

REC Position on a Commercial LPFM Service 
<http://home.recnet.com/commercial-lpfm>(01/2015)

The Six Segments of LPFM <http://home.recnet.com/6segments>



On 7/29/2015 5:23 PM, Donna Dibianco wrote:
> This is Dave Solomon's counter to Michi's filing. Frankly, Mr. 
> Solomon's approach is quite rough. He has attacked nearly everyone in 
> the fold if/when we didn't agree 100%.
> Sorry, but I will not tolerate anyone attacking my peers and 
> colleagues whom I have known for eons.
> His hubris precedes him, and egomania is not my bag.
> *Donna DiBianco*
> Station Start-up Specialist_
> 503-960-1068_
> www.linkedin.com/pub/donna-dibianco 
> <http://www.linkedin.com/pub/donna-dibianco/2b/13b/459/>
> www.facebook.com/communityradiogoddess 
> <https://www.facebook.com/communityradiogoddess>
>
>
>
> On Wednesday, July 29, 2015 1:18 PM, "juice at whidbey.com" 
> <juice at whidbey.com> wrote:
>
>
> Request to the FCC to commercialize LPFM
> Tom.
>
> http://apps.fcc.gov/ecfs/comment/view?id=60001095736 [1]
>
>
>
> Links:
> ------
> [1] http://apps.fcc.gov/ecfs/comment/view?id=60001095736
>
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