[grc] LPFM 250 - comment by June 21

Mon Jun 21 06:37:48 PDT 2021

Thank you Caitlin for the comments.

Today is LP250 day!  It's time for our voices, especially our rural and 
suburban voices to speak louder.

LP250 will bring those stations that meet the slightly higher technical 
requirements and are otherwise able to make an upgrade the ability to 
extend their average service contour from 3.5 to 4.4 miles.  Not only 
will this help reach to listeners further out, but it will also help 
with some performance issues in town.

I do want to point out that LP250 is not gloom and doom for urban 
opportunities.  First things first, we absolutely oppose any kind of 
redlining that specifically forecloses on urban LP250 opportunities as 
was previously proposed back in 2012.  Unlike in the past, we do not 
have the distraction of a competing 10-watt microstation preservation 
effort that ruined our chances for LP250 back in 2012.

In our studies, we consider an LPFM to be "urban" if their service 
contour has a population of 100,000 persons or higher.  Currently 18.3% 
of all LPFM stations serve at least 100,000 persons.  4.3% of LPFMs have 
a service area of over 250K and less than 1% have a service area that 
exceeds 500K.   Rural areas (less than 25K) represent 45% of all LPFM 
licensees with "deep rural" (less than 10K) being over one quarter of 
the LPFM stations in America.

Even for the LPFM stations we classify as "urban", up to 44% of these 
stations will have some form of path to an upgrade.  This path may 
require a channel change. It may face challenges from more stringent 
second-adjacent channel waiver requirements. Stations may be limited on 
expanding antenna builds as for some stations in all population classes, 
upgrading to LP250 may require switching out antennas (such as going 
from 1 bay to 2 bays) or switching out transmitters, which in some cases 
may require electrical work to accommodate a 220V AC transmitter.

The major change since the last times we proposed LP250 was a positive 
statement from the FCC that a certain engineering aspect of the LPFM 
service called the "buffer zone" can't be compromised.   Think of the 
"buffer zone" as this 12 1/2 mile protective aura around every 
full-service broadcast station that has existed since day one of LPFM in 
order to "help LPFM stations cope with full-service stations making 
minor moves in their community" (or so they say)... Past proposals 
busted this buffer zone, mainly because the FCC proposed to bust the 
buffer zone in 2012.  Fast forward 8 years and the FCC says, no.. you 
can't do that!  The 12.5 (20km) buffer zone must stay, otherwise we 
think it will run afoul of the LCRA.  As a result, we had to extend the 
minimum distance separation requirements to make up for the full buffer 
zone that both the FCC had REC had proposed to bust in the past.

Nationwide, nearly 56% of LPFM stations will be able to upgrade on 
channel and of those that can't upgrade on channel, nearly half of them 
could upgrade with a channel change.

Today is the deadline for filing in the FCC's Electronic Comment Filing 
System in proceeding RM-11909.

REC had filed comments this morning.  Our comments just gave general 
support for the petition.  We also addressed some of the negative trade 
press coverage LP250 has received (the typical NAB-like blah blah blah 
it will interfere with everything, yadda yadda yadda) as well as dealing 
with a small number of LPFMs in a peculiar station where they are spaced 
at a specific distance where both stations would be able to ask for 
upgrades but only one could get it due to distance separation rules.

Our comments as well as the reports we filed today with the FCC can be 
found at
https://recnet.com/LP250

You can also check for LP250 potential for any LPFM station at:
https://check.lp250.com

Thank you for your support of LP250 and HAPPY LP250 DAY!!

*Michelle A. Bradley, CBT*
/Amateur Radio: KU3N/
/Founder - REC Networks/ - *https://recnet.com* <https://recnet.com>
*1-844-REC-LPFM* / +1 202 621-2355
SBE Certified
On 6/21/2021 12:32 AM, Caitlin Reading via grc wrote:
> Dear GRC Friends,
>
>   If you aren't familiar with the Simple 250 proposal and are wondering your
> community radio station
> will be able to apply to increase power, the short answer is;
>      Most LPFM stations, in urban markets & where the dial is crowded, will
> *NOT* be able to
> benefit from this potential change.
>      This is a good thing for folks who have stations in rural areas,
> locations where their listenership
> is spread out and typically where FM service is, well, underserved.
>       Keep in mind that "LPFM" is, by definition, low power equal to or less
> than 100 watts. It is a
>    broadcasting classification.
>       Historically there have been some stations that have applied for
> waivers to increase power,
> particularly in areas that are, let me say "land challenged" or operating
> in communities that expand
> beyound the typical urban delineations & density. Some waivers have been
> granted. Some stations
> are able to utilize "boosters" or repeaters, antennas that are placed to
> overcome geographic obstacles
> such as mountain shadows to carry or fill in the signal so it can achieve
> full coverage of it's allotted range.
> 250 might provide another choice to these folks too.
>        Michele Bradley, who has worked diligently spearheading this effort,
> has information available on the
> REC website.
>         It's a good thing to support LPFM comrades, even if it is not to
> your own direct benefit. Yet be clear on
> what you are supporting lest you garner unrealistic expectations.
>         Take action responsibly.
>
> make a difference every day
> c. reading, community radio activist / advocate
>
> On Sun, Jun 20, 2021 at 8:45 PM Sharon Scott via grc <grc at maillist.peak.org>
> wrote:
>
>> Grassroots Radio Friends,
>>
>> As you may have heard, the FCC is currently accepting comments in
>> support of RM-11909, the Simple LP250 proposal from REC Networks that
>> could nearly triple the operating power of America's Low Power Radio
>> stations!
>>
>> The Commissioners need to know that the American people support this
>> increase.  ALL Community Radio Activists should get their comments
>> submitted to the FCC by MONDAY, June 21st.  It is SO IMPORTANT that we
>> get a lot of momentum on this proposition - - this could be a HUGE DEAL
>> for Community Broadcasting nationwide and we may not get this
>> opportunity to increase our collective power again.  While specific
>> testimonials in support of your local station are welcome, even simply
>> telling the FCC, "I support LPFM 250" will help!
>>
>> For info on LPFM250 and instructions on submitting FCC comments:
>> http://artxfm.com/LPFM250/
>>
>> To UPLOAD pre-written documents in support of RM-11909 use this link:
>> https://www.fcc.gov/ecfs/filings
>>
>> To file an "Express Comment" and type your comment directly into the FCC
>> website click here:
>> https://www.fcc.gov/ecfs/filings/express
>>
>>
>>
>> In Solidarity,
>> Sharon
>>
>>
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