[grc] IMPT: Help LPFMs extend their reach! - File comments by Aug. 8 @ midnight ET

Tue Aug 8 07:07:55 PDT 2023

Correction to the link to the REC summary of the Translator Reform 
petition for rulemaking.

https://recnet.com/node/3849

=m

On 8/8/2023 10:03 AM, Sharon Scott via grc wrote:
> Forwarded from Todd Urick of Common Frequency
>
> -------- Original Message --------
> Subject: FCC Proposed Rule Making Pertinent to LPFM
> Date: 2023-08-08 01:40
> From: Todd Urick <todd at commonfrequency.org>
> To: Todd Urick <toddurick at gmail.com>
>
> If you are affiliated with a non-commercial or LPFM radio station and
> your station ever wanted to apply for a FM translator* (*_a licensed FM
> transmitter to re-broadcast you main station signal to either extend
> your station, or fix interference issues_), you may consider submitting
> a _Reply Comment_ to the FCC by Wednesday August 9 (due by the end of
> the day, midnight eastern time) concerning Proposed Rulemaking RM-11952.
>  This proposed rulemaking asks the FCC to enact policies that limit
> speculators in applying for FM translators (for profiteering purposes),
> and asks to provide more opportunity for non-commercial and LPFM
> broadcasters to apply for FM translators (the next FM translator filing
> window, anticipated in the next couple years).
>
> _You might consider filing a comment to the FCC:_
>
> - Stating you are in favor of limitations on mass FM translator filers
> and speculation.
>
> - Tell the FCC that the next FM translator filing window should be
> designated for LPFM and non-commercial stations only.  Commercial
> broadcasters have been given ample opportunities within the last three
> translator filing windows (two filing windows for translators for AM
> stations in 2017, and a filing window in 2003).
>
> - LPFM has never had an opportunity to file for FM translators. NCE
> stations have not had an opportunity for decades.
>
> - LPFM faces many signal problems.  LPFM licensees have asked the FCC
> for years for signal relief without any opportunity up to this point.
> Tell the FCC your station's signal problems.
>
> - NCE and LPFM community stations have fringe areas where no other local
> community stations serve.  It would be in the local public interest to
> extend those signals to fringe areas with a FM translator.
>
> - If you really want to get into the finer points of the rule-making,
> read below at "BACKGROUND" (recommended).
>
> You can file an ECFS comment with the FCC here:
> https://www.fcc.gov/ecfs/filings/standard
>
> You can choose _STANDARD FILING_ (attach PDF that you wrote) or _EXPRESS
> COMMENT _(write a comment into blank on the FCC site)
>
> Under "Proceeding" enter RM-11952
>
> BACKGROUND:
>
> In August 2022 LPFM advocate REC Networks ("REC") filed the "Translator
> Reform" petition for rulemaking with the FCC.  Recently, the FCC has
> opened a window for comments on the proposal, which is currently in the
> Reply-Comments stage.  REC has proposed to the FCC policies to prevent
> the same trafficking and gamesmanship that followed the last FM
> translator filing opportunity ("filing window", or "Auction") in 2003.
> In this FCC Auction, several speculators filed dozen(s) to hundreds of
> applications for new FM translators on speculation, to merely sell for
> profit.
>
> In 2017 there were two more FM translator filing windows (for new
> translators) for AM licensees to apply to rebroadcast their AM stations
> on FM.  During this filing window, the FCC ignored following the mandate
> of the Local Community Radio Act ("LCRA"), which required the FCC to
> save channels for future LPFM filing opportunities.  Because of this,
> there are not that many frequencies left in cities for LPFM or new
> translators (major cities have no open channels).
>
> REC proposes restrictions within the next FM translator filing window
> which places limitations on the resale of FM translators, requires more
> disclosure of attributable interest, filing caps, and other mild
> limitations.  REC also asks the FCC (for LPFM licensees) to eliminate
> the LPFM to FM translator contour overlap requirement (which is
> untenable), replace the 10/20 mile market-dependent distance
> restrictions for a translator owned by a LPFM with a 25-mile
> restriction, and other small adjustments.  REC proposes an enhanced
> protection system of protecting LPFM openings in the FM band from being
> claimed by translators via a “disparity factor" regimen.
>
> REC requests for the next FM translator file window be designated for
> LPFM and NCE stations to apply for translators between 88.1 FM - 91.9
> FM.
>
> Non-commercial/LPFM advocates Common Frequency has submitted a comment
> that aggressively asks the FCC for much stronger protocols for the next
> FM translator filing window that _favors local non-commercial NCE and
> LPFM stations_.  This list includes:
>
> - Filing caps don't work to keep speculators from applying for large
> amounts of FM translators and reselling them.
>
> - In the last two FM translator filing windows, where AM stations were
> allowed to apply for FM translators, the FCC did not comply with the
> LCRA.  Much more stringent measures are needed to save room for LPFM and
> NCE FM translators.
>
> - Commercial radio licensees do not need another opportunity to file for
> more FM translators because they have had ample opportunities to do so.
> It is time to open an opportunity for only LPFM and NCE FM to apply for
> FM translators, because:
>
> (a) There has been no or little opportunity for them to apply in the
> last two decades
>
> (b) Both services have a dire need to fix signal interference issues and
> extend their local programming to other communities.
>
> Specific policies or actions CF recommends include:
>
> (1) Limiting the number of applications to five by any entity to prevent
> speculation.
>
> (2) The filer should be in the proximity of the proposed new FM
> translator.  Or rebroadcast a station that can be received off-the-air
> (_not via satellite or internet_ -- to dissuade national networks).
>
> (3) The next filing window should be for nonprofits, LFPM, and
> non-commercial stations only.  The FCC should allow applicants to
> propose translators anywhere on the FM band, _not just 88.1 FM -91.9
> FM._
>
> (4) Translators applied for by LPFM licensees should have no 60 dBu
> overlap or distance-to-headquarters requirement.  These measures stifle
> the amelioration of complex interference and signal issues.
>
> (5) Applicants should provide a brief narrative of the "intention of
> use" for a newly-proposed FM translator.  This should deter speculators.
>
> (6) The FCC should modify the "FCC point system" (this system designates
> the highest point-receiver as the winner of a radio channel if multiple
> applicants apply for the same channel).
>
>    (a) A point should be given for a broadcaster with a local studio
> creating local programming.
>
>    (b) A point should be given to broadcasters that currently do not own
> any translators and are only applying for one translator.
>
>    (c) Change the "establish local" point.  This affords points to
> applicants that have been around two years applying for a translator
> within 25 miles of their station.  However, for full power community and
> public stations, they may want to apply for a translator more than 25
> miles away.  The proposal allows these NCE applicants to claim local
> points if it is within the 40 dBu fringe contour of their station which
> shares a common headquarters for the entity.
>
>    (d) Do away with the translator "technical superiority" point system.
> The FCC usually rewards the proposal that maximizes use of spectrum
> (large coverage areas).  Although this subject matter is difficult to
> explain, "technical superiority" usually rewards the dominant
> broadcaster who has access to the best tower site, and does not use
> spectrum strategically.
>
> You can read REC's proposal and Common Frequency's comments via the
> links below
>
> CF's Comment https://www.fcc.gov/ecfs/document/107270843413704/1
>
> REC's Proposed Rulemaking: Well-summarized by REC here:
> _https://recnet.com/node/3849_ and the proposed rulemaking as submitted:
> https://www.fcc.gov/ecfs/document/1072672306591/1
>
> Thanks
>
> Todd
> Common Frequency
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-- 
*Michelle Bradley, CBT, KU3N*
/Founder: REC Networks/
+1 202 621-2355
https://recnet.com
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