[grc] Help NCE's extend reach. Sample letter to FCC - Due 8/8 @ Midnight ET

Tue Aug 8 12:14:11 PDT 2023

Community Radio Station and Friends,

Please take a moment to express your support for RM-1995 which hopes to 
make FM translators available to Noncommercial Educational stations, 
including but not limited to LPFM stations.

The information provided below has some insight.  It is always best to 
file comments in to the FCC in your own words but sample letter is 
attached. You may personalize this form letter if you need a simple way 
to show your support.

FILE COMMENT HERE:
https://www.fcc.gov/ecfs/filings/standard

To attach a document select: STANDARD FILING_
To write your own comment select: EXPRESS COMMENT

Under "Proceeding" enter RM-11952

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On 2023-08-08 10:07, Michelle Bradley via grc wrote:
> 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
>> _______________________________________________
>> grc mailing list
>> grc at maillist.peak.org
>> http://maillist.peak.org/mailman/listinfo/grc
> --
> *Michelle Bradley, CBT, KU3N*
> /Founder: REC Networks/
> +1 202 621-2355
> https://recnet.com
> facebook.com/recnet - Twitter: @michichan
> _______________________________________________
> grc mailing list
> grc at maillist.peak.org
> http://maillist.peak.org/mailman/listinfo/grc
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