[grc] Correction: Due Aug. 9 at Midnight

Tue Aug 8 12:18:16 PDT 2023

On 2023-08-08 15:14, Sharon Scott via grc wrote:
> 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. Due Aug. 9 @ Midnight.
> 
> 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
> 
> 
> **********
> **********
> **********
> 
> 
> 
> 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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