Statement of REC Networks: Informal objections filed by Prometheus, et. al. against pending FM translator applications

Elkhart, Indiana – May 17, 2018

What happened?

Last night, a consortium representing Prometheus Radio Project, Common Frequency and Center for International Media Action (from herein, referred to as “Prometheus, et al.”) has filed nearly one thousand informal objections against virtually every pending FM translator original construction permit and modification application including short-form applications that have not been accepted for filing. 

Let’s first discuss the issues that Prometheus et al has raised in the objection.   

Initial Statement of REC: Prometheus, et. al. informal objection against many cross-service FM translator applications.

REC is aware of the informal objection that was filed against hundreds of FM translator applications by Prometheus Radio Project, Common Frequency and the Center for International Media Action.  This objection raises issues related to the Local Community Radio Act and it's application to the recent Auction 99 and 100 windows.   Due to previous obligations, REC is not prepared to comment at this time but expects to have a statement issued prior to 11:59PM EDT today, Thursday, May 17. 2018.

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Translator to LPFM interference and the proposed interference rulemaking (MB Docket 18-119)

Based on two petitions for rulemaking filed by the National Association of Broadcasters (NAB) and Aztec Capital Partners, the licensee of a translator in New Jersey and the massive growth and concentration of FM translators that originally started with the Great Translator Invasion of 2003 and then increased by the various efforts in 2016 to 2018 to support AM Revitalization, the FCC has opened this proceeding to address the issue of a large number of interference complaints the FCC has received from these new translators and how some form of a balance can be found between the incumbent broadcasters and the new secondary translators.  For the purpose of this document, we will limit the context to that of LPFM stations but many aspects of this document can be applied to other FM translators as well as for full-service facilities.

Letter to Chief of FCC Public Safety & Homeland Security Bureau regarding LPFM participation in the September 2017 Nationwide EAS Test

Dear Ms. Fowlkes,

I am very sad to say that this is the second year in a row that I have had to write to you regarding results of the participation of LPFM stations in a Nationwide EAS test.  As a major stakeholder who advocates for the LPFM service, I am very disappointed by the outcome of LPFM’s overall participation in the test.  While LPFM stations did report an increase in receiving and retransmitting the test message, the actual percentage of LPFM stations participating was very disappointing.  After the 2016 test results, I had hoped that Staff would have reached out to me, so we could work on uncovering why the participation was so low and what we could do to improve it.  

Statement of REC Networks on the departure of Commissioner Mignon Clyburn from the FCC

The airwaves belong to the people, not just a few CEOs and shareholders but to all of the people.  During her tenure at the FCC, Commissioner Clyburn's focus has been on the people and she was always looking for ways to bring more women and minorities into the ranks of broadcasters.  Some of REC's recent initiatives have been inspired by her aspirations to give a voice to those who do not have one.  Her speaking style was very eloquent and outspoken. She was not afraid to hold back.  This could be best evidenced in her dissent in the recent proceeding to repeal net neutrality.  At the FCC, she was a warrior and she will be deeply missed.  Hopefully, her legacy will carry over in her successor.  Thank you Mignon Clyburn for all you have done.  Your contribution didn't go unnoticed.

PIRATE Act: Well Intended, But Misguided

Statement of REC Networks, Michelle Bradley regarding the draft "PIRATE Act".

You may have heard about a bill that may be considered in the U.S. House of Representatives, the "Preserving Illegal Radio Abuse Through Enforcement" or PIRATE Act.  This draft bill has been presented to the Energy and Commerce Committee, Subcommitee on Communications & Technology by Rep Leonard Lance (R-NJ) on March 22, 2018.  For those of us who are familiar with the recent history of broadcast regulation, the New Jersey Broadcasters Association (NJBA) has been very vocal and has been a staunch opponent of LPFM.  Through the influence of the NJBA, the so called "New Jersey Rule" was placed into the Local Community Radio Act of 2010.  Under the New Jersey Rule, full-service FM stations in New Jersey can object to LPFM stations in a similar manner that they can oppose FM translators under §74.1204 of the rules.  In the 2013 LPFM window, no New Jersey full-service broadcast station filed such a protest.  It is possible though they can still object to modifications.  So, yes, New Jersey has a strong broadcast lobby.

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