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03-185: Comments filed in this proceeding.

Updated 7/20/2022 08:00 ET

This is a working document that provides a brief outline of what organizations are saying in their comments on MB Docket 03-185.  This document is used internally by REC to compile information for the consideration of Reply Comments and we will share this document with the public.

This document is active and will be periodically updated as new comments come in.

REC, NAB, NPR, HD Radio and broadcasters express their concerns about using boosters for geo-targeted advertising

The comment period has closed in MB Docket 20-402 in the Geo-Targeted Booster proceeding.  In this specific comment period, the FCC wanted comments related to the recent testing of Geo Broadcast Systems (GBS) "zone-casting" system based on the reports submitted by GBS.  The tests were conducted at KSJO, San Jose, California and WRBJ-FM, Brandon Mississippi.  The following is a brief summary of the comments, both supporting and opposing, regarding zone-casting and the recent tests.

REC Position: LPFM operation at ERP greater than 250 watts

With the recent news that the FCC will be cracking the door open slightly on the possibility of the use of Channel 6 spectrum (82~88 MHz) for use by FM broadcasting, there has been a lot of buzz on social media and the discussion boards related to LPFM.  We have heard comments from people wanting dedicated channels for LPFM stations as well as increased power for LPFM stations, such as 500 or 1,000 watts for stations in this spectrum.  

FCC to consider ongoing operation of existing FM6/Franken FMs, Expanded FM Band and Elimination of Reserved Band Protection Requirements

At the June FCC Open Meeting, the Commission will consider a Notice of Proposed Rulemaking (NPRM) in MB Docket 03-185 in regards to Low Power TV (LPTV) stations operating on Channel 6 that provide an analog FM radio service on 87.75 MHz.  REC and the FCC refer to these as "FM6" stations and they are commonly referred to as "Franken FM" stations.  The FCC is also considering changes that would eliminate the reserved band FM Channel 6 protection requirements and to extend the FM broadcast band to 82.1 MHz in areas where no channel 6 operations are taking place.

FCC to move more radio filings to LMS on May 17, 2022

The FCC has announced that over a dozen different types of filings that were done previously in CDBS and temporarily on "paper" (email notification), as well as some new filing types will be able to be done electronically through LMS starting on May 17, 2022. 

These application types include:

2021 NCE Window: What's next in the process? (updated 5/2/22)

As we proceed through the aftermath of the 2021 NCE Filing Window, some may be asking, how long it is going to take for the FCC to start granting applications.  If we attempt to compare to the 2007 NCE window, it may be a challenge to compare since the 2007 window was much more enormous in scale.  In 2007, the FCC received over 3,000 applications, which resulted in the establishment of 457 groups of mutually exclusive (MX) applications.  By comparison, in the 2021 window, the FCC received 1,282 applications, resulting in 231 MX groups.

REC Position: Those with a "pirate past" directing existing LPFM stations

Let’s be up front on one issue before we continue, many years ago, REC issued a position statement about unlicensed operation of a broadcast station, commonly referred to as “pirate radio”.

REC conducts document audit on NCE MX groups in point system

Between February 4 and February 9, 2022, REC Networks (REC) conducted an exercise where in order to better predict the potential winners of mutually exclusive (MX) groups from the 2021 NCE Filing Window (Window), we reviewed applications that were subject to comparative review in the point system.  As such, we examined documents provided in order to support claims for the established local presence, diversity and state-wide network points.  If we had found a lack of supporting documentation or documentation contrary to the points being claimed, we would reject those claims in our system, note the reason for the rejection of those claims, re-compare the group and in some cases, select a new potential winner.

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