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REC Position Statement: Part 15 Broadcaster Status In Relation To LPFM

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There is one group that wishes to give "Part 15 Broadcasters" a "point" for LPFM where it comes to a comparative review.

Part 15 transmission systems in the broadcast bands operate on both AM and FM. There are several methods of distribution such as an antenna, carrier current and "leaky coax".

Part 15 transmission systems have very limited field strength restrictions. Systems operating on AM or operating through carrier current or leaky coax systems in educational campus environments are allowed a little more leeway.

Part 15 systems can range from professional systems to consumer devices such as the C. Crane FMT, a device currently used at REC as an over the air monitor for J1. Part 15 devices can also include children's toys (Mr. Microphone) and soundtrack systems used by drive-in movie theaters.

Unlike commercial, non-commercial and LPFM stations, Part 15 systems are not subject to licensing (they are licensed by rule), EAS requirements, public file, studio rules, interference protection requirements, table of allotments and virtually all administrative and technical rules that licensed broadcasters face including obscenity rules.

While some Part 15 operators provide a valuable service to their neighborhoods and campuses, they are not accountable to the FCC (other than basic technical compliance), their community and other spectrum users.

In addition, unlike licensed broadcasters, Part 15 operations are not registered by the FCC or an independent coordinator and therefore, bona-fide Part 15 operations could not be determined. REC's attempt to create a national Part 15 registry in consideration for protections in the LPAM proceeding was met with substantial resistance from the Part 15 community.

For these reasons, REC Networks does not consider a broadcast operation using an unlicensed transmission permitted under Part 15 of the rules as a "broadcast station" for the purposes of obtaining preference points in a comparative review. At the same time, we also do not consider the operation of a Part 15 transmitter as an attributable media interest that would have to be divested or discontinued with the issuance of a LPFM construction permit.