REC Networks has filed comments on the Low Power FM second notice of proposed rulemaking (NPRM). In comments, REC supports various pro-LPFM initiatives proposed by the FCC including second adjacent channel waivers as well as compensation to LPFM stations when full power FM stations make a change of its community of license or other facility changes.

REC feels that more room for LPFM can be achieved by eliminating unnecessary and conflicting rules including rules requiring LPFM stations to protect other station's IF channels as well a major change on how reserved band LPFM protects LPTV and Class A stations on TV Channel 6.

On this date 5 years ago, the FCC issued a public notice which effectively puts a nail in the coffin for hundreds of LPFM applications. These were the applications that were impacted by the Radio Broadcast Preservation Act enacted by Congress which mandated third-adjacent channel protection by LPFM stations to full-power and translator stations. While some applicants were able to move to other channels, many applicants were "deadlocked" and could not change frequencies or locations to remain compliant with the Act. A Petition for Reconsideration lead by REC and supported by others was denied by the Commission.

5 years ago this week, the FCC opened the "Auction 83" filing window which was designed to expand the number of FM translators. As a surprise to many, over 14,000 applications were filed in the window with a significant number of them filed by the co-owned Radio Assist Ministries and Edgewater Broadcasting.

What eventually surfaced was a long battle by REC, Prometheus and the grassroots movement that eventually lead to the FCC starting to look at their policies regarding speculative filing. As a result, the FCC has placed limits on the number of pending applications from that filing window and to address potential issues of speculative filing in the full power services, the FCC imposed a similar limit on last year's Non-Commercial Educational (NCE) FM filing window.

While we encourage all proponents to support the future development and expansion of LPFM stations in comments, for those who wish to specifically address the issues that the FCC is raising in this second Further Notice of Proposed Rulemaking (FNPRM), REC has complied a list of the questions and issues the FCC is seeking comments on. Our listing is in a bulleted list format for ease of reading. When we file detailed comments, we first prepare a document like this to work off of.

REC encourages everyone to read the Report and Order and Second FNPRM.

Our doucment does not express any opinions. We will be releasing positional information on issues at a later time and for some issues, after consultation with our allies.

Deep in a notice of proposed rulemaking (NPRM) for broadcast diversity (MB Docket 07-294), the Federal Communications Commission, acting on a recommendation by Mullaney Engineering, would propose the expansion of the FM Broadcast Band to include the spectrum of TV Channels 5 and 6 (76-88 MHz).

If approved, this could open opportunities for 60 additional channels to the existing 100 channels.

The spectrum between 76-88 MHz is already used for FM broadcast in Japan (their FM band is from 76-90 MHz and they have television in the 90-108 MHz range).

REC will be working together with our allies and media partners to provide our own concept of an expanded Channel 5 & 6 spectrum.

Notice of Proposed Rulemaking

Comments of Mullaney Engineering