LP-250 update

Simple 250 RM-11909

Updated March 8, 2024

On Friday, May 21, 2021, the FCC has assigned RM-11909 to REC’s “Simple 250” Petition for Rulemaking (PRM). 

The Simple 250 PRM was filed in direct response to the FCC’s main concerns regarding the previous LPFM proposals filed by REC.

To address concerns that the previous petitions were too complex and it was in the public interest to keep LPFM “simple”, we developed a new LP-250 class of service that with processes similar to the current LP-100 service without the need for any kind of mandatory contour study to take advantage of the higher power.

To address concerns that the previous petitions would not pass the muster of the Local Community Radio Act of 2010 (specifically Section 3(b)(1), which prohibits the FCC from reducing the distance between LPFM stations and full-service stations), we maintained the 20 kilometer buffer zone, which meant required distances between LPFM stations and all full-service, secondary and foreign facilities would increase.  Minimum distances to co-channel full-service stations would increase by 5 kilometers (up to 9 on Class B and B1 stations) and distances on first-adjacent channels would increase by 2-3 kilometers.

The new service class proposal features the following:

  • 250 watts effective radiated power (ERP) at 30 meters height above average terrain (HAAT), providing an effective service contour of 7.1 kilometers (4.4 miles) with a minimum service contour of 5.7 kilometers (over 3.5 miles).
  • A ceiling of 451 meters HAAT for new LP100 facilities (as service contours for 1 watt above 451 meters would exceed 5.6 kilometers).
  • Creates a second distance separation table for the new LP-250 class of service.
  • Fully respects the 20 kilometer buffer zone.
  • Reinstates the “intermediate frequency” (IF) (+/- 10.6 and 10.8 MHz) protection for any LP250 station operating 101 watts ERP or more. LPFM stations operating at 31~48 meters HAAT should be permitted to limit their ERP to 100 watts in order to avoid IF short spacing. LPFM stations 49 meters HAAT or higher would not be subject to the IF protections as their LP250 ERP would be less than 101 watts.
  • Propose policy for upgrades on stations that already have a second-adjacent channel waiver.
  • Permits a minor move of up to 14.2 km if LP250 is either the current or proposed class of service (can be waived with a contour study like with LP100).
  • Does not add any new process that would require a contour study.  Contour studies that are codified for LP100 (second adjacent waiver, moves beyond 14.2 km and channel 6) will be the same for LP250.
  • Propose to allow upgrades and downgrades between LP100 and LP250 as minor changes.
  • Proposes a “launch window” concept where during a certain period of time, all LPFM stations are considered LP250 for the sole purpose of determining minimum distance to other LPFM stations (this is to allow all qualified LPFM stations a fair chance at upgrading at the introduction of the service).
  • Proposes a simplified radio frequency radiation standard for LP250 stations on non-shared towers, similar to the current LP100 policy.

While some urban area LPFM stations will be able to upgrade to LP250, a large majority of the upgradable stations are in rural and less dense suburban areas.  Our studies show that overall:

  • 39.3% of all LPFM stations would be able to upgrade on their channel without a second adjacent channel waiver.
  • 16.6% of all LPFM stations would be able to upgrade on their channel with an updated second adjacent channel waiver showing.
  • 44.1% of all LPFM stations would not be able to upgrade on their channel, but some may find an alternate channel where upgrade may be possible.

NOTE: These figures are from our original study, we will soon release similar figures for the March, 2024 update.

While the biggest beneficiary of LP250 will be rural areas, we have found that some LPFM stations in the following top-25 urban core areas may have the opportunity:

  • Los Angeles
  • San Francisco
  • Philadelphia
  • Miami
  • Seattle
  • Phoenix/Mesa
  • Tampa & St. Petersburg
  • Denver
  • Charlotte
  • St. Louis
  • San Antonio

Original Simple250 RM-11909 documents

Please read our Petition for Rulemaking for what we submitted to the FCC.

REC LPFM Advisory Letter #11 - LP250 Upgrade: Technical Planning Considerations for LPFM Stations

REC Networks comments in RM-11909 (06/21/2021)

REC Simple250 LP-250 Upgrade Availability Report Summary as of May 24, 2021

REC Simple250 LP-250 Upgrade Availability Detail Report as of May 24, 2021

LP250 information updated March 8, 2024

REC Simple250 LP250 Summary Update as of March 8, 2024

REC Simple250 LP250 Potential Upgrade Availability Detail Report as of March 8, 2024

REC Simple250 LP100/LP250 LPFM Population Coverage Report as of March 8, 2024

REC Simple250 LP250 Potential Upgrade Station Lookup as of March 4, 2024

NOTE: The 2024 data does not take into consideration the Foothill Effect concepts discussed by REC in the past through reply comments.

Filing comments to support LP250

File comments with the FCC through their Electronic Comments Filing System.  For “Proceeding(s)” enter RM-11909.   We are especially interested in hearing from LPFM stations of all sizes that would be able to receive the upgrade.  Explain your community not just within 3.5 miles, but out further; any issues your station is having with being at LP100 and how you think LP250 would not just benefit the station, but the community as a whole.  Please file your comments by June 21, 2021.  

Even though the original RM-11909 comment period has ended, you are still welcome to follow the instructions above to file supporting comments.   Please also contact your Representative and Senators and express your support for this Petition for Rulemaking as a true way to improve localism and improve the rural quality of life in a manner that is bipartisan in nature.

Ideas for what stations can write in their comments.

REC Reply Comments in RM-11909

REC has been working hard for nearly 10 years to get LP-250 out to the areas that need it.  We would always appreciate your support.   Please click on the Donate button on this page.  We thank you in advance!