REC FCC Filings: MM Docket 99-25 - Low Power FM Radio Service

Fourth Notice of Proposed Rulemaking

Petition for Partial Reconsideration (1/14/2013) REC is asking that the FCC modify the recent rule regarding periodic announcements by new LPFM stations to apply only to LPFM stations that do not meet third adjacent channel minimum spacing requirements under the old rules. Currently, the rule is written to apply to all LPFM stations that have always been legal under the previous (and current) rules. Letter to FCC Staff on various issues (10/23/2012) Ex-parte presentation on various LPFM subjects and the pending Petition for Reconsideration related to pending Auction 83 translator applications. Partial Opposition to Petition for Reconsideration (6/10/2012) REC opposes EMF's request for reconsideration on the definition of the market boundaries. In the same filing, REC supports a granting of waivers to the "one-to-a-market" policy for translators that are outside of the metro core areas, do not prevent new LPFM stations and do not overlap with other commonly filed applications. Pending application counts by party Details by application Reply Comments of REC Networks (5/21/2012) There is overwhelming support to retain a sub-100 service such as REC's enhanced LP50 service. LP250 should be available to new applicants and usage should be limited in metro areas. A "western" solution for rural LPFM should be examined. Consortia creates licensing abuse, discrimination and the silencing of oppressed voices. Extending the local presence requirements to 20 miles for rural and urban. The restricted cross-ownership of LPFM Translators should also be extended to include Boosters. The timing of the LPFM filing window does not need any artificial delays, there's enough natural delays. Second adjacent waivers should allow for minimal population overlap. Existing LPFM stations on second adjacent waivers are not subject to any increased LCRA interference standard. Comments of REC Networks (5/7/2012) Addressing issues including third adjacent channel, periodic on-air announcements, translator input signals, definition of interference, introduction of LP50 to replace LP10, support LP250, IF channel restrictions, Native Nations, LPFM/translator cross ownership and student operated stations. Proposing a complete overhaul to the selection and time share process while opposing consortia, point aggregation and successive licensing policies. Main document includes Appendices A through E. Appendix A - Proposed spacing tables for LP50 Appendix B - Proposed §73.811 Text Appendix C - Sample Time Share Scenarios Appendix D - REC SuperCoordinator 2012 Summary Potential for LPFM in Metro Markets Appendix E - REC SuperCoordinator 2012 Summary Channels in SL Markets by Type Appendix F - REC SuperCoordinator 2012 LPFM in Individual Metro Markets Appendix G - REC SuperCoordinator 2012 Master Allocations Reports Appendix H - Native Nations Appendix I - LPFM Availability Maps in Top-4 Markets with LP50 Appendix J - Metro LPFM Service Contour Coverage with LP50/100/250 vs LP100 only

Third Notice of Proposed Rulemaking

MM Docket 99-25 and MB Docket 07-172. Reply Comments/Petition for Rulemaking (9/27/11) Addressing some issues already expressed and proposed some changes to the LPFM service in the anticipated next NPRM that will implement Section 3 of the LCRA (elimination of third adjacent channel and codification of the second adjacent channel waiver). Letter from Michi Eyre - REC Networks (9/15/11) Concurred with the National Association of Broadcasters' petition to extend the reply comment deadline date. Comments of REC Networks (9/5/11) Supported the Joint Proposal of REC, Prometheus and Common Frequency to reduce the study area to 20x20 and various aspects of controlling translator trafficking and encouraging localism in the broadcast services. Appendix C - Full 20x20 LPFM Availability Study Appendix D - Summary of each market's availability under 20x20 Motion for Extension of Time (8/28/11) In the aftermath of Hurricane Irene, many people on the Eastern Seaboard are without power and broadcasters, both low power and full service have been working hard to keep their listeners informed. We feel that a two week extension will permit time for power restoration and for proponents to focus on the proceeding. Motion for Supplemental Information (7/29/11) On the date that the NPRM was published in the Federal Register, REC Networks has formally motioned the Commission to release vital information about their channel availability study to obtain a key piece of data that determines how their conclusions were reached.

LPFM and the Great Translator Invasion Auction #83 Window

2x70 Plan - State and Metro LPFM Maps 3-1-2011 - Maps submitted to the FCC graphically showing the likely outcome of the 2x70 plan. Identification of translator applications 2-23-2011 - REC assigns each translator application to 1 of 5 groups to determine if the application should be dismissed or processed - Cover Letter | Lists 1 through 5 Reply Comments 01-11-2011 reply comments to the 21 broadcasters who have pending translator applications and Educational Media Foundation with an alternative solution to strike a balance between translator and LPFM applications in a way that is compliant with the Local Community Radio Act.

2005 FNPRM

Comments Support many pro-LPFM issues Report Proposed protection to LPTV/Translator Channel 6 stations LP-100 Nationwide Availability Map Legacy Translators eligible for protection LPFM in Metropolitan Areas

Opposition Oppose Station Resource Group motion to exntend comment period Letter Letter from REC to the FCC Office of the Inspector General Motion Motion to extend reply comment perod Reply Comments and Report Listing of all translators bought or sold by Radio Assist Ministries and Edgewater Broadcasting

MITRE Report

Comments MITRE Report comments - supports lifting third adjacent restriction Top 5000 communities that can gain LPFM Proposed rule changes Mitre maps generated by REC: Alabama-Colorado Delaware-Maine Michigan-Oklahoma Oregon-Wyoming

2nd MO&O

Comments (MS Word) Reply Comments A lot of our early observations about the Great Translator Invasion. Reply Comments - Appendix A List of Radio Assist and Edgewater translators and what they sold for.

BNPL 20000608ACW LPFM stations deadlocked due to RBPA (100+)

Joint Petition for Reconsideration Place all RBPA dismissed applications back into pending status.

MM 99-25 Low Power FM (LPFM) - Original NPRM

Comments Original LPFM comments Amendment Supporting a K-12 school exception on cross-ownership of full power and LPFM. Student run stations. Opposition to Extension REC opposes NAB petition to extend time Amendment LPFM having priority over distant transaltors Amendment Revised distance separation charts Opposition Oppose General Media to extend time of reply comment period Amendment Translator subclasses, TV Channel 6, Reply Reconsideration Addresses unlicensed operations, supports directional antennas in some cases, opposes recognizing grandparented superpower commercial stations, LPAM Reply Comments Low Power Radio Nationwide Channel Availbility (now obsolete) Opposition REC objects to CPB and NPR requests for extension of time.