Current Issues

Here are issues that REC is currently following as well as any notes and opinions regarding these proceedings.

Docket Title Comments Impacts to LPFM


REC Comments

Class C4 FM Service Petition by SSR Communications to create a new Class C4 FM broadcast service.  This would be an upgrade path from Class A FM stations.  Service contour greater than 28.3 km and less than 33.3 km.  Service would only be available in FM Zone 2 (where C3, C2, C1 C0 and C is already available). C4 may create additional incoming interference to LPFM stations on the fringes of upgraded stations.  Most LPFM stations will not feel the impact due to the spacing of LPFM stations to full service stations (overprotection due to the buffer zone).  A fairly low number of Class A stations will be able to or want to upgrade.  REC is working to assure that LPFM stations are not precluded from moves in a manner consistent with the LCRA.



Reply Comments

REC LP-250 Petition Proposed to create a new class of service to allow many LPFM stations to upgrade from a 5.6 km service contour to a 7.1 km service contour by operating at a power equivilent to 250 watts at 30 meters height above average terrain.  Updates to the Petition through Reply Comments and in MB Docket 17-105 suggested a "hybrid" method of protection using a combination of minimum distance separation and contour overlap in a manner that is consistent with the LCRA.  Allow LPFM stations that meet certain qualifications to upgrade automatically and notify the FCC if they made the upgrade.  Increase the distance LPFM stations are allowed to change on a minor move.  New provisions in the assignment and transfer rules to address "failing" LPFM stations. A considerable number of LPFM stations would be able to upgrade on their current channel while many others would be able to upgrade wiht a channel change.  Some upgrades may require new antennas or other methods to protect second adjacent channel stations.  The change to minor moves would bring the policy to a manner consistent with FM translators and without the need for wavier requests.  The "hybrid" method proposed will open up new opportunities for new stations in a future filing window.



AM synchronous boosters Petition by WAPA(AM) to codify on-channel AM boosters.  WAPA had been running these boosters on experimental authoriations. Does not directly impact LPFM and not likely to reduce the demand for cross-service FM translators to rebroadcast AM stations.



REC Comments

Protect local radio service provided by full-in area FM translators Aztec Capital Partners, Inc. petition for rulemaking to afford a level of "priority" to FM translators providing a fill-in AM or FM service in respect to inteference to distant full-service FM stations. LPFM stations would be prevented from opposing the grants of new or modified translators where the LPFM station has listeners in the 1 mV/m service contourof the translator if that translator was being used to rebroadcast an AM or HD-2 station.



REC Comments

Improve the translator interference complaint process NAB petition to permit FM translators to move to any channel as a minor change.  Currently translators are only allowed to make changes to first, second, third or IF adjacent channels unless there is a "trigger" event by a full-service station that would result in displacement.  In contrast, LPFM rules permit changes to "any channel" upon a showing of reduced incoming or outgoing interference. Removes the "predictability" that translators can only change to certain channels.  At the same time, it puts translators on a more level playing field with LPFM stations.

GN 16-142


"Next Generation" Broadcast Television Standard The Commission has approved the voluntary use of "Next Gen" digital television also known as ATSC 3.0. For a period of 5 years from commencing ATSC 3.0 operations, a TV station must keep normal DTV (ATSC 1.0) operations.  Apparently, this can be done using the existing channel bandwidth or on a separate vacant channel. A FNPRM has been filed to discuss the processes around obtaining this temporary vacant channel. This could impact channel 6 and the availability of reserved band FM channels for LPFM and full-service.  While the R&O makes a note of "in-band" alternate channels, we are concerned because it is our understanding that the VHF channels are more desirable for ATSC 3.0.  We need to assure that only VHF-Lo band TV stations can designate channel 6 and that the temporary use of channel 6 does not curtail the availablity of channels 201~220.

MB 17-105

REC Comments

Modernization of Media Regulation This proceeding was an open proceeding where the FCC has asked the public to identify media rules that should be eliminated or changed.  REC has used this proceeding to request that the Commission to amend the rules to allow for more realistic protections of other broadcast facilities by LPFM stations in a manner that is consistent with the LCRA.   Other proceedings will spawn as a direct result of this proceeding. This proceeding was an open forum on changes to media rules.  Several LPFM issues were raised in this proceeding.
MB 17-179 Sinclair-Tribune merger   No direct impacts to LPFM operating rules.

MB 17-231


Maintenance of copies of FCC rules. Eliminates the requirements that licensees of LPTV, TV translator, FM translator, FM boosters and CARS stations maintain copies of several sections of the Code of Federal Regulations. These rules do not exist in Part 73 and have no impact on LPFM stations.

MB 17-264


Public Notice of the filing of broadcast applications/TV station ancillary and supplementary services reporting This is a proceeding that has spawned from 17-105 that address two issues.  First it eliminates a report that is filed by full service TV stations regarding the use of their signal for non-broadcast supplemental services such as datacasting.  Under the proposed rules, only the stations that engage in supplemental services would need to submit reports as they do pay fees on the revenues from provision of those services.  This proceeding also proposes to allow full-service, FM translator and booster applicants to make public notice of certain broadcast applications to be disclosed over the internet in lieu of local newspapers.  The NPRM also seeks comments on modifying the required on-air public notice announcements (e.g. license renewals) can refer listeners to a website instead of broadcasting the information over the air.   Requirements for local public notice of filing of broadcast applications including on-air announcements of renewals (73.3580) does not apply to LPFM stations per 73.801.  Therefore this has no impact on LPFM stations.

MB 17-289


Rules and policies to promote new entry and ownership diversity in the broadcasting services. The Commission has approved this item that would loosen up the ownership limits on commercial stations including eliminating the newspaper cross-ownership rule and the radio/TV cross-ownership rule. There were also changes to embedded radio markets (suburban NYC, DC areas) as well as TV joint sales agreements and shared service agreements. Overall, REC's position that this decision is very toxic overall. The "one to a customer" rule as well as the rules prohibiting broadcast cross-ownership.  There may be an impact where it comes to the newspaper cross-ownership rule.  We are still looking into this.