FM Broadcast Class C4 & §73.215 Changes

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).  This petition also calls for changes to §73.215 where larger full-power stations (mainly Class C) had never operated their stations at full facilities would be protected at their current facility parameters instead of at the maximum facility parameter for their station class.

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.  REC estimates that just over 200 Class A stations could upgrade to C4 however many Class A stations are currently running with substantially small service contours for a variety of reasons such as their community need does not dictate a larger facility and international protection. 

The §73.215 change would allow the proponent of a C4 (or any other service class) that is short spaced under §73.207 but properly spaced under §73.215 to request an "Order to Show Cause" as to why the short-spaced full-service station (mainly Class C stations) should not be protected to their full facility even though their actual facility is lower.  While REC has not performed any studies on this, the proponent of the change is claming that up to 700 stations could potentially upgrade causing even more issues and potential displacements of LPFM stations.  The §73.215 downgrade part of this proposal does not provide any fringe benefit to LPFM since it does not result in a change to the station class of the "downgraded" station.  This is different than current policy that permits a Class C station operating at less than 450 meters HAAT to be downgraded to C0. 

REC cautiously supports the C4 class portion of this petition if it is accompanied by by several rule and policy changes (including a reinterpretation of the LCRA) to afford LPFM stations maximum flexibility in the event of increased noise floor.  REC opposes Class C4 in Zone I (not part of the original petition). 

REC staunchly opposes the §73.215 aspect of the Notice of Inquiry as it will increase the noise floor towards LPFM and FM translator stations and could substantially reduce opportunities for new LPFM stations by extending commercial FM services into areas where stations already exist.