LPFM.AG Proposal

Proposed various changes to the LPFM service including the ability to operate commercially, have full parity between LPFM and FM translator technical rules, primary status for LPFM, changes to assignments and transfers, ownership caps and removing the "-LP" from call signs.

Since the original 1999 Notice of Proposed Rulemaking, commercial LPFM operations have been opposed from a wide range of organizations and other entities.  The Commission has already denied an attempt to introduce commercial LPFM in an Order on Reconsideration.  Due to numerous statutes that can't be waived by the FCC specifically for LPFM, commercial LPFM would not be possible without the necessity of using competitive bidding (auctions) to resolve mutual exclusitivity as well as the payments of filing fees and annual regulatory fees.  Statutes would put our "one to a customer" ownership limits into jeopardy.  In addition, Commercial stations may be required to pay higher music licensing fees through ASCAP, BMI, SECAC and SoundExchange.  The GMR "$1 per year" rate would not apply. Implementing full translator rules in LPFM would violate Section 3(a) of the LCRA.  Primary status violates Section 5(3) of the LCRA and would subject LPFM stations to evaluations under Section 307(b) of the rules to assure fair, efficent and equitable distribution of licenses among the states and communities thus meaning that the FCC may deny a license if there's too many stations in a particular area.  LPFM stations would need to demonstrate why their city of license would need a new allotment.  Moves would be scruitinized and moves from rural to urbanized areas would be prohibited under the Rural Radio decision.  

While REC would like to see LPFM stations use every opportunity to obtain funding through the use of commercial advertising, the current legislative environment that all broadcast services operate under is not conducive to the small organization and local nature of LPFM.  Under a commecial regime, LPFM stations will pay far greater fees for music licensing, taxes as well as fees to the FCC they never had to pay before.  While primary service is desirable for LPFM, current statute prohibits it and the FCC cannot waive it.  REC does agree that there needs to be some changes in the handling of assignments and transfers as well as the elimination of the requirement that LPFM stations have an "LP" suffix in their call sign.  The aspects of RM-11753 that REC agrees with are in our comments in MB Docket 17-105.

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