19-193: REC to FCC: Stop NAB's cat-and-mouse game and move forward on LP-250, FM translator relief and LPFM short-spacing.
In Reply Comments before the Federal Communications Commission, REC Networks called-out the National Association of Broadcasters and their ongoing excuses and fear mongering over the past 20 years in their war on new voices in radio comparing the conflict to something out of Tom and Jerry cartoon. REC demonstrates how the NAB had used deception back in 2000 to fool Congress, who are not necessarily broadcast engineers of what third-adjacent channel interference would “sound” like and how the NAB’s 2012 concerns about second-adjacent channel waivers for LPFM stations would cause a massive amount of interference despite FM translators using the same exact policy without any issues raised by national organization.
The cartoon reference came when REC was comparing the Tom and Jerry cartoons to the ongoing conflict the NAB is creating towards LPFM while ignoring the bigger threat in the room.
“It is important to realize too that in the past few years while Tom (NAB) has been chasing Jerry (LPFM) around the kitchen over the LPFM interference myth, Spike the Dog, in the form of alternative media services such as satellite radio, audio streaming and “over the top” video services is in the process of eating both Tom and Jerry for lunch. In other words, these “non-radio” services are more threatening to Beasley, Saga and Hubbard than any 250-watt noncommercial station would ever be.”
REC again calls for the Commission to bring up a 250-watt LPFM service and the ability for LPFM stations to use advanced engineering towards FM translators and other LPFM stations in a manner that complies with the Local Community Radio Act of 2011.
REC tells the New Jersey Broadcasters Association that “what happens in Jersey, stays in Jersey”. While recognizing that New Jersey was the birthplace of FM radio and that because of population density, not every Class A FM station is running more than a 3 kW facility, REC recognizes New Jersey’s unique spectrum situation being wedged between the New York and Philadelphia markets but also demonstrates in detail that the LPFM stations are not causing any interference to New Jersey full-service stations and that New Jersey already gets special treatment in the Local Community Radio Act. REC states a position that New Jersey should not dictate the policy for the rest of the country.
REC addresses the issues faced by LPFM stations over the Emergency Alert System and while REC supports alerting, it calls on the Commission to rethink the role of LPFM and Class D FM’s role in the EAS given the high price of equipment and updates as well as the hyperlocal nature of the stations and the number of inapplicable alerts LPFM stations receive, especially in large counties out west.
REC clarifies the use of directional antennas by LPFM stations, continues to support LPFM boosters, agrees on up to an 11 km minor move radius without a contour study, supports the elimination of channel 6 protection requirements, the elimination of “franken FM” stations, calls for the FCC to add a “silent station” rule for LPFM and opposes any new foothill effect rules for existing LP-100 stations while supporting them for future upgraded LP-250 stations as well as for FM translator relief and LPFM short-spacing applicants.
REC is asking for LP-250, translator relief and LPFM short-spacing to be brought up in a Further Notice of Proposed Rulemaking as not to delay any future filing windows for new LPFM and reserved band FM stations. REC will continue to work closely with Commission staff to move these proposals forward.
# # # # #