REC Networks initial statement on NAB/Xperi Petition for Rulemaking
Currently, all FM stations (including LPFM stations) are permitted to operate at a digital effective radiated power (ERP) of -14 dB below carrier (dBc), which equates to 4 percent of their analog ERP. Stations can operate up to -10 dBc (10 percent of analog ERP) with a contour study showing that the station meets certain contour overlap requirements to first adjacent channel stations.
The Petition for Rulemaking filed by the National Association of Broadcasters and Xperi (HD Radio) is based on real-world experiences and while it will still keep the maximum digital ERP at -10 dBc, it will loosen the criteria for stations to operate at digital ERPs higher than -14 dBc while maintaining some form of first-adjacent channel protection.
This will help some stations that are currently constrained including NCE community stations as well as make it easier for some LPFM stations to better implement HD Radio for their limited service areas.
While we are concerned about some isolated minor potential for increased digital interference towards secondary services, we support most of the proposal as it will make HD Radio more robust and help in our overall objective of keeping radio relevant in a sea of non-broadcast competition for the listener's ear. For grandfathered Class B and C super power stations, we do not support any increase of digital ERP to any more than 10 percent of the maximum analog ERP based on Class B or Class C maximums for similar stations at the same height above average terrain.
REC will be watching and plans to participate in this proceeding.