REC statement of Michelle Bradley, CBT, directed to all LPFM stations regarding LP250 and our current relationship with the NAB

(This originally appeared on the REC Networks Facebook page in an effort to reach all LPFM stations and stakeholders who may not use social media.)

At the 2024 National Association of Broadcasters Show in Las Vegas, I had a chance to have some brief dialogue with the Director of Spectrum Policy and counsel at the NAB to address the issues of LPFM and specifically LP250. While it is premature to state that there was any "progress", I did want to at least get the word out that REC is continuing to pursue LP250 as a second LPFM station class available for existing stations that can meet the extended distance separation requirements as proposed in RM-11909.

Of course, the positions of NAB reflect the opinions of their membership and I stated that I believe the opinions of the [NAB] membership may be misguided in some ways based on past conceptions of LPFM which date all the way back to 1998 during the original rulemaking. There have also been concerns raised about LPFM compliance. I have also raised concerns about LPFM participation in past EAS National Periodic Tests, which is a major issue here at REC.

While there may be some who may be thinking that my relationship and dialogue with the NAB is nothing more than just "sleeping with the enemy", I beg to differ. While the NAB may continue to oppose any expansion to LPFM, there have been many issues lately that may negatively impact LPFM where REC and NAB have common ground. NAB has been recognizing impacts to LPFM stations on various issues such as the recent EAS and geo-targeted booster proceedings.

LPFM will be turning 25 next year. I have been arguing that the service is now "mature" and that some of the issues that NAB members feared back in the late 90s never came to fruition. However, it is important that we as a service, do everything we can to assure compliance at our stations. This includes:

• Assuring that underwriting acknowledgements only identify and not promote.
• Assuring facilities are operating from their authorized locations, antenna heights and effective radiated power.
• That LPFM stations are properly equipped with the latest EAS software/firmware versions and that they participate in each National Periodic Test by submitting all three forms.

The issue around underwriting announcements is probably the most visible that anyone who is scrutinizing the LPFM service can detect. I consider the underwriting issue as one of the main issues as to why there continues to be a major backlash to growth of LPFM.

I am willing to bring to the table a compliance-based prong to getting the LP250 upgrade. Bottom line, if a station is not complying with the rules, they should not be eligible for an upgrade. With the recent decisions in the Low Power TV Protection Act proceeding, there is precedence to include such a provision and I would support such a provision that would be based around Notices of Violation/Forfeitures as well as around participation in the National Periodic Test. If these things are what it takes to assure the NAB membership that those getting the "good things" are the ones doing the "good deeds", then we may have a little more leverage going forward.

I ask the LPFM community to please step up and come on board with these initiatives to assure that your station is operating in compliance by utilizing the REC Self Inspection Checklist, by assuring that your underwriting announcements are compliant using the REC Compliance Guide and that every year, your station is participating in the EAS National Periodic Test.

Again, there is progress, albeit, baby steps. But there is some open dialogue in progress. It's up to all of us as members of the overall broadcast ecosystem to do our part to assure that we are being good neighbors. Big radio needs to realize that little radio is not the threat, but instead, non-radio is the threat. I hope I can count on each station to do their part.