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IRTS (Ireland) bandplan consultation comments: band plan for new VHF-low amateur spectrum in Ireland.

To whom it may concern,

It is an exciting time to be an amateur operator in Ireland.  Ireland has achieved a massive expansion in spectrum in the low VHF with new allocations at 30-49 MHz and 54-69.9 MHz.  With the hope of a successful reallocation of 52-54 MHz to the Amateur Service in ITU Region I at the upcoming 2019 World Radio Conference, this is a nearly continuous throughout the amateur band we hope could someday inspire some movement in the USA for the FCC to consider a secondary allocation to the amateur service, especially at around 40 MHz. 

FCC denies Prometheus reconsideration request on AM Revitalization decision to not limit cross-service translators to 40 miles. (This is not the recent Informal Objection filings)

Yesterday, the FCC denied the timely-filed Petition for Reconsideration of Prometheus Radio Project in regards to the Second Report and Order that changed rules that stated where a cross-service (AM) translator can be placed. Under the previous rules, cross-service translator service contours were limited to their 2 mV/m daytime contour but no more than 25 miles from the AM station. Under the revised rules, those service contours were limited to an area that consisted of the 2 mV/m or 25 miles, whichever was longer in the subject direction and with no outer limit.

Statement of REC Networks: Informal objections filed by Prometheus, et. al. against pending FM translator applications

Elkhart, Indiana – May 17, 2018

What happened?

Last night, a consortium representing Prometheus Radio Project, Common Frequency and Center for International Media Action (from herein, referred to as “Prometheus, et al.”) has filed nearly one thousand informal objections against virtually every pending FM translator original construction permit and modification application including short-form applications that have not been accepted for filing. 

Let’s first discuss the issues that Prometheus et al has raised in the objection.   

Initial Statement of REC: Prometheus, et. al. informal objection against many cross-service FM translator applications.

REC is aware of the informal objection that was filed against hundreds of FM translator applications by Prometheus Radio Project, Common Frequency and the Center for International Media Action.  This objection raises issues related to the Local Community Radio Act and it's application to the recent Auction 99 and 100 windows.   Due to previous obligations, REC is not prepared to comment at this time but expects to have a statement issued prior to 11:59PM EDT today, Thursday, May 17. 2018.



Translator to LPFM interference and the proposed interference rulemaking (MB Docket 18-119)

Based on two petitions for rulemaking filed by the National Association of Broadcasters (NAB) and Aztec Capital Partners, the licensee of a translator in New Jersey and the massive growth and concentration of FM translators that originally started with the Great Translator Invasion of 2003 and then increased by the various efforts in 2016 to 2018 to support AM Revitalization, the FCC has opened this proceeding to address the issue of a large number of interference complaints the FCC has received from these new translators and how some form of a balance can be found between the incumbent broadcasters and the new secondary translators.  For the purpose of this document, we will limit the context to that of LPFM stations but many aspects of this document can be applied to other FM translators as well as for full-service facilities.

Letter to Chief of FCC Public Safety & Homeland Security Bureau regarding LPFM participation in the September 2017 Nationwide EAS Test

Dear Ms. Fowlkes,

I am very sad to say that this is the second year in a row that I have had to write to you regarding results of the participation of LPFM stations in a Nationwide EAS test.  As a major stakeholder who advocates for the LPFM service, I am very disappointed by the outcome of LPFM’s overall participation in the test.  While LPFM stations did report an increase in receiving and retransmitting the test message, the actual percentage of LPFM stations participating was very disappointing.  After the 2016 test results, I had hoped that Staff would have reached out to me, so we could work on uncovering why the participation was so low and what we could do to improve it.