REC Networks has filed comments today in MB Docket 18-184, the FCC's Notice of Inquiry based on the SSR Communications petition that would create a new FM service class C4 (12 kW at 100m HAAT, available only in FM Zone II) and would make a change to §73.215 to allow an applicant station to be able to use contours in addition to distance separation in order for the applicant station to upgrade service class (i.e.

We need more diverse ownership.  We need more people, especially women, minorities and the LGBT entering the broadcasting field as more than just DJs, but as owners, directors and major stakeholders of commercial and noncommercial stations.  Chairman Pai's broadcast "incubator" experiment fails to establish a mentorship program but instead creates a free-pass for large corporate broadcasters to get favors where it comes to ownership caps.  We do not know how this impacts the Prometheus v FCC litigation but we are hoping that "Prometheus 2"/Georgetown Law is going to pursue this.   As a cons

REC Networks has filed comments in the FM translator interference proceeding, MB Docket 18-119. 

In comments, REC points out the distinct nature of LPFM stations as well as Class D educational stations and even smaller Class A full-service FM stations that are the most susceptible to interference by new and modified FM translator facilities. 

In their Petition for Reconsideration, Prometheus, et al does make some very compelling arguments as to why the FCC may have violated Section 5 of the Local Community Radio Act where it came to Auctions 99 and 100 as well as the ungranted applications from Auction 83.  Despite that, this does not change REC's original position that opposed the Informal Objections filed against nearly 1,000 FM translator applications in mid-May.  REC continues to maintain the position