FCC Opens REC Networks 250-Watt LPFM Proposal For Comments

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    Ran across this on All-Access today:

    The FCC has opened for public comment the petition by MICHELLE BRADLEY’s REC NETWORKS (NET NEWS 4/25) to allow a new class of 250-watt low-power FM stations. The proposal, which would allow the new class of stations to have service contours of up to 7.1 km, up from 5.6 km, would be an increase of the current maximum power for LPFMs of 100 watts. The petitioner suggests that as many as 75% of current LP-100 stations could upgrade to the higher power.
    Comments are due at the Commission within 30 days of FRIDAY; the petition has been given number RM-11749. A rival organization of LPFMs, the LPFM ADVOCACY GROUP, headed by DAVE SOLOMON, has criticized the proposal for not including LPFMs in the noncommercial reserved band.

    Read more: http://www.allaccess.com/net-news/archive/story/141560/fcc-opens-rec-networks-250-watt-lpfm-proposal-for-#ixzz3ac8yAvE0
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    Andy Brown

    Interesting, expected but unlikely to go through as written because they are also asking for:

    a) remove the contour-overlap requirement for LPFM-owned FM translators.

    b) for new second-adjacent channel protection requirements for all FM translators to fix “an inequality” between the rules for both services, REC Networks Founder Michelle Bradley previously told Radio World: “Currently, a translator can come into the second adjacent channel of an LPFM but an LPFM cannot come into the second adjacent of a translator without asking for a waiver.

    c)also asked that the LPFM time-share requirement be lessened.

    You can bet dollars to donuts the religioids will fight their translators being effected by 2nd adjacent RFI.

    Also of note, the proposal does not include LPFMs in the noncommercial reserved band.

    This would require a new spacing table.

    Under the proposal as initially written, please note that no LPFM assigned to Portland would be eligible for this.

    Here’s the Petition For Rulemaking:


    Here’s a complete study of ALL GRANTED LPFM FACILTIIES to determine ability to upgrade to LP-250


    No station currently assigned to Portland is eligible for an upgrade (I urge you to check my work) under the proposed changes. KFFP-LP Beaverton (Free Form Radio) is eligible as is KVPB Vernonia. KQRZ-LP in Hillsboro, KKJC in McMinnville and the stations in Wilsonville are not.
    Again, nothing in the Portland Metro as now operating or at CP status can upgrade.

    Here’s an article about the usual reasons for not being able to upgrade:


    Here’s a quick checker if there are existing call letters or you have the facility ID:


    KISN-LP can be made eligible if KQRZ-LP does not move to 95.1 and stays on 100.7, however a new 2nd adjacent showing would be required. In KISN-LP’s case, the area of interference won’t be significant, but you should expect the NAB to be against further infringing on full class stations through increasing the allowable amount of 2nd channel adjacent RFI.

    Again, this is just the first call for comments and these proceedings usually go on for four or five rounds, so the final rules may or may not look anything like they do now.

    In addition, between now and then, should the FCC open a window for translators, you can bet the deep pocketed interests will file for translators that create a co channel impediment to LPFM’s upgrading. Many of them already have co channel critical spacing which will become short spaced when the new spacing table becomes the rule. In other words, and for example, should KQRZ not use its CP for 95.1 (to let KISN upgrade), but a window for translators results in a whole mess of applications to put a translator on 95.1 over on the west side, any possible upgrade will be quashed by the same reason as explained above, that is, being short spaced under the proposed spacing table for LP-250’s.

    Any questions?


    Is there any rules re: another local non-profit purchasing an existing LPFM CP?


    you can’t sell you, but you can transfer it to another non-prof but only after you own it for an X amount of time. I believe its 4 or 8 years. One of 2 for sure


    Overall I think LP-250 is a great idea. And Andy, you are wrong, there are LPFMs in PDX that could upgrade to 250 if the petition passes. I hope it does.

    Andy Brown

    “4 or 8 years. One of 2 for sure”

    No. The holding period is 3 years.

    §73.865 Assignment and transfer of LPFM licenses.
    (a) Assignment/Transfer: No party may assign or transfer an LPFM license if:

    (1) Consideration promised or received exceeds the depreciated fair market value of the physical equipment and facilities; and/or

    (2) The transferee or assignee is incapable of satisfying all eligibility criteria that apply to a LPFM licensee.

    (b) A change in the name of an LPFM licensee where no change in ownership or control is involved may be accomplished by written notification by the licensee to the Commission.

    (c) Holding period: A license cannot be transferred or assigned for three years from the date of issue, and the licensee must operate the station during the three-year holding period.

    (d) No party may assign or transfer an LPFM construction permit at any time.

    (e) Transfers of control involving a sudden change of more than 50 percent of an LPFM’s governing board shall not be deemed a substantial change in ownership or control, subject to the filing of an FCC Form 316.

    Andy Brown

    ” you are wrong, there are LPFMs in PDX that could upgrade “

    No. YOU are wrong. I double checked. Look at the report I linked to. It will show that:

    •89.5 would be IF short spaced to KKRZ
    •90.3 would be IF short spaced to KXL-FM
    •95.1 previously explained, short spaced to KQRZ CP
    •96.7 the two CP’s would be short spaced to each other, one doesn’t cover any of Portland anyway (probably will file for a different COL like Tigard) and the other is also IF short spaced to KXJM (the only possible omission I could find in the report)
    •99.1 would be IF short spaced to KBVM
    •100.7 Not yet CP’d, but MX settled, so not in the linked REC report. However they will be IF short spaced to KQAC
    •101.5 the two CP’s would be short spaced to each other and IF short spaced to KBOO
    •105.5 the two CP’s are issued but the report was generated previous to that, but they both would be IF short spaced to KNRK.

    Those are all the Portland LPFM’s. These have to be built and on the air soon and if built as proposed, they won’t be eligible to upgrade.

    So, spud, what are you talking about? Remember, you can move an LPFM only a short distance. Some of these are not going to be able to move far enough to clear the short spacing as a minor change. Some of them are right on the edge (they would have to move the maximum allowed – about 5.6 km – and in all cases, the move would have to be away from the center of Portland). Add to that the high expense of relocating, and for most of the LPFM’s that are lucky enough to actually realize their CP’s into a license, doing it all over again will not be tenable. They are going to have to make good on their CP’s well before this rule making is over.

    IF spacing requirements are in the Petition for Rulemaking on page 15.


    Hey all.. Michelle Bradley from REC here.. I just ran across this post while Googling but I do want to clarify some things.

    On the statements made by some who said that the LP-250 upgrades will not cover stations in the reserved band. This is not true. The confusion came from a proposal as a part of LP-250 called “automatic upgrade” where eligible stations would be able to upgrade by public notice instead of having to file a 318. If they upgrade in the automatic upgrade period, they would only need to file a 319 to tell the FCC that they did upgrade. As a part of the automatic upgrade concept, we excluded certain groups of stations:
    – Stations within 320 km of Canada or Mexico (due to international reporting requirements)
    – Stations that are operating under second adjacent channel waivers (since new showings would have to be made to assure compliance with the LCRA)
    – Stations that have not completed construction (I can see this caused some confusion above…)
    – Reserved band stations (due to the band crowding issues and many areas plus channel 6)
    Keep in mind, there are only about 60 LPFM stations in the reserved band nationwide.
    ** Those stations that do not qualify for _automatic_ upgrade authority but can still otherwise upgrade would need to file a 318 under the concept of automatic upgrade authority. If the FCC does not move forward with automatic upgrade authority (which is most likely what would happen), then everyone files 318s.

    On translators, LPFM cross-owned translators are subject to the following restrictions:
    – They can only hold two
    – The translator must receive the LPFM station over the air (no microwave, STL, internet, satellite, etc.)
    – The translator must carry the analog or HD-1 program (no HD-2 translators)
    – The translator must be located within 20 miles of the primary community of license or the LPFM transmitter location (within 10 miles for markets 1-50)
    – The service contour of the translator must overlap the service contour of the LPFM station.
    REC is proposing to remove the last requirement. This is to allow cross-owned translators to have some additional flexibility while still remaining within the 20/10 mile localism zone. In other words, it is a redundant requirement and penalizes LPFM stations for using directional antennas for their translators.

    I have not specifically looked at PDX but I know that many metro area LPFM stations will not be able to upgrade due to:
    – Other LPFM stations on the same or first adjacent channel stations.
    – Higher power creating short spacing to translators.
    – Higher power creating intermediate frequency (I.F.) interference (+/- 10.6 and 10.8 MHz)
    – Higher power creates a new second adjacent channel short spacing (which would likely not be recoverable unless the LPFM station can show lack of contour overlap)

    As far as objections by the translator operators. REC’s LP-250 is supported by the National Translator Association and even one of the largest translator operators, Educational Media Foundation does not oppose the concept of LP-250, they only raised concerns about contour overlap by LPFM stations (for both LP-100 and LP-250).. They had even suggested that LPFM have contour overlap protection requirements instead of distance spacing for LPFM protection to translators. (This will give LPFM stations more flexibility and could result in some more LPFM stations being allowed to upgrade..)

    The proposal is now out of the initial proposal stage. It is up to the FCC to determine whether to move it forward as a notice of proposed rulemaking. My hope is that it is put together with a review of the rules including the SSR Communications Class C4 proposal (12 kW @ 100m HAAT).

    What was proposed in RM-11749 were things that could be done within existing federal statutes including the Local Community Radio Act.

    Some of the other things we had asked for:
    – Imposing a second adjacent channel protection requirement for FM translators to LPFM stations. Surprisingly, EMF, NTA and NAB did not address or oppose this.
    – Moving the maximum move to 11.1 km for LP-100 and 14.1 km for LP-250. This is more consistent with FM translator rules that permit moves to any location that would involve an overlap in contours.
    – Relief for time share stations that are subject to local programming pledges (there’s only a small handful including at least one in PDX) where there is still an 8 hour a day requirement but those 8 hours are split between the two stations broadcasting on the channel. (The FCC already gives relief for the main studio rule)

    I hope this clears up a bunch of stuff. Hopefully the FCC will move this forward. Thanks again for your support.

    Michelle Bradley
    Founder: REC Networks


    Whatever happened to LP-1000?

    Andy Brown

    Thanks for your input, Michelle. Here in Portland, almost all the LPFM’s needed 2nd adjacent waivers for LP-100. There were so many applications in the Portland-Vancouver metro it’s mind boggling, but many (almost all) are going to be ineligible for a power increase to LP-250 for some of the reasons you listed (and I covered in the post above yours) chiefly I.F. short spacing and co channel short spacing (we have several LPFM’s on the same channel, achieved by moving just far enough apart to pass muster so it won’t be far enough at higher power. Those are two drop dead issues that preclude whether or not new 2nd adjacent distances would be met. Portland has for many years been over served by commercial drop ins class upgrades that previous to 1996 never would have happened but now that the big monster owners own the stations on both ends of the short space, they can downgrade, change channel, etc. to allow moving closer to the metro, upgrading, etc. It’s been a pretty ugly twenty years. Also all of our full service stations come from a tight area in the hills west of downtown Portland and that makes it difficult to put an LPFM any closer then has already been done at LP-100.

    Unfortunately LPFM’s in Portland can’t really cover both sides of the city due to those hills and the presence of all the full service antennae up there. There are presently no frequencies left for translators, either, at least until the LPFM construction permits expire on those applicants that aren’t going to make it. If you want to catch up on what’s going on here, go to this thread:


    Again, thanks for dropping by.

    Andy Brown

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