February 6, 1999 )
) MM Docket No. 99-25
BEFORE THE FEDERAL COMMUNICATIONS )
COMMISSION, Washington D.C. )
)
TABLE OF CONTENTS
I. INTRODUCTION
1. An important decision.
2. We must work together with full-power
broadcasters.
3. The FCC has recognized the need for LPFM.
4. LPFM means diverse programming and
training.
5. LPFM brings radio back to the local
community.
6. LP-1000 can work in rural areas where full
facilities are not available.
II. SPECTRUM CONSIDERATIONS
7. We must make 87.5-87.9 available to LPFM.
8. Commercial use of the reserved band by LP-100
and microstations.
9. LP-1000 should be subject to reserved band
restrictions.
10. LPFM access to Auxillary Broadcasting
Services.
III. SPECTRUM PRIORITY
11. The interference potential.
12. LP-1000 should be primary.
13. Other LPFM should be secondary.
IV. OVERVIEW OF THE SERVICES
PROPOSED
14. LP-1000 for rural areas only.
15. LP-100 for urban and suburban areas.
16. Rural LP-1000 should protect urban LP-100’s.
17. Protection to translators.
18. “Translators” for LPFM.
19. The “Microradio” class.
20. Names of classes.
21. Transmitter certification.
22. Control of transmitter purchases.
23. Use of directional antennas.
24. In regard to booster stations.
25. Special event, part time microradio stations.
26. Use of frequency coordinators.
27. On third-adjacent channel protection.
28. IBOC and keeping the FM band analog.
29. LPFM does not need subcarriers.
V. OWNERSHIP AND ELIGIBILITY
30. Cross-ownership of full power broadcast and
LPTV.
31. LPFM in exchange for AM stations.
32. Cross-ownership with other media.
33. Technical qualifications of LPFM licensees.
34. One to a market.
35. National ownership.
36. Residency requirements.
37. In regards to unlicensed operations.
VI. SERVICE CHARACTERISTICS
38. Local-origination program requirements.
39. NEPA and electronic radiation protection.
40. Political broadcasts.
41. Operating hours.
42. License terms.
43. Construction permits.
44. Regulatory fees.
45. Sale of stations.
46. Emergency Alert System (EAS).
47. Station identification.
48. Inspections and public files.
49. Shut down stations due to impermissible
interference.
VII. APPLICATIONS
50. Electronic filing.
51. Mutually exclusive (MX) applications.
52. Frequency Coordinators.
53. Filing windows.
54. Auctions.
VIII. INTERNATIONAL NOTIFICATION
55. Protecting Mexican and Canadian stations.
56. Distance spacing of LPFM stations.
IX. SUMMARY
57. In conclusion.
APPENDIX A – REC NETWORKS’ PROPOSED
DISTANCE SPACING FOR LPFM STATIONS.
APPENDIX B – LIST OF THE 50 MAJOR
METROPOLITAN AREAS WHERE LP-1000
STATIONS WOULD NOT BE AVAILABLE
WITHIN A 100 KM RADIUS.
APPENDIX C – MAPS OF SELECTED MAJOR
METROPOLITAN AREAS DETAILING WHERE
LP-1000 STATIONS WOULD NOT BE
AVAILABLE
APPENDIX D – OUR PROPOSED LPFM
SERVICES AT A GLANCE
APPENDIX E – AN EXAMPLE OF
TRANSLATORS THAT WOULD NOT BE
PROTECTED BY SECONDARY LPFM STATIONS
UNDER PARAGRAPH 17 OF OUR COMMENTS.
APPENDIX F – A LISTING OF RADIOS WE OWN
THAT COVER CHANNELS 198, 199 & 200.
APPENDIX G – FREQUENCY SEARCH FOR REC
LOCATION BASED ON OUR PROPOSED
DISTANCE SPACING.
REC Networks comments relating to FCC 99-25
-i-02/
06/1999