Comments RE: MM Docket No. 99-25 (Creation of a Low Power Radio Service)
Walter Molony
7558 Davian Drive
Annandale, VA 22003
February 5, 1999
As a potential community broadcaster, I would like to provide comments on the proposed Low
Power FM service from my background as a former broadcast engineer (held the old "FCC First
Class" license) and as a current amateur radio operator (Advanced Class).
The FCC's proposed power levels, antenna heights and station separation parameters all appear to
be based on sound engineering judgment. For LP100 and microstations, the low power levels and
small service areas should negate any need for 2nd or 3rd-adjacent channel considerations. While
there may be some validity to concerns for LP1000 station 2nd-adjacent channel separation,
improvements in receiver technology nullify this concern and the benefits of the new service far
outweigh the unlikely exceptions.
However, new LP1000 stations should be required to protect existing co-channel and 1st-adjacent
channel LP100 stations.
Channels 201-220 (88-92 MHz) should be reserved for noncommercial educational broadcasters,
including community and religious organizations. Channels 221-300 should be available to both
commercial and noncommercial entities.
Use of radio broadcast auxiliary frequencies for STL needs should be allowed, especially for
LP1000 stations who may not be able to locate studios near their transmission facilities.
As for future digital services, the more aggressive bandwidth utilization of IBOC by existing
broadcasters may be more likely to cause interference to LPFM rather than the reverse, and it
appears that current broadcasters are using the "interference argument" as a part of their effort to
thwart introduction of a LPFM service.
Proposed transmitter certification, using existing standards, would insure correct operation and
minimal harmonics. Additional masking or bandwidth restrictions would prove unnecessary given
the limited power ranges of the new service. However, sacrificing LPFM subcarriers should not
be detrimental to the overall goals of establishing the service.
If necessary, a compromise regarding bandwidth that would not impact transmitter costs could be
achieved by limiting the modulating frequencies above 12 KHz. This could be achieved
economically by attenuating frequencies over 12 KHz in the audio processing stage, and would
still provide acceptable stereo audio fidelity.
As for programming, LPFMs should be able to use a network service at their discretion.
Particularly in a startup mode, a broadcaster may need to rely more on such programming to
allow time to develop and increase the level of local programming.
No specific regulations regarding public interest programming should be imposed on LP100 or
microstations. Similarly, other service rules shouldn't be imposed on the smaller stations.
LP100 and microstations should be able to renew their licenses at specific intervals (e.g. 8 years).
In many metro areas, only a few LP100 stations may be technically feasible and those who make a
concerted effort to serve their community and/or fight against the odds to become commercially
successful should not be faced with losing their license simply because other voices may want the
frequency.
Commercial transmitters currently available for a 100-watt facility costs approximately $5,500
and a 30 meter tower costs in the range of $3,000 installed. This means getting an LP100 station
on the air can easily cost $10,000, depending on the facilities and other equipment. Broadcasters
taking these risks of time and money should not be penalized with the uncertainty of being able to
keep their license. Unless they have failed to meet stated service requirements, a "renewal
expectancy" is most appropriate in this situation.
Electronic filing of applications makes sense, but auctions don't. Bidding by commercial applicants
could conceivably exceed constructions costs. A lottery method would be preferable, giving small
broadcasters the opportunity to put limited resources into their station facilities rather than the
rights to the frequency. To resolved mutually exclusive applications, there is merit to the "first-come"
processing method during a specified application window.
I appreciate this opportunity to comment, and hope my next communication will be a license
application!
Cordially,
Walter Molony