Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554
In the Matter of )
)
Creation of a Low ) MM Docket No. 99-25
Power Radio Service )
) RM-9208
) RM-9242
)
)
MOTION FOR EXTENSION OF TIME OF COMMENT
AND REPLY COMMENT DEADLINES
Pursuant to 47 C.F.R. § 1.46, the National Association of Broadcasters (“NAB”); 1 the
Consumer Electronics Manufacturers Association (“CEMA”);2 the North Carolina Association of
Broadcasters (“NCAB”);3 the Virginia Association of Broadcasters (“VAB”);4 as well as, the
Alabama Broadcasters Association, Alaska Broadcasters Association, Arizona Broadcasters
Association, Arkansas Broadcasters Association, California Broadcasters Association, Colorado
Broadcasters Association, Connecticut Broadcasters Association, Florida Association of
Broadcasters, Georgia Association of Broadcasters, Hawaii Association of Broadcasters, Idaho
State Broadcasters Association, Illinois Broadcasters Association, Indiana Broadcasters
Association, Iowa Broadcasters Association, Kansas Association of Broadcasters, Kentucky
Broadcasters Association, Louisiana Association of Broadcasters, Maine Association of
Broadcasters, Maryland/District of Columbia/Delaware Broadcasters Association, Massachusetts
Broadcasters Association, Michigan Association of Broadcasters, Minnesota Broadcasters
Association, Mississippi Association of Broadcasters, Missouri Broadcasters Association, Montana
Broadcasters Association, Nebraska Broadcasters Association, Nevada Broadcasters Association,
New Hampshire Association of Broadcasters, New Jersey Broadcasters Association, New Mexico
Broadcasters Association, The New York State Broadcasters Association, Inc., North Dakota
Broadcasters Association, Ohio Association of Broadcasters, Oklahoma Association of
Broadcasters, Oregon Association of Broadcasters, Pennsylvania Association of Broadcasters,
Radio Broadcasters Association of Puerto Rico, Rhode Island Broadcasters Association, South
Carolina Broadcasters Association, South Dakota Broadcasters Association, Tennessee Association
of Broadcasters, Texas Association of Broadcasters, Utah Broadcasters Association, Vermont
Association of Broadcasters, Washington State Association of Broadcasters, West Virginia
Broadcasters Association, Wisconsin Broadcasters Association, and Wyoming Association of
Broadcasters (“State Associations”)5 (collectively, “Movants”) request that the Commission extend
the comment deadline by ninety (90) days and reply comment deadline by one hundred fifty (150)
days in the above-captioned proceeding.
The Commission’s Notice of Proposed Rule Making (“Notice”)6 was published in the
Federal Register on February 16, 1999. The comment and reply comment deadline dates are set at
April 12, 1999, and May 12, 1999, respectively.7 The new deadlines would be July 12, 1999, and
October 11, 1999, respectively. Movants believe there is good cause for the FCC to provide an
extension of these deadlines. The Commission’s Notice proposes to establish a new low power
radio service within the existing FM band. The established comment period is too short for the
completion and evaluation of ongoing and planned studies to measure the effects of the proposal.
An additional 60 days to file reply comments is necessary so that parties may properly respond to
any studies that are submitted at the comment stage.
The Notice proposes relaxation or elimination of interference protection requirements as a
means to create a viable LPFM service.8 These include 2 nd adjacent, 3 rd adjacent and intermediate
frequency interference requirements. The Commission also suggests a novel supposition – reducing
the FM channel bandwidth by half for these LPFM stations – and requests information on the
impact that this might have on stereophonic reception.9 These proposals, and others in the Notice,
require comprehensive evaluation. The Commission, itself, has requested that commenters consider
and comment on the harmful effects to existing stations and listeners, and the current state of
receiver technology.10 Providing this detailed information will take substantially more time than the
Commission has allowed for this proceeding.
Various parties to this Motion plan on conducting studies to determine the impact of some of
the proposals in the Notice. For example, NAB has commenced a series of technical studies to
ascertain the impact of low power FM facilities on existing FM reception. First, NAB will study the
characteristics of various categories of FM receivers. After that study is complete, NAB will use
that information to determine the interference impact on stations – and their listening audiences – in
specific markets. Additionally, NAB is commissioning study to evaluate the economic impact of a
new radio service on the quality of radio now enjoyed by the public.
CEMA also has commenced a significant study of FM receivers, and their performance
with, and susceptibility to, the FCC’s proposals and to other interference impairments. CEMA
believes the data derived from these evaluations will provide the Commission with a factual
technical record to better assess the impact of its proposals.
The NCAB and VAB are retaining engineering and economic experts to assist in analyzing
the numerous proposals contained in the Notice. Given the complexities involved in the possible
creation of new low power and microradio services, NCAB and VAB believe several different types
of engineering studies may need to be performed in several different types of markets. Moreover,
NCAB and VAB believe that it will not be possible to commence the economic analyses until the
engineering studies are completed.
The named State Associations also support the request for extension of time to file. They
will be meeting at NAB’s State Leadership Conference in Washington D.C. on March 6 – 9, 1999.
The State Associations will be discussing the LPFM Notice and determining whether other studies
should be conducted.
Each organization believes the additional time is necessary to complete and evaluate these
studies and then submit comments to the Commission in this proceeding. The information derived
from these studies is vital in order for the Commission to establish a comprehensive record upon
which it may make a knowledgeable decision on whether to adopt or reject its proposals.
Thus, the Movants respectfully request that the Commission extend the filing deadlines for
comments and reply comments to July 12, 1999 and October 11, 1999, respectively.
Respectfully submitted,
NATIONAL ASSOCIATION
OF BROADCASTERS
1771 N Street, N.W.
Washington, D.C. 20036
(202) 429-5430
Henry L. Baumann
Jack N. Goodman
Barry D. Umansky
Lori J. Holy
CONSUMER ELECTRONICS
MANUFACTURERS ASSOCIATION
2500 Wilson Boulevard
Arlington, VA 22201-3834
(703) 907-7638
Gary Klein
Michael Petricone
NORTH CAROLINA ASSOCIATION
OF BROADCASTERS AND VIRGINIA
ASSOCIATION OF BROADCASTERS
Wade H. Hargrove
Brooks, Pierce, McLendon, Humphrey &
Leonard, L.L.P.
P.O. Box 1800
Raleigh, NC 27602
(919) 839-0300
Counsel for the North Carolina Association of
Broadcasters and the Virginia Association of
Broadcasters
ALABAMA BROADCASTERS
ASSOCIATION, ALASKA
BROADCASTERS ASSOCIATION,
ARIZONA BROADCASTERS
ASSOCIATION, CALIFORNIA
BROADCASTERS ASSOCIATION,
COLORADO BROADCASTERS
ASSOCIATION, CONNECTICUT
BROADCASTERS ASSOCIATION,
FLORIDA ASSOCIATION OF
BROADCASTERS, GEORGIA
ASSOCIATION OF BROADCASTERS,
HAWAII ASSOCIATION OF
BROADCASTERS, IDAHO STATE
BROADCASTERS ASSOCIATION,
ILLINOIS BROADCASTERS
ASSOCIATION, INDIANA
BROADCASTERS ASSOCIATION,
IOWA BROADCASTERS
ASSOCIATION, KANSAS
ASSOCIATION OF BROADCASTERS,
KENTUCKY BROADCASTERS
ASSOCIATION, LOUISIANA
ASSOCIATION OF BROADCASTERS,
MAINE ASSOCIATION OF
BROADCASTERS,
MARYLAND/DISTRICT OF
COLUMBIA/DELAWARE
BROADCASTERS ASSOCIATION,
MASSACHUSETTS BROADCASTERS
ASSOCIATION, MICHIGAN
ASSOCIATION OF BROADCASTERS,
MINNESOTA BROADCASTERS
ASSOCIATION, MISSISSIPPI
ASSOCIATION OF BROADCASTERS,
MISSOURI BROADCASTERS
ASSOCIATION, MONTANA
BROADCASTERS ASSOCIATION,
NEBRASKA BROADCASTERS
ASSOCIATION, NEVADA
BROADCASTERS ASSOCIATION, NEW
HAMPSHIRE ASSOCIATION OF
BROADCASTERS, THE NEW YORK
STATE BROADCASTERS
ASSOCIATION, INC., NORTH DAKOTA
BROADCASTERS ASSOCIATION,
OHIO ASSOCIATION OF
BROADCASTERS, OKLAHOMA
ASSOCIATION OF BROADCASTERS,
OREGON ASSOCIATION OF
BROADCASTERS, PENNSYLVANIA
ASSOCIATION OF BROADCASTERS,
RADIO BROADCASTERS
ASSOCIATION OF PUERTO RICO,
RHODE ISLAND BROADCASTERS
ASSOCIATION, SOUTH CAROLINA
BROADCASTERS ASSOCIATION,
SOUTH DAKOTA BROADCASTERS
ASSOCIATION, TENNESSEE
ASSOCIATION OF BROADCASTERS,
TEXAS ASSOCIATION OF
BROADCASTERS, UTAH
BROADCASTERS ASSOCIATION,
VERMONT ASSOCIATION OF
BROADCASTERS, WASHINGTON
STATE ASSOCIATION OF
BROADCASTERS, WEST VIRGINIA
BROADCASTERS ASSOCIATION,
WISCONSIN BROADCASTERS
ASSOCIATION, AND WYOMING
ASSOCIATION OF BROADCASTERS
Richard R. Zaragoza, Esq.
Fisher Wayland Cooper Leader & Zaragoza
L.L.P.
2001 Pennsylvania Avenue, NW, Suite 400
Washington, D.C. 20006
(202) 775-5660
Counsel for the named State Associations
March 5, 1999
ARKANSAS BROADCASTERS
ASSOCIATION AND NEW MEXICO
BROADCASTERS ASSOCIATION
Frank Jazzo, Esq.
Fletcher Heald & Hildreth, P.L.C.
1300 North 17 th Street, 11 th Floor
Rosslyn, VA 22209
(703) 812-0470
Counsel for Arkansas Broadcasters
Association and New Mexico Broadcasters
Association
NEW JERSEY BROADCASTERS
ASSOCIATION
John Garziglia, Esq.
Pepper & Corazzini, L.L.P.
1776 K Street, NW, Suite 200
Washington, D.C. 20006
(202) 296-0600
Counsel for the New Jersey Broadcasters
Association

1 NAB is a nonprofit, incorporated association of television and radio stations and broadcast
networks which serves and represents the American broadcast industry.
2 CEMA, a sector of the Electronic Industries Alliance, is the principal trade association of the
consumer electronics industry. CEMA members design, manufacture, distribute and sell a wide
variety of consumer electronics equipment, including radio broadcast receivers.
3 NCAB is a voluntary non-profit trade association of some 23 television and 154 radio stations in
North Carolina.
4 VAB is a voluntary non-profit trade association consisting of some 22 television stations and 104
radio stations in Virginia.
5 The State Associations represent radio broadcasters in all states, the District of Columbia and
Puerto Rico.
6 In the Matter of Creation of a Low Power Radio Service, MM Docket No. 99-25, released
February 3, 1999.
7 64 Fed. Reg. 7577 (1999).
8 Notice at ¶ 45 and ¶ 46.
9 Id. at ¶ 56.
10 Id. at ¶ 46.