January 28, 1999

Re:	Notice of Proposed Rulemaking in MM Docket No. 95-25 Creation of a Low Power FM Radio Service

I support issuance of this Notice of Proposed Rulemaking looking toward creation of low power radio service. Many have called upon us to consider a new low power class of service as a means of opening opportunities in radio broadcasting for new entrants. Others contend that authorizing low power services will facilitate "community radio" designed to serve currently unmet information needs. These are worthy goals and we should consider whether we can authorize such services.

Having said this, I want to make clear that I have some concerns about this proposal. I highlight two in particular and urge those who comment in this proceeding to focus on them. First, I urge the parties to develop a full, objective record regarding potential interference problems that might result from creation of these new classes. One very important purpose of this agency is to ensure efficient and effective use of the radio spectrum. I will be very interested in understanding the spectral ramifications of creating low power FM radio service and I intend to consider interference questions very seriously before taking final action.

My second concern relates to the impact that creation of low power service may have on potential conversion to terrestrial digital radio service. I understand that there have been promising advances of late that can enable current radio operations to convert to digital transmission technology "in band on channel." Converting to digital transmission technology could improve the quality of radio service and potentially increase spectral efficiency. These are very real benefits and I would be concerned if authorizing some or all of these low power radio services would make in band on channel conversion to digital radio unworkable for existing terrestrial services. Again, I encourage commenters to focus specifically on this issue, so that we can make a fully informed judgement.