LPFM

Take the FmTube Connection to LP-FM Streams News Release March 10, 2008 Update by IowaFM Engineer  Todd Urick New Rules Regarding Low Power Radio Service The FCC wants your comments by APRIL 9, 2008 concerning new rules for "Low Power FM" (LPFM) radio stations.  These are low wattage radio stations that non-profits, schools, and other organizations can apply for to provide a local radio service to your own community.  The FCC may release more frequencies for LPFM usage if they hear enough support from the public.   Iowa LP-FM include:       Community:      KRUU       Overview In response the public's limited access to local radio stations and First Amendment rights on the public airwaves, the FCC created what is called LPFM radio service.  Up to that point, the FCC only had the following classes of FM radio licenses: Commercial FM stations:  These stations generally play hit music or talk, run commercials, and exist to make profit (92.1-107.9 FM).  They can range from 100 to 100,000 watts.  Their licenses are worth millions of dollars. Non-Commercial Educational (NCE) FM stations:  Nonprofit FM stations from 100-100,000 watts primarily on the "reserved" end of the FM radio band (88.1-91.9FM); used by non-profits, college stations, NPR, and religious organizations.  The NCE band is filled to capacity in most areas.  Both Commercial and NCE stations are referred to as full power or primary service stations. Translators (FX) and Boosters (FB):  Translators are automated transmitters (1-250 watts) that rebroadcast a primary station's programming to a new area, or an area of poor reception.  Boosters are infill transmitters used on the same frequency as the main station only within that station's area of service.  Translators have been a hot topic issue because some radio networks are exploiting the service for profit. The LPFM class of service was designated in 2000 as a non-commercial service for non-profits.  These are 100-watt (LP-100) and 10-watt (LP-10) licenses allotted primarily on the commercial FM band (92.1-107.9FM).  LPFM was originally designated as a secondary service, meaning, all licensed LPFM stations must prevent interference on all current and future full power radio stations.   Certain elements of this status are now up for comment. Understanding LPFM Radio frequencies are generally applied for on first-come first-served basis in designated filing windows or auctions.  Non-commercial services follow filing windows-specific dates for filing applications.  Shortly after the first LPFM filing windows, commercial broadcasters (organized under an industry group National Association of Broadcasters [NAB]) lobbied Congress to limit LPFM under the false premise that the service would cause interference to full power commercial stations.  In all likelihood, the NAB simply didn't welcome new competition from new LPFM broadcasters.  This "interference" problem was eventually proven untrue, but the rule is still on the books to this day.  This has meant the LPFM service was never fully implemented, because as the rules stand, the "spacing requirements" for licensing an LPFM require them to have three blank channels1 between them and a full power station.  This unnecessary requirement has made LPFM impossible in most major urban areas.  Below is a pictorial example of the current stringent requirements: Figure 1: Scenario A "Third Adjacent" Spacing Example A:    FM    1    2    3    4    5    6    7    FM B:    FM    3rd    2nd    1st    LPFM    1st    2nd    3rd    FM 95.1    95.3    95.5    95.7    95.9    96.1    96.3    96.5    96.7   ^                    ^          ^          ^ Established            An LPFM    Locally    Established commercial            could fit    "unused"    commercial station on 95.1            here        channels    station on 96.7 Scenario C: "Second Adjacent" Spacing Example     FM    2nd    1st    LPFM    1st    2nd    FM     95.1    95.3    95.5    95.7    95.9    96.1    96.3       ^              ^              ^     Com. Station        LPFM            Commercial Station The channels next to a broadcast station are referred to adjacents. In order to license an LPFM, you need to find Scenario A, a blank space of seven channels between existing stations.  Engineering data shows this type of interference protection for stations is overkill.  The above is referred to as "third adjacent" protections, because the potential LPFM is protecting up to three channels over. Most agree that third adjacent protections should be lifted.  However, even if they are, you would still need to find a space of five blank channels (See Scenario C) to propose an LPFM for any given location.  This type of spacing is still hard to find in most major cities. The Plot Thickens While the rules to license the LPFM service have been in limbo at the FCC, the frequencies that could have carried future LPFM channels have been given away to translator service (see page 1 for definition).  In 2003 the FCC had a translator filing window in which applicants could file as many applications as they wanted for this service.  The translator service was originally meant for broadcasters to be able to rebroadcast a full power FM station in an area of weak or impaired reception, like when you drive behind a mountain and a regional station goes away.  Because of a licensing loophole, religious entities started filing for translators to extend the reach of their primary stations up to thousands of miles from their studio location.   For example, the Calvary Chapel of Twin Falls, Idaho rebroadcasts their primary radio station in Twin Falls via satellite to about 440 translators across the nation.  During the translator filing window in 2003 several entities got in on the action, filing for a combined total of thousands of frequencies.  One entity named Radio Assist Ministry, Inc applied for about 2400 translators without even owning a primary service radio station. Shortly after the 2003 translator filing window the FCC began blindly granting translators to organizations like Radio Assist; Radio Assist began to sell the frequencies to other religious broadcasters for a profit.  The bottom line is that the FCC was giving away the public's airwaves to select groups of individuals-certain individuals were then either selling the frequencies as a profit, or starting remote broadcast networks that provide no local-specific programming. To add insult to injury, as sanctioned by the NAB, translators can cover larger broadcast areas than LPFM stations and can be placed on the FM band where LPFM stations are not allowed. The below is a crude depiction: Figure 2: Stipulation A:  Current LPFM separations     FM    3    2    1    LPFM    1    2    3    FM 95.1    95.3    95.5    95.7    95.9    96.1    96.3    96.5    96.7   ^                    ^                  ^ Established local        An LPFM            Established local commercial            could fit            commercial station on 95.1            here                station on 96.7 Stipulation B: Current Translator at Minimum Channel Separation FM    1    FX    1    FM 95.1    95.3    95.5    95.7    95.9   ^          ^          ^ Established    A translator    Established commercial    could fit    commercial station on 95.1    here        station on 95.9 Translators are allowed to be placed where LPFM's cannot be placed.  Huh, what?  How does this work?  Yes, the FCC is allowing entities such as religious radio networks to own dozens to hundreds of translators licensed with stipulation "B", but makes locally based broadcasters using LPFM licenses follow stipulation "A".  LPFM and translators use the same type of transmitters at almost the same wattages; they are physically the same. Regulation-wise, however, they are treated completely different.   The FCC allows placement of LPFM stations solely based upon a non-technical physical spacing requirement.  This means, the Commission originally wanted to simplify the method of placing new LPFMs by basing it upon transmitter spacing, regardless of antenna pattern or signal strength.  The problem with this licensing scheme is that it doesn't use the FM band efficiently2. Translators use a contour/signal strength-based methodology3, which more precisely uses real-world engineering models for placement.  The discontinuity between the two methodologies prevents LPFM and translator services from being technically compared to each other, allowing a "fog" for NAB to use to argue against LPFM-yet be pro-translator.  If interference concerns were really an issue, all NAB would have to say is "LPFM should use translator licensing requirements" and be done with it.  But NAB dislikes LPFM because it is, in fact, competition. The Current Problem LPFM is still in limbo.  Not only that, but stations lucky enough to already be on the air are being encroached upon due to their secondary status, and relaxed FCC rules for moving full power stations. Here are the main hurdles we are dealing with: 1.NAB went over the FCC's head and made Congress enact the third adjacent rule (Figure 1B).  This prohibits the FCC from using the less stringent, but engineering approved second adjacent rule (Figure 1C).  However, even a second adjacent rule would not allow LPFM's to be licensed in many cities.  The FCC should allow LPFM stations to be placed using translator rules (Figure 2B). 2.Thousands of translator applications are still pending approval from the 2003 translator application window by a handful of applicants who want to use these frequencies for primarily automated, out-of-town repeater networks or for selling to others.  Is a select few owning dozens to hundreds of these frequencies fair use of the public airwaves?  Does this improve local radio?  The FCC should dismiss most of these speculator applications. 3.With most of the approved translator applications in the hands of religious broadcast networks, and the pending ones tied up with mainly speculators and future-planned broadcast networks, there is no room for new LPFM channels in many cities.  In these cases, the FCC should deem certain translator frequencies already in use4 newly available for local LPFM applicants. 4.It is important that LPFM stations already on the air be given primary service status in order to maintain their public service license.  Currently, when a large commercial station wants to move their facilities to a more profitable location, they are allowed to legally bump an LPFM off the air.  For those LPFM broadcasters who spent a lot of time and money developing a radio station to serve the local community, this "encroachment" contradicts the purpose of regulating the public airwaves in the first place.  The FCC should develop a solution that appeals to both services. The above is merely a non-technical overview of the situation at hand.  More detailed concerns regarding the LPFM rulemaking can be viewed here: http://recnet.com/fcc/99-25_2nprm_questions.pdf Asking Help By April 9, 2008 The FCC is asking for comments regarding regulations for LPFM.  You can read their Third Report and Order and Second Further Notice of Proposed Rulemaking here (http://fjallfoss.fcc.gov/edocs_public/attachmatch/FCC-07-204A1.doc).  The FCC asks the public what they think when they propose new rules.  Big Media is filing to limit LPFM and keep translator ownership as it is.  It is important you file comments to show that there are individuals and organizations that would like LPFM available in their own city.  The point needs to be made that the Commission ought to make new regulations to make LPFM available in larger metro areas.  A proliferation of LPFM is justified because current commercial and non-commercial radio services do not satisfy many local communities.  If you live in a community that isn't being served by radio to the fullest extent, the Commission wants to know5. File your comments here (http://fjallfoss.fcc.gov/prod/ecfs/upload_v2.cgi).  You can type something up in MS Word, make a PDF, or just type in comments directly on the FCC site itself.  In the "proceeding" blank type 99-25; the rest is self-explanatory. * * EASTER WEEKEND  2008 ** **  2003 hmm March 17, 2008 ** IowaFM  marks the 5th anniversary of the "St. Patty's Day Massacre" On this date 5 years ago, the FCC issued a public notice which effectively puts a nail in the coffin for hundreds of LPFM applications. These were the applications that were impacted by the Radio Broadcast Preservation Act enacted by Congress which mandated third-adjacent channel protection by LPFM stations to full-power and translator stations. While some applicants were able to move to other channels, many applicants were "deadlocked" and could not change frequencies or locations to remain compliant with the Act. A Petition for Reconsideration lead by REC and supported by others was denied by the Commission. Five-years later after the FCC through the Congress-mandated MITRE Report and the experimental Comsearch stations, proved that LPFM stations operating on third adjacent channels did not cause severe interference, various groups including REC, Prometheus and other LPFM and media advocacy groups are trying to get Congress to lift these restrictions. The broadcast industry lead by the National Association of Broadcasters disputes the findings in the MITRE report claiming that the report does show that some interference is caused and that MITRE did not do the second part of testing, which called for the economic impacts of LPFM stations operating on third adjacent channels. Versions of the bill (S-1675 for the Senate & HR-2802 for the House) have been introduced to lift these restrictions. IowaFM, Common Frequency, Radio For People,  Community Public Radio, REC, and the Prometheus Radio Project all support LPFM and continues to ask you to please all contact your legislators to support these two bills for the future art of thoughtful community speech.