AM Revitalization: REC supports preservation of nighttime AM radio service, reasonable flexibility for translators, long term migration and X-band expansion

REC Networks has filed comments in the Further Notice of Proposed Rulemaking in MB Docket 13-249, the AM Revitalization docket.  

In our comments, we stated our objections to the Commission's proposal to eliminate nighttime "sky wave" protections for clear-channel Class A AM stations stating that the nighttime service is a national resource but at the same time, called on Class A station owners to better program their stations to attract a nighttime audience.  Despite the many options for listeners, nighttime AM radio remains the only service available free of charge that does not require constant re-tuning and can reach into areas where there is insufficent AM and FM services.  

Part 15: Let's talk about spectrum

I am reading several threads on the thought of expanding Part 15 or very low power broadcasting either as a service authorized by rule (unlicensed) or authorized by license.  I have seen several ideas come up as far as spectrum is concerned. I have seen mentions of longwave, 510 kHz, 520 kHz, 1710 kHz, 1710 to 1780 kHz and shortwave. 

First of all, let’s quickly talk about how spectrum is allocated. 

REC Statement: Univision complaint against Iglesia Alfa y Omega/KYEB-LP

REC supports Univision's complaint against KYEB-LP.  If the allegations made in the complaint are true, this is a serious violation of the FCC Rules, puts the integrity of LPFM at risk and strains the relationship between LPFM and the full-service broadcast industry.

The alleged actions of KYEB-LP are not representative of the LPFM service as a whole.

While Univision alludes to the REC Informal Objection against 246 Cesar Guel-assisted applications, we wish to point out that Iglesia Alfa y Omega was not included in that objection because the original application for Iglesia Alfa y Omega was not handled through Antonio Cesar Guel and/or Hispanic Christian Community Network but rather by another consultant.  Guel/HCCN was involved in a subsequent minor modification.  

FCC dismisses more Cesar Guel LPFM applications

So far as of this writing, the FCC has dismissed applications that were filed by Antonio Cesar Guel for new LPFM stations in San Antonio, Jacksonville, Lufkin TX, Columbia SC, Lake Charles LA and McAllen TX.

These dismissals were as a result of the Commission investigating the addresses that these applicants claimed as their headquarters.  In these cases, the Commission used public records to determine the property owners (which were mainly churches) and these property owners verified that these organizations were never headquarted at these locations.  As a result, the Commission determined that the applicant did not meet the requirements of §73.853(b)(1).  Since the same addresses were used for the board members, these addresses were dismissed for the purpose of establishing 75% of the organization's board members are local in accordance with §73.853(b)(2).  Since the localism requirements were not met, the applicant is not qualified to be an LPFM licensee and thus, the application was dimissed.

Today's decisions did bring two issues to light:

REC is filing another round of informal objections against Cesar Guel

What started at 246 applications that were filed by Antonio Cesar Guel during the 2013 LPFM filing window has now dwindled down to 85.  Many applications were dismissed at the request of Guel or due to FCC action.  Applications in North Carlolina and Texas were dismissed as a result of investigations and supplemental filings by REC.  

Through investigations, REC has cleared 19 applicants that were determined to be existing organizations and as a result, these applicants have received grants. 

In the latest wave of objections, REC is investigating the so-called "HEFF" applications.  These are the applications with a city name and then a common name such as "_____ Community Radio", "_______ Hispanic Church", "_____ Hispanic Educational Family Fundation" (or HEFF), etc.  

REC reminds FM translator applicants and LPFM permittees on protections towards unbuilt LPFM stations

REC puts out this reminder to engineers and other parties who are involved with the modification of FM translators to assure that the "note" to §74.1204(a)(4).  The note reads:

LP100 stations, to the purposes of determining overlap pursuant to this paragraph, LPFM applications and permits that have not yet been licensed must be considered as operating with the maximum permitted facilities. All LPFM TIS stations must be protected on the basis of a nondirectional antenna.

While §74.1204 does not define a "maximum permitted facility", the same language is used in §73.215(a) (4)  to refer to the maximum facilities for full power FM stations in Puerto Rico and the Virgin Islands which then refers to §73.211(b)(3) which defines the maximum ERP and HAAT for stations in Puerto Rico and the Virgin Islands.  

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