In Reply Comments before the Federal Communications Commission, REC Networks called-out the National Association of Broadcasters and their ongoing excuses and fear mongering over the past 20 years in their war on new voices in radio comparing the conflict to something out of Tom and Jerry cartoon.  REC demonstrates how the NAB had used deception back in 2000 to fool Congress, who are not necessarily broadcast engineers of what third-adjacent channel interference would “sound” like and how the NAB’s 2012 conc

"I do find it very disappointing that there is not one person on this committee who is representing the 2,186 licensed LPFM broadcast stations, many of which provide very diverse and in many cases, localized content on the fronts of ethnicity, gender, LGBT and religion. In addition, there is no representation of independent LPFM and community based full-service noncommercial educational (NCE) broadcasters at the upcoming symposium on the broadcast industry.

Across the country, community-focused secular and faith-based LPFM stations as well as smaller full-service NCE stations are providing unique and localized content not available elsewhere on the dial or even in the larger media landscape.  Its time for these thousands of broadcast licensees to be taken seriously and properly represented at the Commission as members of the media landscape."

The following is a summary of timely-filed comments in MB Docket 19-193 as interpreted by REC, and can be used as a basis for filing Reply Comments which are due on November 4.  Additional annotations by REC provided where appopriate.  Annotations reflecting REC positions shown in italics.

In response to the FCC Notice of Proposed Rulemaking in MB Docket 19-193, REC Networks, the author of most of the items in the proceeding has filed comments with the FCC to support the various items the Commission has agreed to move forward and has also petitioned to have several items that were tentatively rejected brought back into discussion.

REC Networks is aware of the situation that has been taking place at Pacifica Foundation station WBAI, New York including the litigation and has heard from both sides of this issue.

With the exception of the output of the WBAI FM transmitter, REC takes no position in the dispute of the issues that are within the jurisdiction of the State of New York.