FAQ: What technical changes were actually proposed in 19-193? (updated 7/14/19)
As of July 14, 2019:
In advance of the FCC's August 1, 2019 open meeting, a draft Notice of Proposed Rulemaking has been released (this is a great policy that has been in place since Ajit Pai has been Chairman). In this draft NPRM, various items have been proposed including the following:
Extending the distance of minor moves
REC proposed that LPFM be allowed to harmonize with FM translator rules to permit a minor move where the 60 dBu contour of the current facility and the proposed facility overlap. In the FCC's proposed version of the rule, moves of 5.6 km or less would not require a contour study (as is the case today) but moves over 5.6 would be permitted with the use of a contour study to show overlap between the old and new locations. Frequency changes would still be limited to +/- 1, 2, 3, 53 and 54 channels or upon a showing of reduced inteference to any channel.
Currently, LPFM stations are permitted to operate directional antennas if the station is operated by a public safety agency or the station is using the directionality of the antenna to request a second adjacent channel waiver. In the NPRM, the directional antenna rule could also be used in accordance with an international agreement. The primary benefactor of this rule change will be LPFM stations in the 125 km "strip zone" along the Mexican border that have been limited to 50 watts. Under the proposed rule, they would be able to operate at maximum power in all directions except those directions that are within 125 km along any point on the US/Mexico border. While REC proposed a more substantial use of directional antennas (such as to protect translators and other LPFM stations), REC also addressed the need for relief on the strip zone. Directional antennas can also be used towards Canada though the restrictions are not as strict as they are towards Mexico.
The new directional antenna removes an unnecessary restriction on the use of "composite" antenna patterns as opposed to "off the shelf" or "standard" patterns, which is currently what is codified.
We note that while the proposed codified rules limit the expansion of the scope of the use of directional antennas for international use, the text of the NPRM opens possible doors for LPFM stations to use directional antennas for other purposes. REC's position is that LPFM stations should be able to ask for waivers of the §73.807 rules in respect to minimum distance separtation between LPFM stations with FM translators and other LPFM stations using a contour overlap model if they so choose to. Unlike any waiver of reduction of distance separation to full-service stations, LPFM using distance seperation towards FM translators and other LPFM stations is not mandated under the Local Community Radio Act. REC urges all LPFM proponents to request that the FCC expand the scope of the use of directional antennas to seek such waivers with conditions of no interference in a manner similar to the FM translator rule §74.1203(a) as suggested by Prometheus Radio Project. This specific waiver type will be the primary focus of REC's ex parte strategy as such a study can be done in manner similar to the proposed 5.6 km expansion and interim TV channel 6 waiver proecess mentioned below.
TV Channel 6 protections
What is probably the biggest (and most controversial) change on the proposal is the declaration of the elimination of protection requirements between FM broadcast stations on Channels 201~220 (88.1~91.9) and TV stations on Channel 6 (low power and full power). Under the FCC's proposal, the Channel 6 protection rules that apply to full-service FM radio, FM translators and LPFM would sunset on July 13, 2021, the sunset date for analog low power television. In an interim process prior to the sunset, LPFM stations seeking channels in the Channel 201~220 reserved band can seek a waiver of the rules using a contour study similar to that used for FM translators. REC only asked that LPFM stations be allowed to use the contour overlap study, the FCC came back and proposed to eliminate Channel 6 protections across the board.
Codifies the use of FM boosters for LPFM stations without the need for a waiver. A booster would count as a "translator" in respect to the two translator limit.
Other non-substantive changes proposed include modifying the language of a third-adjacent protection rule to be consistent with the recently changed rule for FM translators (replacing an itemized list of protected radio services with a blanket statement).
This FAQ is fluid and is subject to change based on the rulemaking process.