With the recent filing window coming up for new non-commercial educational (NCE) stations, some LPFM operators may think that this is their "security blanket" to a primary service. Before LPFM operators get their hopes up on this primary service nirvana, LPFMers should be aware of the additional responsibilities that come with the territory.
As we have learned with previous opportunities to file for NCE-FM stations, the number of situations where applications can be mutually exclusive are very high, especially in more suburban and urban areas. Some MX applications have gone for over 10 years before either a settlement agreement or comparative review. There is no "if there's 3 equally qualified applicants, we will split the license" rule with NCE-FM.
From an engineering standpoint, many more rules apply to you. Even for a simple 100 watt station. Since NCE-FM is done through a prohibited overlap model and not distance spacing like LPFM, you better be ready to hire a consulting engineer or someone to help you out with the frequency, location and antenna search. In many areas, you will not be able to do anything without a directional antenna.
From an administrative standpoint, you better be ready to follow all of the rules, not just the ones picked-and-chosen for LPFM. This includes the main studio rule and the requirements to maintain a public file and a management presence at the main studio. What a couple of our LPFM stations that I know of doing (e.g. going on vacation for a week and letting the station run itself) will not cut it here.
But for those with the budget to afford a consulting engineer and attorneys and are willing to jump through the firery hoops of the FCC, then the advantage to being a full power NCE-FM station is:
- Potential additional reach,
- Primary status,
- The ability to own your own translators and
- The ability to own multiple stations.
If you are ready to make this big jump, then go ahead and file for an NCE-FM. Remember, you will need to divest yourself of your LPFM station prior to the grand of your CP. Therefore, you may be off the air during your transition.
Good luck to those LPFMs who decide to make the jump and for those who don't, we understand and we still support your decision.
Michelle Eyre
for REC Networks
