REC to FCC: LPFM should be considered an "FM broadcast station"
With the passage of the Consolidated Appropriations Act, Congress is allowing "FM broadcast stations" and FM translators access to reimbursement for certain expenses accured as a result of the repacking of television stations. In MB Docket 18-214, the Commission reached a tentative conclusion that LPFM stations were considered as "FM broadcast stations" for the purpose of enacted law and therefore should be permitted to seek reimbursement as appropriate.
In comments, REC stated that while it was not specifically aware of any LPFM stations that have been asked to move from the their current tower site to make room for another station impacted by the repack, we must continue to leave the door open. REC stated that the statutory language in this law is distinctively different than the wording in the Local Community Radio Act of 2010 where discrete terms "full-service FM stations" and "low-power FM stations" were used.
In the brief two-page filing, REC Networks did agree with the FCC on their interpretation the law. The only other organization filing on the LPFM inquiry was the National Association of Broadcasters which also agreed with the Commission's definition thus also supporting that qualifying LPFM stations should be eligible for reimbursement for specific expenses related to the repack.
REC also stated that Class D secondary stations that are impacted by the repack should also be eligible for reimbursement.
LPFM stations forced to change tower locations as a direct result of a TV station needing the tower space or an FM station needing to move to the LPFM tower space as a result of a TV station needing to relocate should contact their attorney or REC Networks for assistance.
Reply comments are due on October 26, 2018.