REC files comments on LPFM Third-adjacent channel protection

Supports elimination of third adjacent and limited second adjacent requirements

REC has filed comments with the FCC on the 700+ page report by the MITRE Corporation in respect to third-adjacent channel protection in respect to Low Power FM (LPFM) broadcast stations.

This report was ordered by Congress as a part of the passage of the Radio Broadcast Protection Act, the legislation that imposed third adjacent channel restrictions on LPFM stations.

In our comments, we supported the elimination of third adjacent channel restrictions to domestic FM full power and translator stations.

We have addressed several of the issues brought up in the MITRE report.

Reading Services for the Visually Impaired: REC notes that most RSVI services operate in the reserved band (88-92 MHz) and that a majority of LPFM stations are in the non-reserved band (92-108 MHz) and that interference will be minimal to non-existant.

REC feels that existing rules that specifically address third adjacent channel interference from LPFM stations to full power broadcast stations (rules that were put in when LPFM stations could be on third adjacent channels) can address situations where interference is caused to a full power station's on a third adjacent channel when the LPFM is right on the fringe of their service contour and that no rule change is necessary to address this specific issue.

In addition, REC feels that existing rules regarding interference resolution to the input frequencies of translators can also address the issues raised in the MITRE report and that a rule change is not necessary.

REC opposes any new rules that specify a specific transmitter type for LPFM stations. REC is opposed to the exisitng rules requiring Part 73 Certified equipment (where the rest of the broadcasting world only needs Part 73 Verified equipment).

In addition, REC has raised the issue of second adjacent channel protection of translators by LPFM stations. REC feels that it is unecessary in light of translators not being required to protect LPFM station's second adjacent channels.

REC has filed a copy of the maps that are found on our MITRE page (http://www.recnet.com/mitre) as well as a list of the Top-5000 communities that currently have LPFM availability or will have it as a result of the elimination of third adjacent channel, REC's proposed elimination of second adjacent for translators as well as REC's proposed reclassification of translator protection levels.

A copy of our filing can be found at http://www.recnet.com/fcc.