REC Position: LPFM operation at ERP greater than 250 watts
With the recent news that the FCC will be cracking the door open slightly on the possibility of the use of Channel 6 spectrum (82~88 MHz) for use by FM broadcasting, there has been a lot of buzz on social media and the discussion boards related to LPFM. We have heard comments from people wanting dedicated channels for LPFM stations as well as increased power for LPFM stations, such as 500 or 1,000 watts for stations in this spectrum.
On the issue of dedicated LPFM channels, REC agrees that this is something that can be workable. REC is working on a comprehensive plan for an expanded FM radio service in the Channel 6, as well as the Channel 5 (76~82 MHz) spectrum. In areas where Channel 6 would be available, we are considering a plan that would allow for full-service (high power) operation on 20 of the 30 channels within a TV channel. In markets with a current FM6 operation, 87.7 would be set aside for a new commercial allotment. This will leave 7 to 10 potential channels for secondary operations, including LPFM. In areas where Channel 6 is not available but Channel 5 is, the band plan would be shifted to allow for 20 full-service and 10 secondary low power channels. In areas where both channels are available, Channel 6 will get the full-service stations as we just described and the Channel 5 spectrum would be available for secondary low-power operations. Our proposed band plan puts the full-service in the middle of the TV channel and low power operations on the edges as to provide a guard band to an adjacent TV channel (in areas where protection to a full-power Channel 5 or 6 stations is necessary) or in the case of Channel 5 spectrum, to adjacent fixed service and other non broadcast operations, including the marker beacons at 75 MHz.
On the issue of increased power over 250 watts. REC is unable to support these higher powers for a secondary service. When the original LP-1000 service was proposed in the late 90s, it was proposed by Rodger Skinner, who envisioned that the 1,000 watt LPFM stations would be like a "Class A Lite" FM service class with lower power, fewer restrictions, primary service and commercials. LP-1000 was eventually opposed by those in the grassroots and community radio circles because a single LP-1000 station could foreclose on multiple LP-100 opportunities. The FCC also considered LP-1000 as not meeting the more hyperlocal nature of the reason why the FCC is creating this service. So they kept the service at 100 watts, noncommercial and secondary. The secondary service aspect of LPFM was further sealed in 2011 with the enactment of the Local Community Radio Act.
We must also look at an RF safety issue. When the FCC designed the current "simple" guidelines for LP-100, they included a worksheet that shows that for the antenna to meet the RF exposure guidelines established by the EPA, a station with 100 watt vertical antenna must be at least 20 feet (6 meters) from any occupied area. With LP-250, that same 250 watt vertical antenna would require 27.6 feet (8.4 meters). At 1,000 watts, that distance would need to be 48.2 feet (14.7 meters). When the FCC envisioned LPFM back in 2000, they figured that stations would run from rooftops with simple vertical antennas. Second adjacent channel waivers did not come until the LCRA. Now, in all fairness, depending on the antenna that is operated, it may be possible to bring 1,000 watts closer to occupation. For example, an EPA-2 type antnena (such as a NIcom BKG-77), 2 bays, full-wave spaced, is able to come within 33.1 feet (10.1 meters) of occupied area. Again, where it comes to the higher powers, it requires someone with more experience to install and manage those kind of operations. While some LPFM operators are experienced broadcasters, many area not, especially when you look outside of the minority of the "community radio" type LPFM stations.
Also, it is REC's ambition to bring LPFM stations as close to an equal footing with non-fill in FM translators while remaining within the confines of the LCRA. REC's Simple 250 plan is somewhat comparable to the current rules that permit non-fill in FM translators east of the Mississippi River or in California south of 40 latitude to operate 250 watts at 32 meters. Translators have the advantage because they can go to 32 meters where REC proposed 30 meters in order to be consistent with the FCC's prior LP250 proposal. LPFMs have the advantage because we did not promote a "maximum HAAT" rule that non-fill in translators have to follow. In the non-fill in translator world, HAAT is measured in 12 directions and if the HAAT along one of those 12 radials exceeds 32 meters, then either a directional antenna is needed to limit radiation along that radial or if a non-directional antenna is used, the highest of the 12 HAAT measurements will determine the maximum ERP. In contrast, LPFM uses the average of 8 radials, which is more consistent with full-power FM rules.
While we do not support ERPs above 250 watts for secondary LPFM stations, we do support a third LPFM class that would permit LPFM stations up to 250 watts at 107 meters HAAT in the expanded FM band. Where the Simple 250 (100w @ 30m HAAT) has a 7.1 km service contour, this "LP250 PLUS" would have a service contour of up to 13.3 km. We envision LP250 PLUS being available only in the extended FM spectrum and only available in areas west of the Mississippi River except California south of 40 degrees latitude, similar to non-fill in FM translators in the same area.
It is also important to remember that if the FCC does approve the use of Channel 6 (and hopefully also Channel 5) for FM use, there will be more spectrum available for primary higher power operations, where you can run 1,000 watts if you want. It is REC's position that if Channel 6 (and Channel 5) are enacted, that at least the first two filing windows for new full-service stations be limited to established local non-profit organizations. This will assure a level of diversity in the spectrum and not the same networks you hear everywhere else.
So yes, it is about safety, keeping LPFM local and not raising the bar on secondary services. Think about it. If the FCC was to give LPFM 1,000 watts as secondary service, the FM translators will demand the same. That will forclose opportunities in the legacy FM band (88~108 MHz). For now, let's keep it no more than a 13.3 km service contour and no more than 250 watts.
We are working on a full plan for the use of the expanded spectrum and will release that at a later time.