03-185: Comments filed in this proceeding.

Updated 7/20/2022 08:00 ET

This is a working document that provides a brief outline of what organizations are saying in their comments on MB Docket 03-185.  This document is used internally by REC to compile information for the consideration of Reply Comments and we will share this document with the public.

This document is active and will be periodically updated as new comments come in.

AlmaVision Hispanic Network, Inc. (AlmaVision) - Licensee of WEYS-LD (FM6 Ch. 6 LPTV). Never received one report of interference from FM6 operation. Ancillary or supplemental should comply with the Communications Act. FM6 should be allowed to make technical modifications. 5% fee should not apply to commercial advertisements. Aligns with PCPC on Part 73 position.

America's Public Television Stations et al (Public Media) - TV spectrum should not be repurposed. Could hinder the the deployment of ATSC3. FM6 should be ancillary or supplementary and have a public inspection file.

Cocola Broadcasting Cos., LLC (Cocola) - Licensee of KGMC (Full-service TV) and KMCF-LD (non FM6, Ch. 6 LPTV). Filed STA to commence FM6 in 2022 and was denied. FM6 should be allowed to expand and limiting to the 13 existing stations is arbitrary and capricious. The recent NCE window shows that there is demand for NCE spectrum and they welcome the fact that the FCC is seriously considering repurposing vacant Channel 6 spectrum for analog (FM) services. Such expansion should be limited to noncommercial. FM6 should be allowed to ramp up and where spectrum is still available, should be available for NCE-FM use.

Common Frequency, Inc. (CFI) - FCC has lost most of its "public interest" stipulations from direct lobbying by the broadcast industry. The proposed regulation is a "franken regulation". Questions the uniqueness of FM6 programming citing KBKF-LD running EMF programming, stations running Christian formats that are widely available, ME-TV FM, and stations running classic hits formats.  Also noted that the Boston (which is not on the list of 13) and Las Vegas has recently offered LMAs for sale in trade publications. The premium leasing of FM6 facilities are usually networks or used for programming similar to what is alrady avaialble on AM and FM.  There is clearly a dearth of locally-run stations that run the gamut of underrepresented programming: independent and local music, local news, ethnic community affairs, alternative public radio formats, etc; content that barely exists on FM radio.  Since these are leased time services, there is no expected permanence to their existence.  FM6 licensees normally do not produce their own programming.  Analog FM broadcasting is not an advanced television service. 87.7 and 87.9 should be reserved for NCE. The rest of Channels 5 and 6 should be reserved for NCE and "AM service exchange" (turn in the AM and cross service translator licenses).  ERPs should be limited to 250 watts (unlimited HAAT) in the top 100 markets and use second adjacent channel waivers. LPTV licensees should be able to convert their LPTV license to a 87.7 grandfathered FM station.  Supports elimination of FM to TV6 requirements.

George S. Flinn, Jr. (Flinn) - Licensee of WPGF-LD (non FM6, Ch. 6 LPTV). Supports permanent use of FM6 for stations with a significant history of providing FM6 to the public. FM6 is spectrally effiicent. No legal barriers to making FM6 ancillary or supplementary.  Considers attempts to repurpose Ch. 6 as "draconian". 

Hank Bovis (Bovis) - Long time radio listener. Receives a good video signal from WDCN-LD. FM6 should be able to continue and STAs should not be required. Should be allowed to use 87.7 (as opposed to 87.75) as the analog carrier frequency. "E-Skip" and other interference implications have not been considered when considering expansion of FM into 82~88.  FM to TV6 should be held over until the FCC makes a decision on the REC and NPR concepts of expansion of FM.

(More comments will be added later)

Intercollegate Broadcasting System (IBS) - Supports extension of FM band to include Channels 198~200 (87.5, 87.7 and 87.9). FM6 STAs should not be extended. ATSC3 has not been widely embraced by consumers yet. Supports elimination of FM to TV6.

Jay Nelson Rogers (Rogers) - Supports the conversion of 76~88 to FM sound with a bandplan that calls for license free 1 watt operation on 76.1~76.9, LP-10 on 77.1~77.9, LP-100 on 78.9~78.9, Class A FM on 79.1~83.9 and all FM classes on 84.1~87.9.  

Juan Carlos Matos Barreto (Barreto) - Licensee of W06DA-D (non FM6, Ch 6 LPTV). Supports FM6. FM6 should be expanded to other licensees. FM6 should be considered ancillary or supplementary.

Kids Television, LLC (Kids) - Licensee of WJMF-LD (non FM6, Ch 6 LPTV). Supports expansion of FM6 markets. FM6 should be ancillary or supplementary. Supports efforts to allow FM6 and NCE to coexist. FM6 should be transferrable.

KORE Broadcasting, LLC (KORE) - Licensee of KORE(AM). Supports FM6. They should be treated as Class A (FM) licensees. FM6 not causing interference to NCE.

Luna Foods, Inc. (Luna) - Licensee of K06PU-D & K06QD-D (both non-FM6 LPTV). FCC should amend rules to allow newcomers to serve the needs for underserved minorities citing that broadcast companies (in their area) care little about the Spanish speaking community. It would be wasteful to set aside 82 to 88 MHz for FM use as radios don't tune down there.

Marquee Broadcasting, Inc. (Marquee) - FM6 is a worthy use of spectrum and should not be subject to onerous regulation. The question of wether to expand NCE into Ch. 6 boils down to whether a TV broadcaster's FM station is any better than a non-profit's use of the channel. FCC should embrace the use of more than one technology in the channel. A digital TV signal should be broadcast before an FM signal is allowed.  Questions whether assignments/transfers would do any harm. Supports opening up of channel 6 hybrid technology.

National Public Radio (NPR) - Does not oppose 14 FM6 stations (they are also including WVOA-LD, Westdale, NY). Part 73 rules should apply to FM6 stations. FM to TV6 interference obligations are outdated and should be removed. 87.9 should be opened for NCE stations. 

QXZ Media Works LLC (QXZ) - Supports all-digital in Ch. 6 spectrum.  Calls FM6 "inefficent". Grandfathering FM6 would preclude new all-digital FM stations from the major markets.  FCC should call for mandate for WIDE-FM capability in FM receivers.

TZ Sawyer Technical Consultants (Sawyer) - Supports continued FM6 operation. Questions why only the 13 stations. Questions community of license requirements. Questions whether preventing technical changes would be necessary. 

WPVI Television (Philadelphia), LLC (WPVI) - There is no evidence that full-power TV stations will not be subject to interference if FM to TV6 protections are eliminated or reduced. Without digital receiver studies, it would be premature to conclude that eliminating existing Channel 6 protections would not subject full-power digital Channel 6 TV stations to the precise types of interference the current rules are designed to protect against. Some in the broadcast industry claim that if 73.525 and 73.825 were lifted, there would be a "flood of requests" from FM stations.