Preliminary Statement of REC Networks on FCC's LPFM Decision

As with many in the LPFM community, we are pleased with many aspects of the FCC's decision on LPFM from last week's Commission meeting. We will comment further when the official Report and Order (R&O) comes out. We also plan to participate in the Further Notice of Proposed Rulemaking.

This R&O does bring some new opportunities for new reports and database applications.

We are particularly interested to see how the FCC is going to defend the comments made at the meeting that certain types of automated programming does not count towards an LPFM station's 8 hours a day in order to stand-up to potential encroachment by a city of license change. We want to assure that the LPFM will not be bogged down with extensive paperwork and logs to defend this and we want to assure there are no First Amendment issues here.

We are pleased that the FCC hastily took action and addressed the Great Translator Invasion filing window of 2003. What the FCC does not realize is that in many areas the damage has already been done due to singleton applications that have already been granted and in some cases, sold/assigned to other entities. REC feels that the "10-application" policy should be retroactive to the opening of the window and that new and existing LPFM stations should have priority over any GTI translator facilities that were filed at the window over the 10 limit. We will also demand that Radio Assist Ministries and Edgewater Broadcasting be considered a single entity under the 10 application limit.

REC continues to fight for various changes that are needed to the LPFM rules including:
- Additional tiers of translator classes to make protection more granular.
- Complete change to how reserved band LPFM stations protect Channel 6 TV and Low Power stations.
- Placing LP-10 on the same spectrum priority level as LP-100.
- Elimination of IF protection requirements.
- Address the "distant translator" issue.

For now, we can only wait for the R&O.