Statement of REC Networks in regards to LPFM.AG's Petition for Rulemaking filing.
Dave Solomon's Low Power FM Advocacy Group (LPFM.AG) has filed their Petition for Rulemaking with the FCC. If the FCC decides to assign a rulemaking number and move it forward for comments, it may take a month based on how long it took to move REC's LP-250 petition that became RM-11749.
LPFM.AG's petition comes from a very important aspect of the LPFM service, the "microbroadcast" segment, the segment of LPFM stations that are primarily started by organizations created solely for the purpose of running LPFM stations unlike other LPFM stations that are operated under the auspices of a well established "brick and mortar" organization such as a church, ministry, educational institution, government agency or service organization.
Unlike the other segments, the microbroadcast segment does not have the same funding sources and backing that other LPFM organizations may have. It is very understandable why some of these licensees would desire the ability to provide supporters with the ability to get a message out without having to be in the confines of Section 399b of the Communications Act that codifies the restrictions for non-commercial educational (NCE) stations that LPFM falls under.
REC continues to oppose LPFM being in a situation where commercial and non-commercial interests would compete for spectrum due to regulations and statutes that require auctions to settle mutual exclusitivities and puts community ownership at risk. REC is also concerned about the economic impacts of minority-owned and family-owned full-power stations, especially in rural areas.
In our initial evaluations of the LPFM.AG proposal, there are some aspects of the petition that do warrant consideration. When reviewing these proposals, we must first take into consideration any aspect of the rules that was established by statute (such as the Communications Act, the Local Community Radio Act, the Balanced Budget Act, etc.) as these aspects of our operating environment can not be changed without an act of Congress. We must also review whether the proposals are technically sound and how the proposals harmonize with the other broadcast services.
As demonstrated over the past few months on social media, the LPFM.AG petition has struck some chords both within the LPFM community as well as the full-power community especially over the ability for LPFM stations to air commercials. REC hopes that we can have a civil discussion on the issues now that they are in the open. We need to be open to all ideas and allow them to have their due process.
Until the LPFM.AG petition is given a rulemaking number at the FCC, comments can not be filed on this petition. Once it is assigned an RM number, there will be a 30-day comment period.
For now, read the petition and form your own opinion and be ready to comment. Whether you support all of it, some of it or none of it, your opinion will matter.
Michelle Bradley
Founder: REC Networks
Related links:
Low Power FM Advocacy Group (LPFM.AG) Petition for Rulemaking (pending FCC processing)
