"Growing pains" associated with the Federal Communications Commission recent conversion of FM engineering applications such as modifications and licenses is causing substantial delays in the processing of broadcast applications.  

The FCC has released a draft Report and Order (R&O) in MB Docket 19-3, the Noncommercial Educational (NCE) and Low Power FM (LPFM) administrative proposal.  The R&O will be voted on at the prior to the December 12, 2019 FCC open meeting.  Rules will not be implemented until they are published in the Federal Register.  The following is a run-down of the changes in the draft R&O:

REC Networks has filed comments with the FCC in MB Docket 17-264.

The Communications Act requires broadcast applicants (existing and new entrants) to make public notice of certain types of broadcast applications at the time they are accepted for filing at the FCC.  Currently, those notices are made through purchasing ads in newspapers.  In an effort to modernize the rules and to reflect the current state of media, the FCC has proposed to eliminate the newspaper requirement and replace with an online announcement.   The FCC also proposes changes to the public notice announcements heard over the air and officially implements public notices for LPFM.  The LPFM implementation was an oversight from 19 years ago.

In Reply Comments before the Federal Communications Commission, REC Networks called-out the National Association of Broadcasters and their ongoing excuses and fear mongering over the past 20 years in their war on new voices in radio comparing the conflict to something out of Tom and Jerry cartoon.  REC demonstrates how the NAB had used deception back in 2000 to fool Congress, who are not necessarily broadcast engineers of what third-adjacent channel interference would “sound” like and how the NAB’s 2012 concerns

"I do find it very disappointing that there is not one person on this committee who is representing the 2,186 licensed LPFM broadcast stations, many of which provide very diverse and in many cases, localized content on the fronts of ethnicity, gender, LGBT and religion. In addition, there is no representation of independent LPFM and community based full-service noncommercial educational (NCE) broadcasters at the upcoming symposium on the broadcast industry.

Across the country, community-focused secular and faith-based LPFM stations as well as smaller full-service NCE stations are providing unique and localized content not available elsewhere on the dial or even in the larger media landscape.  Its time for these thousands of broadcast licensees to be taken seriously and properly represented at the Commission as members of the media landscape."

The following is a summary of timely-filed comments in MB Docket 19-193 as interpreted by REC, and can be used as a basis for filing Reply Comments which are due on November 4.  Additional annotations by REC provided where appopriate.  Annotations reflecting REC positions shown in italics.