18-119: Statement of REC Networks on LPFM/C Petition for Reconsideration
In the Petition for Reconsideration filed by The LPFM Coalition (LPFM/C) in MB Docket 18-119, the translator interference proceeding, LPFM/C raises some very excellent points in respect to the decisions made by the Commission in the proceeding.
While FM translators must protect existing LPFM stations using prohibited overlap, it is REC's position that the disparity between LPFM's use of distance separation and FM translator use of the contour model does raise an LCRA Section 5 issue where translators are overprotected by LPFM stations by as much as 10 times the area that they are entitled to in cases where a translator's directional pattern can be used to protect an LPFM but LPFM stations must protect a translator as they are a non-directional facility.
