Reply comments in the FCC’s ongoing rulemaking to expand the LPFM service are due on September 27. REC Networks‘ Michi Eyre has written an excellent (and wonky!) summary of comments filed in the proceeding to date by those who have focused on the elephant in the room – the troubled relationship between LPFM and FM translator stations.

Over the last twenty years, the use of FM translators has evolved dramatically. Once a secondary service, such stations are now being deployed as stand-alone outlets around the country. Following the creation of the LPFM service, broadcasters made a run on spectrum for FM translators which has resulted in seven translators going on the air for every one LPFM station over the last decade.

The FCC is now attempting to “level the playing field” so that the explosive growth of translators does not suffocate any LPFM expansion.

It comes as little surprise that the National Association of Broadcasters favor translators over LPFM stations. Commercial AM broadcasters now use FM translators to compensate for degraded listening conditions on the AM band, and many adoptees of HD Radio are purchasing or leasing translators on which to simulcast digital FM subchannels as entirely new radio stations.

Some of the principals in the “Great Translator Invasion,” such as the religious broadcasters Radio Assist Ministry/Edgewater Broadcasting and the Educational Media Foundation, had the hubris to file comments in the LPFM proceeding arguing that they should be allowed to keep their ethically-challenged spectrum windfall.

Radio Assist/Edgewater have sold hundreds of FM translators to other broadcasters and reinvested that money in building a network of 60 full-power religious stations; Educational Media Foundation recently entered into a deal with Clear Channel allowing the latter to program some of the former’s translators with otherwise-unheard FM-HD2 program content.

LPFM advocates like the Prometheus Radio Project, REC Networks, and Common Frequency have developed a joint proposal that would restrict the growth of translators and give the LPFM service meaningful room for expansion.

The FCC has already signaled that it’s not necessarily comfortable with the explosive growth of translator stations and expects to promulgate further rules for LPFM which may result in an application filing window for new stations by the summer of next year.

In the meantime, the folks at Prometheus are conducting a survey of LPFM stations in order to build an informational resource for existing and future LPFM broadcasters. The survey seeks data on LPFM station financing, management and programming “to serve as a tool in our own work with stations, as well as to help us and other advocates and they make the case for LPFM and community radio. We also hope it will be a resource to stations and future LPFM applicants, allowing them to locate and contact other stations, and see information about how other stations function.”