REC Networks has collected and posted summaries of several “constituency comments” (those filed by groups representing communities of interest), doing the thankless job of weeding through the auto-file form-fill spam.
The National Association of Broadcasters, predictably, opposes any changes to the FCC’s LPFM rules that might expand the service, continuing to peddle fully-debunked claims that 100-watt stations have the potential to cause “harmful interference” to stations 10 to 1,000 times their size in terms of power.
The comments – which took three NAB executives, three staffers (including former high-level FCC staff), and two law clerks to write and sign off on – also rubs the agency’s nose in the fact that it is prohibited by congressional fiat from relaxing channel-spacing rules to create space for LPFM stations in urban areas.
The NAB also claims that FM translator stations “enhance localism,” although it fails to describe how exactly that happens. But it does give props to the Educational Media Foundation, promulgators of K-LOVE and AIR 1, for its clever use of translator networking.
Big Broadcasting does now recognize that LPFM “may provide…an important public service.” This is only significant insofar as it’s in writing.
National Public Radio’s comment language is more cerebral, but the song remains about the same: LPFM stations are somehow less “spectrum efficient” than full-power stations, and expanding the service expands the potential for interference. Whereas in the original round of rulemaking NPR’s interference hype revolved around reading services for the blind (often carried on the subcarriers of full-power FM station signals), this time the threat-focus is on translator stations.
NPR (via five authors) believes that should LPFM stations gain priority to spectrum relative to translators, the entire translator service will be “subverted.” The Station Resource Group generally echoes NPR’s substantive claims but is harsher on the FCC for the way it allowed translator-mongers to suck up spectrum in the first place; it also supports an independent investigation into FM translator speculation and trafficking.
On the other hand, the National Translator Association wouldn’t mind doing away with carpetbagging translator-mongers:
The NTA opposes the use of satellites to feed noncommercial FM stations to FM translators. Further, the NTA has opposed, so far without success, filing rules that fail to restrict speculative filers….The NTA considers those applicants who intend to obtain construction permits and then sell those permits to be simply speculators for profit.
It also supports some change in the rules allowing LPFM stations a measure of primacy over satellite-fed translators, but not terrestrially-fed ones.
The initial comment round on the FCC’s proposal to modify LPFM (with an eye toward expanding it) is now closed, but reply comments can be filed until September 21 (use 99-25 as the proceeding number).
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