Common Frequency Inc., a non-profit that promotes community and college radio, wrote: “The commission writes, ‘Historically, some analog LPTV stations licensed on Channel 6 have operated with very limited visual programming and an audio signal that is programmed like a radio station.’ This is a polite way of stating that these LPTV facilities have ignored Section 73.682 of the commission’s rules and have been broadcasting at 300% of the allowable audio modulation to market itself as a radio station at 87.7 MHz on the FM dial instead of a television station.
“The issue here is continuing this service … would require an aberrant special carve-out of new rules to fit within the commission’s current rules if operated as an FM station.”