On April 2, 2020 the FCC released a draft copy of the Report and Order MB Docket No. 17-105 Amendments of Parts 73 and 74 to Improve the Low Power FM Radio Service Technical Rules. The rulemaking originated a couple years ago as a petition for rulemaking to upgrade LPFM service from a 100-watt to 250-watt (LP-250) service, with other minor changes requested to improve the Low Power FM rules. Last July, the FCC finally released a notice of proposed rulemaking concerning this issue, excluding the prospect of LP-250, for public comment. Previous comments for the petition for rulemaking and notice of proposed rulemaking were strongly in support of LP-250. The draft copy is to be voted for official rule change at the Commission's next open meeting. The highlights of the rule change include, on the positive side--
- The ability to move an LPFM station 11.2 km instead of 5.6 km to a new site (or have overlapping 60 dBu contours of the current and proposed stations).
- Allow LPFM stations to operate "booster" stations. These stations do not extend the LPFM signal, only supplement coverage within the station's primary coverage area that is impeded by terrain.
- Allow multiple LPFM stations to use a common Emergency Alert unit to save money.
- The Commission insinuates LPFMs could apply for waivers to change coverage when "boxed in" when short-spaced by translators.
These are positive things. But moving on, the disappointing aspects:
- The FCC refused to upgrade LPFM service wattage for no logical reason, ignoring all the commenters on the docket. There are numerous reasons to upgrade LPFM wattage. In a comment provided by associates of Common Frequency, the Commission's flawed logic stipulated in the notice of proposed rulemaking (see footnote, page 3 of the NPRM for the FCC's excuses) was deconstructed (see page 3+ HERE). The take-home is the current administration is more attuned to the demands of the National Association of Broadcasters, which does not want the breadcrumbs-spectrum-use of LPFM to impart any competition with its commercial radio assets.
- The FCC agreed that LPFM could expand the usage of directional antennas specifically for protection of stations near the US border. However, as per request by the commercial radio industry, the FCC wants LPFM to only directional antennas that are professionally pre-tested by a professional manufacturer. This antenna certification procedure costs thousands of dollars. Furthermore, the stipulation is not grounded in any engineering rationale. First, LPFM stations already must abide by minimum spacing rules to any full power commercial station, which inserts a 20 km safety buffer for interference. A directional antenna, but definition, would only decrease radiation towards commercial stations, not increase. Thus, a directional antenna can only provide more protection than a regular full-pattern antenna. Second, if a LPFM was providing protection to a translator with a directional antenna, it is an unbalanced service-to-service interference protection. Translator stations do not need to have pattern-tested directional antennas, and can operate at higher wattages than LPFM. Since LPFM and FM translator are both co-equal services under the Local Community Radio Act, LPFM would be providing a higher degree of protection to translators than the translators would to LPFM.
- The FCC denied LPFM the use of type-verified transmitters -- the type of transmitter used by FM translator, commercial, and non-commercial stations. LPFM uses type-"certified" transmitters. Both types are the same, only the latter utilizes a third-party testing lab. The FCC is suggesting that the type of transmitters used by commercial stations is not compliant-assured enough to be used by LPFM.
- The FCC decided not to change the Channel 6 protection rules (Channel 6 is adjacent to the lower half of the FM band), and suggesting waiting until next year when the Channel 6 protection rules should be lifted via another Commission rulemaking.
- Two of the three aforementioned positive changes to LPFM -- longer distance moves and boosters -- were already allowed previous to the rule change under waiver or implicit usage.
The substantive changes to the rules here are LPFM service's allowed usage of common Emergency Alert units, the availability to use directional antennas near the border and move longer distances upon modification, and the availability of waivers to change coverage when boxed-in coverage-wise to a translator. While these changes to the rules are readily appreciated, they are more muted in effort compared to the relief the FCC has offered in the past few years to other radio services for their operating issues. Furthermore, reasoning behind not pursuing more changes is not rooted in proper engineering rationale or improved public service, but motivated by protectionist suggestions from the broadcast industry.