REC Networks is giving conditional support to the idea of creating a new FM Class A10. It hopes the FCC will pair A10 with an LPFM power increase proposal as part of an “expansion of rural broadcasting.”
REC, founded by Michelle Bradley, is a consulting and regulatory advocacy firm that works with low-power FM and other small stations.
“REC’s support is conditioned on advancing both the A10 proposal and REC’s Simple250 Petition for Rulemaking to a Notice of Proposed Rulemaking as a combined proceeding,” Bradley wrote in an online post. The latter proposal would allow some LPFMs to increase power to 250 watts.
“Both proposals can provide an overall solution for rural stations to improve their performance both inside and outside of their existing service contours.”
As we’ve reported, Class A10 recently was proposed by Commander Communication Corp. as an intermediate service class between A and B1 or C3, depending on location. Class A10 stations would be licensed with 10 kilowatts at 100 meters height above average terrain, with a service contour of 32 kilometers. The FCC quickly opened the idea to comments, which are due today.
Bradley said she performed several studies to determine the impact of the A10 proposal on FM translators, LPFM stations and newly granted LPFM construction permits from the recent filing window.
She said the number of Class A stations able to upgrade to Class A10 from their current locations would be limited.
“At the outset, just over half of the stations will have a path to upgrade. This number can be further reduced because for most Class A stations with a path to upgrade, it will involve the use of expensive directional antennas and stations will need to determine whether a modification to get a mere 2.2 dB power increase is worth the expense.”
She said the number may be further reduced due to mutual exclusivity situations. “Two Class A stations spaced at a particular distance will not both be able to upgrade.”
She also said that the distance separation studies for LPFM show that in a worst-case scenario, over 20% of stations may experience some kind of impact. “Most of these impacts take place outside the LPFM station’s primary service area. The actual impact will depend on how many Class A stations actually upgrade.”
REC’s contour overlap studies for LPFM and translators show that in the worst case, up to 10.6 percent of LPFM and 12.7 percent of FM translators may experience new or increased contour overlap within their service contour as a result of upgraded stations.
“Contour overlap studies also showed that some LPFM and FM translator stations may receive a benefit from the upgrade if the upgraded station is on their second-adjacent channel (also third-adjacent channel for FM translators).”
She said the upgrade of Class A FM stations to A10 would have a “very minimal impact” on the upgrading of LPFM stations to LP250, as REC has proposed.
Bradley wrote in her post, “It is important to remember that despite the ‘MB Docket’ number, the Class A10 proposal is not yet at a Notice of Proposed Rulemaking. It is still a petition only, at the same level as RM-11909 for LP250. This is nowhere near a done deal at this time.”
Other ideas
Bradley did not agree with everything in Commander’s Class A10 proposal.
If the FCC does not put A10 and LP250 together in a proposed rulemaking, Bradley said she will oppose the A10 class. But she also listed certain other proposed changes in the event that the FCC does adopt A10 alone.
Those counter-proposals include adjusting the A10’s minimum distance separation tables and adding distance separation values for LPFMs; excluding Puerto Rico and the U.S. Virgin Islands from Class A10, splitting them instead into a new FM zone called “One-B”; and making changes to Commander’s proposed treatment of Class B1 and C3 facilities that operate within the parameters of Class A10.
She said Class B1 and C3 facilities in the reserved band (88–92 MHz) that operate within the parameters of Class A10 should be automatically downgraded to the A10 service class “as to allow the excessively reserved spectrum to be used for future LPFM opportunities.”
The REC position also calls for B1/C3 stations in the non-reserved band (92–108) to follow the “Order to Show Cause” process currently in place for Class C facilities operating at Class C0 parameters.
“This is because in the non-reserved band, additional protections are set aside the same way, even for other primary stations, and such a policy would result in an efficient use of spectrum for full-service stations needing to amend the table of allotments in order to accomplish a preferred arrangement of allotments or for a station upgrade,” Bradley said.
“LPFM stations cannot request the downgrade of a Class C to C0 right now, nor do we ask for that ability in respect to B1/C3 to A10 in the non-reserved band. The reserved band does not afford that similar protection (except for non-reserved band channels near the edge of the reserved band in respect to those full-service stations on 92.1–92.5 seeking to make changes).”
Bradley said a considerable majority of Class B1/C3 stations that are actually operating at Class A10 parameters are in the reserved band.
[Read REC’s main comment filing here. Bradley also posted a page for stations to check for possible upgradability of a Class A station to A10 or to check for potential impacts to a specific LPFM or FM Translator station. Find that here.]
