Re: LPFM Rules

[mwaters@mail.wesleyan.edu (Martin J. Waters)]

>In a post to me that was not originally put on the listserv, R.L. Caron wrote:
>The new section 73.209(c) says,  "Permittees and licensees of FM stations
>are not protected from interference by the grant of an LPFM station or of
>authority to modify an existing LPFM station, except in instances where the
>FM station would receive predicted interference from an LPFM station within
>the FM stations 3.16 mV/m (70 dBu) contour."
>
>What I see is that an existing station, say a Class A, will still be
>protected from other full facility stations to its 60 dBu contour (17.6
>miles); but, if the interference is from a LPFM station, then the protection
>is only within the 70 dBu curve. For a Class A, that's only ten miles. That
>means a Class A's "franchise," the area guaranteed to be interference-free,
>goes from 978 square miles down to 320 ... or a loss of 2/3rds! It may not
>be illegal for the FCC to do this, but is this really what efficient
>spectrum management is all about?
>
>Do you see it differently?

        In my previous, I was arguing abstract things. I don't have to like
the LPFM decision to say that I think the FCC has the legal right to vote
yes on it.
        On the LPFM thing, my answer to yours is, No. With Class As, in
particular, I don't think anything should be done to diminish their
coverage areas. And, on top of that, I think that up-ing them to 6,000
watts was about right. Now that you've brought it up, I'd have written the
LPFM rules so that Class As were protected fully, and to the 6,000 level in
any cases where someone might be eligible for more power under the old
rules but hasn't done it yet. If you're going to do the LPFM at all, nibble
away at the Bs and Cs.
        And, if you really want to know, I would have taken this
opportunity to end the abuse of translators by rolling that whole thing
into this rulemaking. I would have morphed all the translator
assignments/provisions into the LPFM thing. I would have effectively
revoked all the existing translators and made the licensees compete in the
pool for new LPFMs, with the right additions included in the LPFM rule to
give credit in situations where the translators are "genuine," i.e.,
local/regional.
        Unfortunately, Clinton never appointed me.