UPDATED: FCC clarifies LPFM channel/points.. LPFM filing window..

REC Networks - Wed, 05/16/2012 - 20:35

In a public forum on LPFM, FCC Audio Division staff member James Bradshaw clarified the requirements that FM Translators will be required to follow to protect LPFM protected channel/points. 

In the Fourth Report and Order, it was not clear at what point LPFM channel/points would be protected by FM translators.  REC assumed that the normal §73.807 LP-100 distance spacing between LPFM and translators would apply thus meaning that translators would be placed into three different "sub-classes" and would be afforded protections based on channel adjacency (co-channel, first or second adjacent channel) and the size of their 60 dBu service contour. 

In today's public forum, Bradshaw clarified the requirements that the FCC will be looking at. 

The FCC will establish a 39km buffer zone around the entire grid (measured from each edge point).  Any translator located within that buffer zone will have to make a showing that they are not precluding any translator opportunity.  Translators must only show that they are protecting LPFM opportunities on co-channel and first adjacent channels.  Second adjacent protection is not required. 

In the preclusion study, the co-channel and first-adjacent channel protection requirements in 73.807 will be used.  For example, a translator with a service contour of 7.9km that is located 25km from the edge of the grid but is located 34km from the co-channel closest LPFM channel/point would still be acceptable for filing because while it is in the buffer zone, it still is at least 32 km away as 73.807 requires.

The FCC does not appear to be protect LPFM channel/points on second adjacent channels despite existing rules that require LPFM stations to protect FM tranalstors on second adjacent channels and no proposed rulemaking that removes this second adjacent channel protection requirement for LPFM stations.

The FCC also clarified how protected LPFM Channel/Points are determined as this varies for spectrum limited and spectrum available markets.  In spectrum available markets, channel/points do not necessarily come into play unless the translator amends their application.  As long as the translator stays at their location, they are acceptable.

These clarifications may impact LPFM Channel Search Tool and backend report (ENAC, SUPER, etc.) results.  REC is in the process of redefinition in our tools and will deliver revised results to our tools and our ORG2ORG users as soon as possible.

We will be adding a new "preclusion" datapoint into our data outputs.  This will be triggered whenever a FM translator is less than 39km from the grid edge.  This will eventually be delivered in the Channel report function of the LPFM Channel Search Tool and will also be made available through Broadcast Query and RECPRO.

Without any preclusion statement requirement for second adjancent, this will slightly reduce the opportunities in spectrum limited markets.  With these changes, we are also correcting an REC related issue with the handling in spectrum available markets.  Acccording

REC will notify users on Twitter and Facebook as these changes are placed in these tools.  During the transition, there may be some times when the Tool returns conservative results.

In the same meeting, the Commission clarified that the LPFM filing window will not likely take place until "spring or summer 2013".  REC has been aware that a Spring 2013 translator filing window is likely.  REC and other LPFM advocates are supporting a request that the FCC give a period of time from when the final LPFM technical rules are released to the time the filing windows begin.  REC is advocating at least two windows featuring adjacent states as to avoid any preference to one state over another in the case of multi-state metropolitan areas.

The FCC also stated that they may "entertain" another FM translator window but not until after the existing Auction 83 applications are handled as well as the LPFM filing window.  Likely in 2014.

This article was substantually corrected to clarify that the 39km buffer is only to show a precusion study and that 73.807 distances are still what is considered overall preclusion.

Categories: Michi's Other Blogs

FCC to hold LPFM/FM Translator public forum

REC Networks - Fri, 05/11/2012 - 22:20

On May 16 from 2.00~3.30PM EDT, the FCC will hold a public forum for the two recent Report and Orders. There will be discussion about the FCC's LPFM Grid software, FM Translator non-preclusion showings and the processing differences between spectrum limited and spectrum available markets. There will also be time for audience questions.

Those in DC can attend at the FCC:
445 12th St SW
Commission Meeting Room

It will also be streamed live at
http://www.fcc.gov/live

Questions may be e-mailed on the day of the event to livequestions@fcc.gov

REC recommends anyone who is interested in the upcoming translator application process should attend this forum.

Categories: Michi's Other Blogs

REC supports limited "one-to-a-market" waivers for rural/suburban FM translator applications

REC Networks - Fri, 05/11/2012 - 06:10

In March, when the FCC decided the fate of over 6,000 FM Translator pending applications from the 2003 Auction 83 window, they had two objectives.  First they had to comply with the Local Community Radio Act of 2010 which states that LPFM and FM translator licenses must be available based on community need.  They also needed to address an issue by REC and many others regarding the excessive speculative filing of applications during the Auction 83 window which REC referred to at that time as the "Great Translator Invasion". 

To address the issues with the LCRA, the FCC developed the concept of "channel floors" and grids which turned into spectrum limited and available markets as well as LPFM protected channel/points. 

To address the issues with trafficking, the FCC imposed a nationwide cap of 50 applications nationwide as well as a cap of 1 application per Arbiron Metro Market. 

In this past week, the FCC has received several petitions for reconisderation. 

One petition came from Educational Media Foundation, an organization with 494 applications still pending in this application.  EMF expressed frustration over the 50-cap especially considering the previous memorandum of agreement between EMF and Prometheus Radio Project that suggested a diferent filing process in lieu of the 10-cap, a process that was later invalidated with the passage of the LCRA.  Also in their petition, EMF wanted clarification from the Commission of the boundaries where one to a market would apply. 

In addition, several petitions were filed by organizations representing faith-based, public radio and commercial interests asking for some relief from the the "one-to-a-market' rule, considering the size many markets.

One of the petitions was filed jointly by Hope Christian Church of Marlton, New Jersey-based Bridgelight, LLC and New York-based Calvary Chapel of the Finger Lakes.  All three of these petitioners have less than 50 applications still pending in the window.  They have requested a waiver to the "one-to-the-market" rule for translators with the following conditions:

  • The 60 dBu service contours of two pending translators from the same applicant can not overlap.
  • The translator will protect LPFM opportunities both within the grid and at the transmitter site.
  • The construction permit includes a stipulation that the permit/license can not be transferred/assigned for a 4-year period from the time the station begins operation.

Arbitron Metro Markets reach well beyond the urbanized city limits of a certain large community but usually also includes adjacent counties without much regard for terrain and coverage.  For example, the Los Angeles market includes the Antelope Valley area, a significant population center but terrain shielded from many Los Angeles area radio stations.  For Calvary Chapel Finger Lakes, they have applications for translators in the Rochester market but the location is approximately 35 miles away from the city center but because of the county the transmitters would be in, it's still considered the metro market. 

In our comments last summer regarding channel floors, we expressed a similar concern.  In our case, we were concerned about "hyphenated" markets or in other words, Arbitron markets that cover more than one significant population center that are not necessarily connected other than in the eyes of Arbitron. 

In a filing to the FCC on Thursday, REC has filed a partial opposition to the petitions for reconsideration. 

REC will support the ability for FM translators to seek waivers with both the conditions that were proposed by Hope Christian Church and three conditions that are being proposed by REC:

  • The 60 dBu service contour can not overlap the areas that were designated by the FCC as areas where LP250 service would not be permitted.  This includes:
    • 30km around the city centers of markets 1 through 20.
    • 20km around the city centers of spectrum limited markets 21 through 50.
    • 10km around the city centers of spectrum limtied markets 51 through 100.
  • For a 4-year period, the translator must rebroadcast a commonly-owned primary station and must be the main analog audio carrier of that AM or FM station.
  • All applications processed under this waiver are still subject to the 50-cap.

For those translators that are currently not short spaced of LPFM protected channel/points, they are showing as "active" in our databases and thus are considered in channel searches. While one-to-a-market will provide some beneifts for LPFM by potentially opening more LPFM opportunities, LPFM will not lose any opportunities under this proposal as what must protect LPFM channel/points today, must protect LPFM channel/points tomorrow.

REC's proposed conditions address the issues related to trafficking.  By imposing a restriction on location away from the major spectrum limited markets, we are assuring that translators obtained through waiver program are truly for suburban and rural areas.  The primary station restriction proposed  by REC assures that the station will not be leased out to another organization for a profit such as EMF's practice of leasing translators to Clear Channel and CBS to operate as "fill-in" stations but are really playing original HD2 programming on analog frequencies.  REC also proposes a restriction that requires the translator to broadcast the main analog audio carrier of the commonly-owned primary AM or FM station.  Finally, we wanted to make sure that if the FCC gives waivers for "one-to-a-market", that it does not mean that the "50-cap" rule is also going to be waived. 

REC still supports the 50-cap as the best way to "stop the bleeding" of excessive filing.  6 applicants have over 100 pending applications and overall, 18 applicants have filed over half of the remaining pending applications.  Those 18 applicants currently have more than 50 pending applications.

For the signers of the "Hope Petition", the REC proposed process would grant:

  • Hope Christian Church: 9 waivers (6 in the outskirts of Philadelphia and 3 in Atlantic City along the shore).
  • Bridgelight, LLC: 4 waivers in the New York market (one in New Jersey and 3 in eastern Long Island).
  • Calvary Chapel Finger Lakes: 2 waivers (Niagara Falls and in rural Genesee County).

We feel that our proposed process will protect LPFM in the urban and rural areas, address the issues of trafficking and add programming diversity to suburban and rural areas with a mix of local and regional voices. We feel that it strikes the right balance.

A copy of our reponse can be found here.

 

Categories: Michi's Other Blogs

REC LP-250 Potential Upgrade List (May update)

REC Networks - Thu, 05/10/2012 - 07:41

REC Networks has reviewed the potential ability for current LP-100 stations to be able to upgrade to LP-250 at their existing site if the FCC approves a 250 watt at 30m HAAT. Stations that may be geographically restricted from upgrading are marked with an asterisk (*). REC has proposed that LP100 stations even in these areas should be allowed to upgrade and if the upgrade can be done on the same channel, a first adjacent or IF channel, it should be a minor change.

In some cases, to use the same channel may require a second adjacent channel waiver. There has been no confirmation that a second adjacent channel waiver may be allowed in these situations. LPFM stations in this situation should check further to see if there's an alternate properly spaced channel available.

To check your location in the LPFM Search Tool while preventing your station from coming up, just enter your station's FCC Facility ID in the "Co-located on another tower" Facility ID field as well as the "Notch" field.

In many cases, an LPFM station that is not able to upgrade on their own channel may be able to upgrade on a different channel. Alternate channels are shown in the line under the LPFM station's call and location.

LPFM stations that are located above 30m HAAT will have their power adjusted so the service contour does not exceed 7.089 km (normally rounded to 7.1 km). In addition, LP-250 stations may be placed at HAAT above 450m where stations will be able to operate 1 watt.

REC has found that a small number of LPFM stations will not have the ability to upgrade at all at the same site.

If your station is within 125km of Mexico and especially if your station is at the 30m HAAT minimum, please disregard your station's status on this list. You are already limited to 50 watts and will not be able to upgrade. It is believed (but not confirmed) that those that are located above 30m HAAT may be able to upgrade power as long as the overall output power does not exceed 50 watts and the 40dBu interfering contour does not exceed 32km.

The LP-250 Upgrade Report as of May 10, 2012 follows:

R E C NETWORKS - LP-250 UPGRADE REPORT

NOTE: based on LP-100 station's current location and does not take into consideration the potential for upgrade with a facility move.

* - Indicates an LP-250 subject to FCC's proposed geographic restrictions. Under their proposal, upgrade to LP-250 not possible regardless of availabity.

The following stations may be able to upgrade on their channel:

KDHS-LP Ch 238 DELTA JUNCTION AK (124904)
--- chan: 238

KEAA-LP Ch 250 EAGLE AK (124743)
--- chan: 250

KXES-LP Ch 225 GALENA AK (123974)
--- chan: 225

KBJZ-LP Ch 231 JUNEAU AK (123926)
--- chan: 231

KVIM-LP Ch 224 JUNEAU AK (124225)
--- chan: 224

KAQU-LP Ch 201 SITKA AK (124750)
--- chan: 201

KWRG-LP Ch 260 WRANGELL AK (124854)
--- chan: 260

WESZ-LP Ch 254 ABBEVILLE AL (132859)
--- chan: 254

WAUF-LP Ch 283 AUBURN AL (133684)
--- chan: 283

WWFC-LP Ch 260 BRYANT AL (134944)
--- chan: 260

WFBH-LP Ch 244 HAMILTON AL (133868)
--- chan: 244

WJSD-LP Ch 233 HENAGAR AL (134704)
--- chan: 233

WRNK-LP Ch 242 LANETT AL (133833)
--- chan: 242

WVMB-LP Ch 300 MADISON AL (133368)
--- chan: 300

WURY-LP Ch 246 PHENIX CITY AL (135293)
--- chan: 246

KCCJ-LP Ch 295 BATESVILLE AR (134755)
--- chan: 295

KUOZ-LP Ch 263 CLARKSVILLE AR (133949)
--- chan: 263

KPWH-LP Ch 278 JONESBORO AR (133430)
--- chan: 278

KFLO-LP Ch 275 JONESBORO AR (134653)
--- chan: 275

KRMN-LP Ch 266 MENA AR (134109)
--- chan: 266

KQIX-LP Ch 243 PERRYVILLE AR (135062)
--- chan: 243

KHEL-LP Ch 247 ROGERS AR (134355)
--- chan: 247

KJAT-LP Ch 247 SULPHUR SPRINGS AR (135764)
--- chan: 247

KULA-LP Ch 236 ILI'ILI AS (132293)
--- chan: 236

KBRP-LP Ch 241 BISBEE AZ (132622)
--- chan: 241

KCWG-LP Ch 262 CROWN KING AZ (133424)
--- chan: 262

KJNN-LP Ch 232 HOLBROOK AZ (135598)
--- chan: 232

KPUP-LP Ch 263 PATAGONIA AZ (134483)
--- chan: 263

KPYT-LP Ch 262 TUCSON AZ (134640)
--- chan: 262

KMAI-LP Ch 250 ALTURAS CA (124325)
--- chan: 250

KCHP-LP Ch 246 ARCATA CA (124464)
--- chan: 246

KRHM-LP Ch 278 BAKERSFIELD CA (123382)
--- chan: 278

KSOJ-LP Ch 278 BANNING CA (124422)
--- chan: 278

KKJD-LP Ch 256 BORREGO SPRINGS CA (124818)
--- chan: 256

KMOB-LP Ch 262 CLEARLAKE CA (124107)
--- chan: 262

KORM-LP Ch 268 CORONA CA (124781)
--- chan: 268

KDPT-LP Ch 275 DOS PALOS CA (123601)
--- chan: 275

KYFC-LP Ch 237 EL CENTRO CA (124429)
--- chan: 237

KFOK-LP Ch 236 GEORGETOWN CA (124842)
--- chan: 236

KVRY-LP Ch 242 GOLETA CA (124826)
--- chan: 242

KGGV-LP Ch 236 GUERNEVILLE CA (124862)
--- chan: 236

KZED-LP Ch 298 LA GRANGE CA (124077)
--- chan: 298

KXRN-LP Ch 228 LAGUNA NIGUEL CA (124565)
--- chan: 228

KGAR-LP Ch 227 LEMOORE CA (124421)
--- chan: 227

KLPC-LP Ch 278 LONE PINE CA (124525)
--- chan: 278

KPSR-LP Ch 300 MODESTO CA (124794)
--- chan: 300

KMSJ-LP Ch 231 MT. SHASTA CA (124869)
--- chan: 231

KRBH-LP Ch 226 RED BLUFF CA (124306)
--- chan: 226

KDEE-LP Ch 249 SACRAMENTO CA (123915)
--- chan: 249

KJVA-LP Ch 232 SAN BERNARDINO CA (124517)
--- chan: 232

KIHP-LP Ch 243 SHASTA LAKE CA (124256)
--- chan: 243

KRDW-LP Ch 297 SMITH RIVER CA (124873)
--- chan: 297

KEFC-LP Ch 263 TURLOCK CA (123909)
--- chan: 263

KMEC-LP Ch 286 UKIAH CA (124562)
--- chan: 286

KWLK-LP Ch 279 VALLEY SPRINGS CA (124867)
--- chan: 279

KYLO-LP Ch 227 WOODLAND CA (124758)
--- chan: 227

KRYC-LP Ch 290 YUBA CITY CA (124521)
--- chan: 290

KCYC-LP Ch 284 YUBA CITY CA (124166)
--- chan: 284

KJSM-LP Ch 246 YUCCA VALLEY CA (124223)
--- chan: 246

KASP-LP Ch 300 ASPEN CO (131679)
--- chan: 300

KCQX-LP Ch 295 CUCHARA CO (132410)
--- chan: 295

KYGT-LP Ch 274 IDAHO SPRINGS CO (131469)
--- chan: 274

KRLG-LP Ch 300 KREMMLING CO (131686)
--- chan: 300

KLNX-LP Ch 300 MINTURN CO (131946)
--- chan: 300

KURA-LP Ch 255 OURAY CO (131909)
--- chan: 255

KTPJ-LP Ch 290 PUEBLO CO (132199)
--- chan: 290

KHEN-LP Ch 295 SALIDA CO (131955)
--- chan: 295

KWMV-LP Ch 240 WESTCLIFFE CO (132142)
--- chan: 240

WNLN-LP Ch 297 NIANTIC CT (126588)
--- chan: 297

WIHW-LP Ch 241 DOVER DE (132040)
--- chan: 241

WWMA-LP Ch 300 AVON PARK FL (135055)
--- chan: 300

WGGP-LP Ch 294 BIG PINE KEY FL (133257)
--- chan: 294

WBVL-LP Ch 259 BUENA VENTURA LAKES FL (133444)
--- chan: 259

WFJV-LP Ch 277 CITRONELLE FL (133271)
--- chan: 277

WXEI-LP Ch 237 CRESTVIEW FL (134286)
--- chan: 237

WCKO-LP Ch 244 CROSS CITY FL (133793)
--- chan: 244

WWEO-LP Ch 280 DE FUNIAK SPRINGS FL (134645)
--- chan: 280

WRLE-LP Ch 235 DUNNELLON FL (133335)
--- chan: 235

WPZM-LP Ch 298 GAINESVILLE FL (133183) *
--- chan: 298

WFBU-LP Ch 234 GRACEVILLE FL (135012)
--- chan: 234

WCIW-LP Ch 300 IMMOKALEE FL (133832)
--- chan: 300

WUCR-LP Ch 300 LAKE BUTLER FL (134253)
--- chan: 300

WFLU-LP Ch 300 MILES CITY FL (134872)
--- chan: 300

WITG-LP Ch 284 OCALA FL (131370)
--- chan: 284

WPCU-LP Ch 295 PANAMA CITY FL (134855)
--- chan: 295

WDBW-LP Ch 247 PORT SAINT JOE FL (134360)
--- chan: 247

WTHA-LP Ch 296 SEASIDE FL (133863)
--- chan: 296

WJRN-LP Ch 240 SUMMERFIELD FL (133510)
--- chan: 240

WFSD-LP Ch 300 TALLAHASSEE FL (133160)
--- chan: 300

WIFL-LP Ch 283 WEIRSDALE FL (135770)
--- chan: 283

WASU-LP Ch 224 ALBANY GA (123997)
--- chan: 224

WRMK-LP Ch 262 AUGUSTA GA (124210)
--- chan: 262

WBHS-LP Ch 285 BRUNSWICK GA (123502)
--- chan: 285

WFVS-LP Ch 282 FORT VALLEY GA (124185)
--- chan: 282

WAQA-LP Ch 233 MORGANTON GA (124833)
--- chan: 233

WWEZ-LP Ch 234 ST. SIMONS ISLAND GA (123743)
--- chan: 234

WJGG-LP Ch 251 THOMASVILLE GA (124213)
--- chan: 251

WSDA-LP Ch 254 TRENTON GA (124572)
--- chan: 254

KGCA-LP Ch 295 TUMON GU (133792)
--- chan: 295

KCSK-LP Ch 272 HANAMAULU HI (132237)
--- chan: 272

KIHL-LP Ch 279 HILO HI (132082)
--- chan: 279

KIOM-LP Ch 255 KAUNAKAKAI HI (132182)
--- chan: 255

KJAS-LP Ch 269 AMES IA (135544)
--- chan: 269

KCDM-LP Ch 252 BURLINGTON IA (133404)
--- chan: 252

KYMJ-LP Ch 276 CARROLL IA (133406)
--- chan: 276

KXJX-LP Ch 223 CLINTON IA (133435)
--- chan: 223

KOUR-LP Ch 224 CORALVILLE IA (133044)
--- chan: 224

KRQC-LP Ch 300 DAVENPORT IA (135708)
--- chan: 300

KTJT-LP Ch 274 DAVENPORT IA (133437)
--- chan: 274

KSDE-LP Ch 285 DE SOTO IA (133652)
--- chan: 285

KGYS-LP Ch 223 DEWITT IA (134279)
--- chan: 223

KEMB-LP Ch 231 EMMETSBURG IA (134365)
--- chan: 231

KRUU-LP Ch 261 FAIRFIELD IA (133984)
--- chan: 261

KDME-LP Ch 252 FORT MADISON IA (133439)
--- chan: 252

KTDC-LP Ch 287 MUSCATINE IA (134691)
--- chan: 287

KWFF-LP Ch 237 POCAHONTAS IA (134901)
--- chan: 237

KSOA-LP Ch 233 SLOAN IA (133584)
--- chan: 233

KUBH-LP Ch 260 URBANA GARAGE TOWER IA (133810)
--- chan: 260

KLCW-LP Ch 288 HAILEY ID (131466)
--- chan: 288

KMEI-LP Ch 247 KAMIAH ID (132207)
--- chan: 247

KRFP-LP Ch 223 MOSCOW ID (132196)
--- chan: 223

KUMC-LP Ch 269 RUPERT ID (131852)
--- chan: 269

WXRJ-LP Ch 235 BLOOMINGTON IL (126570)
--- chan: 235

WZND-LP Ch 277 BLOOMINGTON IL (126023)
--- chan: 277

WLMM-LP Ch 280 CHANNAHON IL (126923)
--- chan: 280

WLBM-LP Ch 289 DANVILLE IL (125790)
--- chan: 289

WCFS-LP Ch 290 DU QUOIN IL (125871)
--- chan: 290

WJHV-LP Ch 236 FAIRBURY IL (126528)
--- chan: 236

WVCL-LP Ch 239 GALESBURG IL (126789)
--- chan: 239

WLGS-LP Ch 268 LAKE VILLA IL (126664)
--- chan: 268

WTND-LP Ch 292 MACOMB IL (126554)
--- chan: 292

WWKJ-LP Ch 275 PEORIA IL (126761)
--- chan: 275

WQIN-LP Ch 275 QUINCY IL (126908)
--- chan: 275

WGVV-LP Ch 223 ROCK ISLAND IL (125960)
--- chan: 223

WTPB-LP Ch 257 ROCKFORD IL (125839)
--- chan: 257

WLJX-LP Ch 300 SPRINGFIELD IL (126157)
--- chan: 300

WIUX-LP Ch 256 BLOOMINGTON IN (123644)
--- chan: 256

WLFQ-LP Ch 254 ELKHART IN (124486)
--- chan: 254

WLDC-LP Ch 290 GOSHEN IN (124209)
--- chan: 290

WTGO-LP Ch 249 LAFAYETTE IN (124424)
--- chan: 249

WIWU-LP Ch 232 MARION IN (123734)
--- chan: 232

WHHC-LP Ch 298 NEW CASTLE IN (123622)
--- chan: 298

WJUK-LP Ch 289 PLYMOUTH IN (124016)
--- chan: 289

KCCA-LP Ch 221 ANTHONY KS (127030)
--- chan: 221

KFEX-LP Ch 226 CHANUTE KS (124998)
--- chan: 226

KCCC-LP Ch 253 HAYS KS (126672)
--- chan: 253

KCIU-LP Ch 269 LAWRENCE KS (126284)
--- chan: 269

KRMI-LP Ch 288 MANHATTAN KS (126285)
--- chan: 288

KTHA-LP Ch 263 THAYER KS (125312)
--- chan: 263

WITB-LP Ch 296 BENTON KY (134179)
--- chan: 296

WRHR-LP Ch 237 CORBIN KY (133957)
--- chan: 237

WJJA-LP Ch 253 EAST BERSTADT KY (133924)
--- chan: 253

WLZD-LP Ch 291 HAZARD KY (135664)
--- chan: 291

WSPP-LP Ch 228 HOPKINSVILLE KY (135680)
--- chan: 228

WKYD-LP Ch 238 JAMESTOWN KY (134075)
--- chan: 238

WIMM-LP Ch 300 OWENSBORO KY (135195)
--- chan: 300

WCCR-LP Ch 233 WILLIAMSBURG KY (133830)
--- chan: 233

WNLW-LP Ch 236 WILLIAMSBURG KY (134917)
--- chan: 236

KCJM-LP Ch 300 ALEXANDRIA LA (123726)
--- chan: 300

KURC-LP Ch 239 BASTROP LA (124101)
--- chan: 239

WHYR-LP Ch 245 BATON ROUGE LA (123985)
--- chan: 245

KVTZ-LP Ch 225 BREAUX BRIDGE LA (124732)
--- chan: 225

WZEN-LP Ch 300 HAMMOND LA (123633)
--- chan: 300

KQWJ-LP Ch 238 JONESBORO LA (124254)
--- chan: 238

KZJM-LP Ch 224 LAFAYETTE LA (123730)
--- chan: 224

KOUS-LP Ch 242 MONROE LA (124733)
--- chan: 242

KCRJ-LP Ch 235 MONROE LA (124800)
--- chan: 235

KZLC-LP Ch 238 PINEVILLE LA (123498)
--- chan: 238

KBLK-LP Ch 292 SHREVEPORT LA (124735)
--- chan: 292

WGON-LP Ch 279 SLIDELL LA (124637)
--- chan: 279

WNRC-LP Ch 248 DUDLEY MA (133676)
--- chan: 248

WLCQ-LP Ch 259 FEEDING HILLS MA (133854)
--- chan: 259

WKGT-LP Ch 296 NORTH ADAMS MA (133361)
--- chan: 296

WRRS-LP Ch 282 PITTSFIELD MA (133782)
--- chan: 282

WLHZ-LP Ch 300 SPRINGFIELD MA (134242)
--- chan: 300

WVVY-LP Ch 229 TISBURY MA (135357)
--- chan: 229

WMVK-LP Ch 297 PERRYVILLE MD (124828)
--- chan: 297

WMJS-LP Ch 271 PRINCE FREDERICK MD (123655)
--- chan: 271

WRYR-LP Ch 248 SHERWOOD MD (124341)
--- chan: 248

WJZP-LP Ch 286 PORTLAND ME (124197)
--- chan: 286

WRFR-LP Ch 227 ROCKLAND ME (124066)
--- chan: 227

WFPM-LP Ch 258 BATTLE CREEK MI (125881)
--- chan: 258

WVBH-LP Ch 287 BENTON HARBOR MI (126875)
--- chan: 287

WBHC-LP Ch 243 BENTON HARBOR MI (126885)
--- chan: 243

WSFT-LP Ch 288 BERRIEN SPRINGS MI (126911)
--- chan: 288

WDLP-LP Ch 226 FENWICK MI (126066)
--- chan: 226

WKUF-LP Ch 232 FLINT MI (125734)
--- chan: 232

WMLY-LP Ch 226 MARSHALL MI (126902)
--- chan: 226

WUVS-LP Ch 279 MUSKEGON MI (125796)
--- chan: 279

WMMT-LP Ch 291 MUSKEGON MI (126334)
--- chan: 291

WMBC-LP Ch 265 NORTON SHORES MI (126701)
--- chan: 265

WRDS-LP Ch 282 ROSCOMMON MI (126011)
--- chan: 282

WBSQ-LP Ch 290 SAINT LOUIS MI (127137)
--- chan: 290

WRHC-LP Ch 294 THREE OAKS MI (126310)
--- chan: 294

WAWB-LP Ch 297 WEST BRANCH MI (126398)
--- chan: 297

KBJI-LP Ch 292 BEMIDJI MN (126481)
--- chan: 292

WYSG-LP Ch 242 HINCKLEY MN (127128)
--- chan: 242

KKRM-LP Ch 244 MONTEVIDEO MN (126323)
--- chan: 244

KXBQ-LP Ch 240 MOORHEAD MN (126770)
--- chan: 240

WMLA-LP Ch 259 MOOSE LAKE MN (126903)
--- chan: 259

KNLW-LP Ch 255 ROCHESTER MN (126358)
--- chan: 255

KGLH-LP Ch 245 SPICER MN (126735)
--- chan: 245

KCSW-LP Ch 246 CANTON MO (131733)
--- chan: 246

KHEZ-LP Ch 300 CAPE GIRARDEAU MO (132259)
--- chan: 300

KWWU-LP Ch 235 FULTON MO (131522)
--- chan: 235

KRFL-LP Ch 300 FULTON MO (131905)
--- chan: 300

KZLX-LP Ch 294 MARYVILLE MO (131938)
--- chan: 294

KLHM-LP Ch 264 ST. JOSEPH MO (131633)
--- chan: 264

WQRZ-LP Ch 278 BAY SAINT LOUIS MS (126435)
--- chan: 278

WPBP-LP Ch 283 BRANDON MS (126132)
--- chan: 283

WQTP-LP Ch 295 COLUMBUS MS (126211)
--- chan: 295

WTRR-LP Ch 246 GLEN MS (126311)
--- chan: 246

WIXP-LP Ch 294 GREENVILLE MS (125794)
--- chan: 294

WQID-LP Ch 287 HATTIESBURG MS (126778)
--- chan: 287

WNNN-LP Ch 239 NOXAPATER MS (126713)
--- chan: 239

WPWS-LP Ch 282 PINEY WOODS MS (126695)
--- chan: 282

WKIU-LP Ch 235 TUPELO MS (126729)
--- chan: 235

KEME-LP Ch 292 BOULDER MT (134665)
--- chan: 292

KBWG-LP Ch 298 BROWNING MT (134853)
--- chan: 298

KQOV-LP Ch 253 BUTTE MT (133299)
--- chan: 253

KEAJ-LP Ch 262 CELL SITE MT (134669)
--- chan: 262

KEUR-LP Ch 299 EUREKA MT (134900)
--- chan: 299

KSMR-LP Ch 246 GREAT FALLS MT (133297)
--- chan: 246

KRWS-LP Ch 264 HARDIN MT (134773)
--- chan: 264

KCCH-LP Ch 249 HELENA MT (134394)
--- chan: 249

KNEH-LP Ch 247 HELENA MT (133295)
--- chan: 247

KWLG-LP Ch 292 MONTANA CITY MT (134809)
--- chan: 292

KCTP-LP Ch 271 PABLO MT (135345)
--- chan: 271

KMDM-LP Ch 300 POLSON MT (133196)
--- chan: 300

KPLR-LP Ch 245 POPLAR MT (134953)
--- chan: 245

KFAS-LP Ch 239 SHELBY MT (135609)
--- chan: 239

KTGC-LP Ch 267 ST. REGIS MT (134971)
--- chan: 267

KESW-LP Ch 293 WHITEHALL MT (134811)
--- chan: 293

WAOG-LP Ch 227 ABERDEEN NC (135064)
--- chan: 227

WRES-LP Ch 264 ASHEVILLE NC (135084)
--- chan: 264

WGNW-LP Ch 239 CANDLER NC (133487)
--- chan: 239

WLRZ-LP Ch 257 HICKORY NC (133607)
--- chan: 257

WFOG-LP Ch 267 MT. AIRY NC (135507)
--- chan: 267

WEZU-LP Ch 240 ROANOKE RAPIDS NC (134797)
--- chan: 240

WDSG-LP Ch 300 SANFORD NC (134499)
--- chan: 300

WBPL-LP Ch 224 WILMINGTON NC (135668)
--- chan: 224

WUBN-LP Ch 295 WILSON NC (135130)
--- chan: 295

KJIT-LP Ch 294 BISMARCK ND (135691)
--- chan: 294

KBEP-LP Ch 229 BISMARCK ND (133278)
--- chan: 229

KLBE-LP Ch 264 BISMARCK ND (133428)
--- chan: 264

KOWW-LP Ch 251 BURLINGTON ND (133549)
--- chan: 251

KPAR-LP Ch 279 DICKINSON ND (135046)
--- chan: 279

KOBT-LP Ch 267 GRAND FORKS ND (134933)
--- chan: 267

KSAF-LP Ch 281 MINOT ND (135303)
--- chan: 281

KIVE-LP Ch 223 AURORA NE (135537)
--- chan: 223

KJFT-LP Ch 300 LINCOLN NE (135606)
--- chan: 300

KNIF-LP Ch 300 SCOTTSBLUFF NE (135313)
--- chan: 300

KPVA-LP Ch 224 SHELTON NE (135442)
--- chan: 224

WJSK-LP Ch 266 BARTLETT NH (126146)
--- chan: 266

WXGR-LP Ch 268 DOVER NH (126947)
--- chan: 268

WUPC-LP Ch 272 ARROWHEAD VILLAGE NJ (133835) *
--- chan: 272

WZFI-LP Ch 253 BRIDGETON NJ (133208)
--- chan: 253

WCFA-LP Ch 268 CAPE MAY NJ (134095)
--- chan: 268

WLOM-LP Ch 224 OCEAN CITY NJ (135683)
--- chan: 224

WPOV-LP Ch 299 VINELAND NJ (134781)
--- chan: 299

KALH-LP Ch 236 ALAMOGORDO NM (134603)
--- chan: 236

KBNM-LP Ch 254 BELEN NM (133409)
--- chan: 254

KLDK-LP Ch 243 DIXON NM (133630)
--- chan: 243

KLYN-LP Ch 239 LAS VEGAS NM (134421)
--- chan: 239

KEDU-LP Ch 272 RUIDOSO NM (134657)
--- chan: 272

KSRL-LP Ch 276 SANTA ROSA NM (135559)
--- chan: 276

KKSC-LP Ch 261 SILVER CITY NM (134039)
--- chan: 261

KKTT-LP Ch 250 WINNEMUCCA NV (126278)
--- chan: 250

WSVV-LP Ch 265 CENTER MORICHES NY (132509)
--- chan: 265

WLRG-LP Ch 298 CORNING NY (132440)
--- chan: 298

WDRX-LP Ch 264 CORTLAND NY (132148)
--- chan: 264

WHWS-LP Ch 289 GENEVA NY (132126)
--- chan: 289

WBLN-LP Ch 285 GLENS FALLS NY (131698)
--- chan: 285

WIHR-LP Ch 231 JAMESTOWN NY (132445)
--- chan: 231

WRFA-LP Ch 300 JAMESTOWN NY (132401)
--- chan: 300

WKHV-LP Ch 280 KINGSTON NY (132425)
--- chan: 280

WGLU-LP Ch 291 NEWPORT NY (131911)
--- chan: 291

WJIH-LP Ch 240 ONEONTA NY (131486)
--- chan: 240

WLDM-LP Ch 239 SANITARIA SPRINGS NY (131507)
--- chan: 239

WEAK-LP Ch 294 ATHENS OH (131497)
--- chan: 294

WYWH-LP Ch 283 ATHENS OH (132289)
--- chan: 283

WVVW-LP Ch 251 BELPRE OH (131712)
--- chan: 251

WKJH-LP Ch 278 BRYAN OH (131382)
--- chan: 278

WOOO-LP Ch 238 DEFIANCE OH (131374)
--- chan: 238

WPCO-LP Ch 289 FREMONT OH (131917)
--- chan: 289

WNHC-LP Ch 281 LIMA OH (131891)
--- chan: 281

WCBV-LP Ch 290 LIMA OH (131958)
--- chan: 290

WWTL-LP Ch 292 LOGAN OH (131371)
--- chan: 292

WWOH-LP Ch 283 MARIETTA OH (132294)
--- chan: 283

WVVP-LP Ch 241 MARIETTA OH (131874)
--- chan: 241

WDCM-LP Ch 248 MARION OH (132319)
--- chan: 248

WLCI-LP Ch 248 NELSONVILLE OH (131994)
--- chan: 248

WNHS-LP Ch 289 NEWCOMERSTOWN OH (131769)
--- chan: 289

WHRR-LP Ch 241 PORTSMOUTH OH (132215)
--- chan: 241

WAJB-LP Ch 223 WELLSTON OH (131575)
--- chan: 223

WUHS-LP Ch 245 WEST UNION OH (132046)
--- chan: 245

WTLL-LP Ch 255 ZANESVILLE OH (131964)
--- chan: 255

KADB-LP Ch 244 ADA OK (123911)
--- chan: 244

KXBI-LP Ch 270 BARTLESVILLE OK (123916)
--- chan: 270

KLGB-LP Ch 232 ENID OK (124233)
--- chan: 232

KZPY-LP Ch 295 MARLOW OK (124070)
--- chan: 295

KPOP-LP Ch 299 SAPULPA OK (123922)
--- chan: 299

KFMY-LP Ch 300 TULSA OK (123878)
--- chan: 300

KSEP-LP Ch 260 BROOKINGS OR (135276)
--- chan: 260

KBWR-LP Ch 251 BURNS OR (135517)
--- chan: 251

KYON-LP Ch 249 CANYONVILLE OR (135780)
--- chan: 249

KBAV-LP Ch 280 COOS BAY OR (134923)
--- chan: 280

KSOW-LP Ch 294 COTTAGE GROVE OR (135431)
--- chan: 294

KUMP-LP Ch 300 DAYS CREEK OR (135478)
--- chan: 300

KITC-LP Ch 293 GILCHRIST OR (134468)
--- chan: 293

KTJN-LP Ch 266 GOLD BEACH OR (134580)
--- chan: 266

KJCR-LP Ch 300 GRANTS PASS OR (135682)
--- chan: 300

KSPL-LP Ch 251 JOHN DAY OR (135568)
--- chan: 251

KZZF-LP Ch 299 KLAMATH FALLS OR (135243)
--- chan: 299

KFYL-LP Ch 232 LA GRANDE OR (135215)
--- chan: 232

KTOD-LP Ch 251 LAKEVIEW OR (135707)
--- chan: 251

KGBZ-LP Ch 273 MADRAS OR (135771)
--- chan: 273

KMAB-LP Ch 257 MADRAS OR (135331)
--- chan: 257

KSHY-LP Ch 232 NEWPORT OR (134994)
--- chan: 232

KPAI-LP Ch 276 PAISLEY,OR OR (133953)
--- chan: 276

KGLS-LP Ch 256 TILLAMOOK OR (134505)
--- chan: 256

WMES-LP Ch 299 ALTOONA PA (133803)
--- chan: 299

WRZO-LP Ch 275 CHAMBERSBURG PA (135294)
--- chan: 275

WLRI-LP Ch 225 GAP PA (135143)
--- chan: 225

WFSJ-LP Ch 279 INDIANA PA (133192)
--- chan: 279

WMUG-LP Ch 286 INDIANA PA (133191)
--- chan: 286

WCSD-LP Ch 285 SHAWNEE-ON-DELAWARE PA (133431)
--- chan: 285

WXHQ-LP Ch 290 NEWPORT RI (123581)
--- chan: 290

WASD-LP Ch 270 AIKEN SC (132469)
--- chan: 270

WPCX-LP Ch 246 CLINTON SC (131284)
--- chan: 246

WXRY-LP Ch 257 COLUMBIA SC (131722)
--- chan: 257

WGEO-LP Ch 289 GEORGETOWN SC (131456)
--- chan: 289

WHEZ-LP Ch 240 HARTSVILLE SC (131603)
--- chan: 240

WVOY-LP Ch 255 JEFFERSON SC (131885)
--- chan: 255

WNIR-LP Ch 238 NEWBERRY SC (132071)
--- chan: 238

WWPZ-LP Ch 240 NEWBERRY SC (131871)
--- chan: 240

WRHJ-LP Ch 226 ROCK HILL SC (132312)
--- chan: 226

WYCJ-LP Ch 283 SIMPSONVILLE SC (131927)
--- chan: 283

WHRZ-LP Ch 281 SPARTANBURG SC (131757)
--- chan: 281

WKPJ-LP Ch 283 ATHENS TN (135040)
--- chan: 283

WVOO-LP Ch 296 COLUMBIA TN (134052)
--- chan: 296

WJNU-LP Ch 245 COOKEVILLE TN (134263)
--- chan: 245

WLTD-LP Ch 264 DICKSON TN (135070)
--- chan: 264

WENV-LP Ch 247 GAINESBORO TN (134993)
--- chan: 247

WLCD-LP Ch 254 JACKSON TN (134022)
--- chan: 254

WSAB-LP Ch 223 JAMESTOWN TN (135001)
--- chan: 223

WGND-LP Ch 269 LAFOLLETTE TN (135282)
--- chan: 269

WLNT-LP Ch 241 LOUDON TN (133392)
--- chan: 241

WSOJ-LP Ch 273 MCMINNVILLE TN (133410)
--- chan: 273

WTAZ-LP Ch 252 NEW TAZEWELL TN (133423)
--- chan: 252

WQTR-LP Ch 291 SAVANNAH TN (134572)
--- chan: 291

WMTN-LP Ch 226 SEWANEE TN (135206)
--- chan: 226

WSPE-LP Ch 226 SPENCER TN (135776)
--- chan: 226

KYRE-LP Ch 224 BRECKENRIDGE TX (133930)
--- chan: 224

KXAL-LP Ch 284 CHALK HILL COMMUNITY TX (134419)
--- chan: 284

KORG-LP Ch 287 CLEVELAND TX (134879)
--- chan: 287

KYLP-LP Ch 268 GREENVILLE TX (135673)
--- chan: 268

KPIA-LP Ch 273 HUNTSVILLE TX (133499)
--- chan: 273

KWSP-LP Ch 285 KERRVILLE TX (135266)
--- chan: 285

KHSP-LP Ch 283 KILLEEN TX (135359)
--- chan: 283

KHTL-LP Ch 284 KILLEEN TX (135367)
--- chan: 284

KEOE-LP Ch 266 LUFKIN TX (135019)
--- chan: 266

KKLK-LP Ch 255 MARFA TX (133266)
--- chan: 255

KACD-LP Ch 231 MIDLAND TX (135434)
--- chan: 231

KNOB-LP Ch 260 MINERAL WELLS TX (134171)
--- chan: 260

KXDX-LP Ch 239 MOUNT PLEASANT TX (133362)
--- chan: 239

KKXI-LP Ch 222 MOUNT PLEASANT TX (133429)
--- chan: 222

KOLF-LP Ch 264 PLAINVIEW TX (133507)
--- chan: 264

KSGS-LP Ch 260 RIO GRANDE CITY TX (133614)
--- chan: 260

KURT-LP Ch 264 STEPHENVILLE TX (134097)
--- chan: 264

KVVT-LP Ch 236 SULPHUR SPRINGS TX (133969)
--- chan: 236

KXVX-LP Ch 256 SULPHUR SPRINGS TX (135743)
--- chan: 256

KGTD-LP Ch 238 UVALDE TX (135416)
--- chan: 238

KWRA-LP Ch 244 WACO TX (135565)
--- chan: 244

KXZY-LP Ch 264 WACO TX (134259)
--- chan: 264

KXWF-LP Ch 300 WICHITA FALLS TX (135595)
--- chan: 300

KXVI-LP Ch 232 WINFIELD TX (133427)
--- chan: 232

KAAJ-LP Ch 280 MONTICELLO UT (123728)
--- chan: 280

KTIM-LP Ch 237 ST. GEORGE UT (124360)
--- chan: 237

WLMP-LP Ch 274 FREDERICKSBURG VA (126648)
--- chan: 274

WXEZ-LP Ch 266 HILLSVILLE VA (127052)
--- chan: 266

WCFC-LP Ch 229 RICHMOND VA (126464)
--- chan: 229

WRKE-LP Ch 262 SALEM VA (124498)
--- chan: 262

WCCA-LP Ch 228 SCOTTSVILLE VA (126026)
--- chan: 228

WTJC-LP Ch 245 CHARLOTTE AMALIE VI (135689)
--- chan: 245

WJPL-LP Ch 221 BARRE VT (135758)
--- chan: 221

WOOL-LP Ch 261 BELLOWS FALLS VT (135150)
--- chan: 261

WVEW-LP Ch 299 BRATTLEBORO VT (134542)
--- chan: 299

WRAN-LP Ch 261 RANDOLPH VT (133815)
--- chan: 261

WMTZ-LP Ch 239 RUTLAND VT (134309)
--- chan: 239

KEIT-LP Ch 264 COLVILLE WA (133042)
--- chan: 264

KYAO-LP Ch 208 OCEAN SHORES WA (133879)
--- chan: 208

KTYG-LP Ch 221 ONALASKA WA (135319)
--- chan: 221

KGTC-LP Ch 226 OROVILLE WA (134798)
--- chan: 226

KETL-LP Ch 263 REPUBLIC WA (135216)
--- chan: 263

KYYR-LP Ch 250 YAKIMA WA (135089)
--- chan: 250

WJLM-LP Ch 245 ALTOONA WI (131883)
--- chan: 245

WRNC-LP Ch 249 ASHLAND WI (131525)
--- chan: 249

WWMD-LP Ch 238 ASHLAND WI (132272)
--- chan: 238

WHRC-LP Ch 247 CHIPPEWA FALLS WI (132228)
--- chan: 247

WPGR-LP Ch 289 CLEAR LAKE WI (132243)
--- chan: 289

WIEC-LP Ch 274 EAU CLAIRE WI (132418)
--- chan: 274

WRFP-LP Ch 270 EAU CLAIRE WI (131963)
--- chan: 270

WHYS-LP Ch 242 EAU CLAIRE WI (131585)
--- chan: 242

WIXL-LP Ch 246 MADISON WI (132239)
--- chan: 246

WIDE-LP Ch 256 MADISON WI (132183)
--- chan: 256

WLWR-LP Ch 299 MARINETTE WI (131536)
--- chan: 299

WRJF-LP Ch 269 MENOMONIE WI (132039)
--- chan: 269

WFAQ-LP Ch 225 MUKWONAGO WI (131376)
--- chan: 225

WRZC-LP Ch 222 RED CLIFF WI (131421)
--- chan: 222

WWJP-LP Ch 269 RICE LAKE WI (131888)
--- chan: 269

WRGW-LP Ch 233 SHAWANO WI (132173)
--- chan: 233

WLBI-LP Ch 296 TOMAHAWK WI (132459)
--- chan: 296

WVPP-LP Ch 250 BECKLEY WV (134453)
--- chan: 250

WDUQ-LP Ch 231 BENWOOD WV (133551)
--- chan: 231

WDTF-LP Ch 300 BERKELEY SPRINGS WV (135458)
--- chan: 300

WYAP-LP Ch 269 CLAY WV (133896)
--- chan: 269

WQAZ-LP Ch 253 EDMOND WV (134635)
--- chan: 253

WBWG-LP Ch 256 FAIRMONT WV (135411)
--- chan: 256

WSPW-LP Ch 249 PARKERSBURG WV (134785)
--- chan: 249

WHMG-LP Ch 254 PURGITSVILLE WV (134476)
--- chan: 254

WVBL-LP Ch 260 SALEM WV (135335)
--- chan: 260

WYRC-LP Ch 222 SPENCER WV (133971)
--- chan: 222

KSLW-LP Ch 258 BUFFALO WY (126655)
--- chan: 258

KFCB-LP Ch 286 DOUGLAS WY (126692)
--- chan: 286

KCOV-LP Ch 239 GILLETTE WY (125905)
--- chan: 239

KOCA-LP Ch 228 LARAMIE WY (125800)
--- chan: 228

KLWR-LP Ch 287 POWELL WY (126226)
--- chan: 287

The following stations may be able to upgrade but will require a channel change to first adjacent of IF. (REC proposing these be minor changes.):

WALW-LP Ch 252 MOULTON AL (133800)
--- chan: 251

KHBR-LP Ch 244 DECATUR AR (134997)
--- chan: 297

KDUA-LP Ch 243 ROGERS AR (134998)
--- chan: 242

KIHW-LP Ch 281 WEST HELENA AR (135189)
--- chan: 280 282

KNYO-LP Ch 299 FORT BRAGG CA (123415)
--- chan: 298 246

KRBS-LP Ch 296 OROVILLE CA (124347)
--- chan: 295

KWVP-LP Ch 224 WASCO CA (124267)
--- chan: 278

KCIG-LP Ch 259 CRAIG CO (131681)
--- chan: 205

KGUS-LP Ch 256 GUNNISON CO (131690)
--- chan: 257

KSJC-LP Ch 223 SILVERTON CO (132167)
--- chan: 222 224 276 277

WWBW-LP Ch 245 HIGGANUM CT (126920)
--- chan: 246

WAPQ-LP Ch 240 AVON PARK FL (135640)
--- chan: 241 293

WSVB-LP Ch 236 CHIEFLAND FL (134859)
--- chan: 237 289 290

WVVD-LP Ch 243 EAST TAMPA FL (135008) *
--- chan: 242

WLGM-LP Ch 237 EDGEWATER FL (134638)
--- chan: 236

WORZ-LP Ch 282 KEY LARGO FL (134502)
--- chan: 281

WMJB-LP Ch 299 LAKE CITY FL (135542)
--- chan: 300

WMLO-LP Ch 246 LIVE OAK FL (133781)
--- chan: 247

WGRV-LP Ch 226 MELBOURNE FL (135636)
--- chan: 225

WSLR-LP Ch 243 SARASOTA FL (132828)
--- chan: 242

WGSE-LP Ch 239 SEBRING FL (135746)
--- chan: 238 293

WBUE-LP Ch 241 COLUMBUS GA (124445)
--- chan: 242

WLVN-LP Ch 246 FORT VALLEY GA (124406)
--- chan: 300

KAKU-LP Ch 203 KAHULUI HI (132284)
--- chan: 256

KEAO-LP Ch 218 WAILUKU HI (131576)
--- chan: 271

KDDI-LP Ch 275 ADAIR IA (133659)
--- chan: 276

KULT-LP Ch 233 CEDAR FALLS IA (134585)
--- chan: 234 286

KCRM-LP Ch 244 MARSHALLTOWN IA (133311)
--- chan: 245

KPLL-LP Ch 235 LEWISTON ID (132474)
--- chan: 234

KAGF-LP Ch 288 TWIN FALLS ID (126205)
--- chan: 287 235

WJHP-LP Ch 277 CARMI IL (126492)
--- chan: 278

WZJM-LP Ch 260 FREEBURG IL (125617)
--- chan: 259

WGRG-LP Ch 263 GENESEO IL (126996)
--- chan: 264

WHUM-LP Ch 253 COLUMBUS IN (124012)
--- chan: 254

KODC-LP Ch 271 DODGE CITY KS (126868)
--- chan: 270

WRVG-LP Ch 229 GEORGETOWN KY (134608)
--- chan: 228 230

WXLN-LP Ch 227 SHELBYVILLE KY (135254)
--- chan: 228

KHBL-LP Ch 245 HANNIBAL MO (131710)
--- chan: 244 246

KYHO-LP Ch 295 POPLAR BLUFF MO (132156)
--- chan: 241

KBAS-LP Ch 252 BASIN MT (134663)
--- chan: 251

KMEA-LP Ch 224 BOZEMAN MT (135715)
--- chan: 223

KOFK-LP Ch 252 BOZEMAN MT (133296)
--- chan: 251

KHFG-LP Ch 270 HELENA MT (131415)
--- chan: 269

KANB-LP Ch 272 KALISPELL MT (135312)
--- chan: 273

KJRZ-LP Ch 287 LIBBY MT (133947)
--- chan: 234 233

KWLY-LP Ch 285 MISSOULA MT (135554)
--- chan: 286

KWHP-LP Ch 283 PLAINS MT (134935)
--- chan: 230

KDGZ-LP Ch 252 TOWNSEND MT (134523)
--- chan: 251

WPVM-LP Ch 278 ASHEVILLE NC (133357)
--- chan: 277

WDJD-LP Ch 229 ELIZABETHTOWN NC (135086)
--- chan: 228

WSER-LP Ch 261 LENOIR NC (134093)
--- chan: 262

WWGT-LP Ch 265 LINCOLNTON NC (134417)
--- chan: 264 266

KGIA-LP Ch 225 GRAND ISLAND NE (135508)
--- chan: 224

KCMG-LP Ch 261 LOVINGTON NM (134891)
--- chan: 262 208 207

KFSL-LP Ch 258 FOSSIL OR (134334)
--- chan: 257 259

KCUW-LP Ch 282 PENDLETON OR (134558)
--- chan: 281

KLLF-LP Ch 294 ROSEBURG OR (135480)
--- chan: 295

WLRE-LP Ch 225 ELLOREE SC (131836)
--- chan: 226

WXOR-LP Ch 272 GREENWOOD SC (132443)
--- chan: 271

WZKQ-LP Ch 287 HODGES SC (132314)
--- chan: 286

KPGN-LP Ch 284 PIERRE SD (132351)
--- chan: 285 230

KFND-LP Ch 246 RAPID CITY SD (132282)
--- chan: 245

WCVD-LP Ch 294 CORDOVA TN (133598)
--- chan: 293

WJCR-LP Ch 235 JASPER TN (135232)
--- chan: 234

WIAM-LP Ch 266 KNOXVILLE TN (135475)
--- chan: 265

WRFN-LP Ch 255 PASQUO TN (135643)
--- chan: 256

KVVO-LP Ch 231 ABILENE TX (134186)
--- chan: 232

KHIA-LP Ch 249 BRUNDAGE TX (135274)
--- chan: 248

KACB-LP Ch 245 COLLEGE STATION TX (133248)
--- chan: 244

KWSK-LP Ch 224 DAINGERFIELD TX (134527)
--- chan: 223

KERC-LP Ch 229 KERMIT TX (135149)
--- chan: 282 283

KDOL-LP Ch 241 LIVINGSTON TX (134491)
--- chan: 240

KCYP-LP Ch 249 MISSION TX (135621)
--- chan: 250

KLNA-LP Ch 263 PITTSBURG TX (135706)
--- chan: 262

KRYH-LP Ch 284 TEMPLE TX (135541)
--- chan: 231

KVLJ-LP Ch 258 VICTORIA TX (134296)
--- chan: 257

KZLH-LP Ch 239 ZAPATA TX (135520)
--- chan: 238

WJSY-LP Ch 241 NEWPORT VT (134559)
--- chan: 240

KXPB-LP Ch 206 PACIFIC BEACH WA (132687)
--- chan: 260

WXXD-LP Ch 225 BELOIT WI (132407)
--- chan: 226 279

WGAG-LP Ch 226 PRINCETON WV (134607)
--- chan: 227

KJHR-LP Ch 261 TETON VILLAGE WY (126477)
--- chan: 262

The following stations may be able to upgrade on their channel but a second adjacent channel waiver may be needed:

WQXD-LP Ch 250 ATHENS AL (135547)

KHSA-LP Ch 297 HOT SPRINGS AR (135443)

KGPS-LP Ch 254 KINGMAN AZ (134768)

KRIM-LP Ch 242 PAYSON AZ (134059)

KWOL-LP Ch 279 ARROYO GRANDE CA (124448)

KQIP-LP Ch 296 CHICO CA (124250)

KMKE-LP Ch 251 EUREKA CA (124536)

KYRR-LP Ch 227 NEVADA CITY CA (123766)

KOCI-LP Ch 268 NEWPORT BEACH CA (124219)

KRGR-LP Ch 267 PARADISE CA (124092)

KMZG-LP Ch 241 DURANGO CO (132236)

KEAE-LP Ch 300 EAGLE CO (131644)

KREV-LP Ch 284 ESTES PARK CO (131930)

KMTE-LP Ch 256 MONTROSE CO (131688)

WACC-LP Ch 299 ENFIELD CT (127007)

WFLP-LP Ch 254 COLLIER CO REST AREA FL (134910)

WFBB-LP Ch 262 GLEN ST MARY FL (134226)

WRDJ-LP Ch 228 MERRITT ISLAND FL (135626)

WUFR-LP Ch 274 UMATILLA FL (134390)

WPPP-LP Ch 264 ATHENS GA (124235)

WHLB-LP Ch 283 CARTERSVILLE GA (123667)

KJHI-LP Ch 297 HONOKAA HI (132268)

KQOP-LP Ch 234 CHARLES CITY IA (133434)

KBOL-LP Ch 261 WATERLOO IA (134517)

WRFU-LP Ch 283 URBANA IL (126154)

WYIR-LP Ch 245 BAUGH CITY IN (123501)

WQHU-LP Ch 288 HUNTINGTON IN (124382)

WNRL-LP Ch 290 LIGONIER IN (123439)

WJPB-LP Ch 256 MUNCIE IN (124356)

WITW-LP Ch 228 VALPARAISO IN (124357)

WWCC-LP Ch 247 WEST LAFAYETTE IN (123509)

WPJI-LP Ch 235 HOPKINSVILLE KY (135616)

WBRJ-LP Ch 247 BATON ROUGE LA (124170)

KQAR-LP Ch 296 SHREVEPORT LA (124872)

WJZF-LP Ch 246 STANDISH ME (123618)

WMRP-LP Ch 284 MUNDY TOWNSHIP MI (126791)

KDMC-LP Ch 279 CAPE GIRARDEAU MO (132020)

WSEQ-LP Ch 225 HUDSON NC (134206)

WHGW-LP Ch 262 MORGANTON NC (135296)

WEJM-LP Ch 291 MOUNT ZION NC (135060)

WLRF-LP Ch 232 BINGHAMTON NY (132127)

WWOC-LP Ch 249 BOWLING GREEN OH (132390)

WJFY-LP Ch 282 NEWARK OH (132035)

WJFZ-LP Ch 281 ZANESVILLE OH (132019)

KAMG-LP Ch 221 ENID OK (123923)

KPOL-LP Ch 295 CANYONVILLE OR (135061)

KLYF-LP Ch 264 COQUILLE OR (134965)

KHRB-LP Ch 222 HARRISBURG OR (134838)

KWPB-LP Ch 254 NEWPORT OR (133784)

WKCV-LP Ch 278 LA PLUME PA (133966)

WVHO-LP Ch 233 NANTICOKE PA (133888)

WIGV-LP Ch 243 PROVIDENCE RI (124214) *

WIAR-LP Ch 263 HILTON HEAD ISLAND SC (132391)

WLXM-LP Ch 300 LEXINGTON SC (131555)

WSCM-LP Ch 261 MONCKS CORNER SC (131441)

KBCP-LP Ch 300 BROOKSHIRE TX (134264)

KXPW-LP Ch 294 GEORGETOWN TX (133411)

KCYR-LP Ch 268 KERRVILLE TX (134081)

KGOD-LP Ch 231 TENAHA TX (132836)

KWBR-LP Ch 289 ST. GEORGE UT (123781)

WRMV-LP Ch 233 MADISON HEIGHTS VA (126573)

WRIR-LP Ch 247 RICHMOND VA (126872)

WRRW-LP Ch 273 WILLIAMSBURG VA (125974)

KAHS-LP Ch 293 ABERDEEN WA (134347)

KWEW-LP Ch 242 WENATCHEE WA (135720)

WCWL-LP Ch 278 CLEARWATER LAKE WI (132491)

WTSW-LP Ch 242 MANITOWOC WI (132217)

WOCT-LP Ch 270 OSHKOSH WI (131805)

WGHF-LP Ch 229 SUPERIOR WI (132409)

WNRB-LP Ch 227 WAUSAU WI (131637)

KJHB-LP Ch 249 JACKSON WY (126884)

The following stations may be able to upgrade but will have to change to a different channel (fully spaced):

WPMR-LP Ch 239 RUSSELLVILLE AL (134788)
--- chan: 214

KWBB-LP Ch 288 BIG BEAR LAKE CA (124259)
--- chan: 231

KGDM-LP Ch 288 MERCED CA (124864)
--- chan: 275 287 298

KCAN-LP Ch 276 NEEDLES CA (124874)
--- chan: 258 291

KOCC-LP Ch 268 OXNARD CA (124258)
--- chan: 257

KDEA-LP Ch 256 DELTA CO (131687)
--- chan: 274

WVDV-LP Ch 285 SEBRING FL (134104)
--- chan: 298

WHTR-LP Ch 245 WAKULLA COUNTY FL (135403)
--- chan: 222

KCOF-LP Ch 273 CAPTAIN COOK HI (132315)
--- chan: 201 208 210 211 213 239 241 248 253 259 261 263 265 283 285 294 296 297

KOPO-LP Ch 205 PAIA HI (131709)
--- chan: 255 267 271

KFMG-LP Ch 256 DES MOINES IA (134908)
--- chan: 238

KDRA-LP Ch 231 DES MOINES IA (132964)
--- chan: 238

KGVC-LP Ch 231 DES MOINES IA (133227)
--- chan: 238

WPDQ-LP Ch 230 MT. CARMEL IL (126788)
--- chan: 238

WQJC-LP Ch 300 QUINCY IL (125912)
--- chan: 255 262 270

WWPO-LP Ch 231 OAKLAND CITY IN (123664)
--- chan: 255

WSHI-LP Ch 253 SHELBYVILLE IN (124813)
--- chan: 255

WSBL-LP Ch 251 SOUTH BEND IN (124343)
--- chan: 228

KSMK-LP Ch 252 ST. MARYS KS (126876)
--- chan: 230 287

WGIO-LP Ch 300 INDEPENDENCE KY (135044)
--- chan: 238

WXYR-LP Ch 283 MONTICELLO KY (134825)
--- chan: 250 276

WFKC-LP Ch 249 WALTON KY (135059)
--- chan: 238

KELB-LP Ch 263 LAKE CHARLES LA (123546)
--- chan: 255

WXSU-LP Ch 242 SALISBURY MD (124825)
--- chan: 263

WGLN-LP Ch 228 CEDAR LAKE MI (127139)
--- chan: 226

WEEH-LP Ch 263 HART MI (126128)
--- chan: 218 246 258 280 290

WQOS-LP Ch 255 MOUNT PLEASANT MI (127095)
--- chan: 299

WUSG-LP Ch 204 CAMBRIDGE MN (127133)
--- chan: 293

KCAH-LP Ch 300 CARTHAGE MO (131696)
--- chan: 242

KVTS-LP Ch 300 REPUBLIC MO (132128)
--- chan: 251

WGWT-LP Ch 279 HOUSTON MS (126174)
--- chan: 237 268

KFHW-LP Ch 266 BILLINGS MT (134746)
--- chan: 264

KEAC-LP Ch 291 CARDWELL MT (134668)
--- chan: 243 250 251 261 274 282

KCTQ-LP Ch 268 CHARLO MT (135572)
--- chan: 238

KWEP-LP Ch 279 ELK PARK MT (134671)
--- chan: 241 274

KCTJ-LP Ch 296 FINLEY POINT MT (135348)
--- chan: 201 289

KXZI-LP Ch 270 KALISPELL MT (134546)
--- chan: 249 250 300

KCTG-LP Ch 251 TURTLE LAKE MT (135625)
--- chan: 201 238 289

KNDS-LP Ch 242 FARGO ND (133106)
--- chan: 201 232

WLLO-LP Ch 275 LONDONDERRY NH (125532)
--- chan: 236

KROZ-LP Ch 290 HOBBS NM (133891)
--- chan: 203 207

KAVS-LP Ch 230 FALLON NV (126241)
--- chan: 223 224 226 228 241 264 270 300

WAPP-LP Ch 262 WESTHAMPTON NY (132494)
--- chan: 283

WBWH-LP Ch 257 BLUFFTON OH (131338)
--- chan: 266

WTPS-LP Ch 231 NAPOLEON OH (131752)
--- chan: 281

WRPO-LP Ch 228 RUSSELLS POINT OH (131601)
--- chan: 295

KEIF-LP Ch 284 ENID OK (124554)
--- chan: 260 265

KJRM-LP Ch 227 MCALESTER OK (124576)
--- chan: 207 224

WLHR-LP Ch 290 MARYVILLE TN (133983)
--- chan: 265

WQFR-LP Ch 300 SOMERVILLE TN (135481)
--- chan: 269 271

WTRL-LP Ch 236 VONORE TN (135624)
--- chan: 245

KDSH-LP Ch 286 BORGER TX (135261)
--- chan: 297

KCER-LP Ch 290 CISCO TX (134550)
--- chan: 277 281

KSAP-LP Ch 296 PORT ARTHUR TX (133414)
--- chan: 244

KAGA-LP Ch 282 SAN ANGELO TX (135074)
--- chan: 251

WEVT-LP Ch 251 ENOSBURG FALLS VT (135390)
--- chan: 242

KGRU-LP Ch 241 ELLENSBURG WA (134590)
--- chan: 286

KOSW-LP Ch 217 OCEAN SHORES WA (134605)
--- chan: 252 254 281 292

WPCA-LP Ch 239 AMERY WI (131741)
--- chan: 226

WLCJ-LP Ch 223 MARINETTE WI (132187)
--- chan: 233

WPHF-LP Ch 287 MENOMONIE WI (132224)
--- chan: 244

WDYD-LP Ch 265 MERRILL WI (131630)
--- chan: 241 296

WMCC-LP Ch 289 SPENCER WV (133540)
--- chan: 264 266

The following stations may be able to upgrade but will have to change to a different channel (interference channel):

WQJJ-LP Ch 249 JASPER AL (135721)
--- chan: 236 237

KSWH-LP Ch 260 ARKADELPHIA AR (134820)
--- chan: 255 256 273

KOZR-LP Ch 275 GENTRY AR (135278)
--- chan: 296 297

KTPV-LP Ch 245 PRAIRIE GROVE AR (133198)
--- chan: 248 283

KSSQ-LP Ch 272 SILOAM SPRINGS AR (135619)
--- chan: 297

KCMA-LP Ch 253 PAYSON AZ (134141)
--- chan: 234 244

KWSS-LP Ch 294 SCOTTSDALE AZ (134485) *
--- chan: 230 242

KWXL-LP Ch 254 TUCSON AZ (133181)
--- chan: 232

KPTG-LP Ch 268 ADELANTO CA (124322)
--- chan: 284 296

KDRT-LP Ch 268 DAVIS CA (123794)
--- chan: 226

KSTG-LP Ch 268 LODI CA (124860)
--- chan: 227 238

KEQP-LP Ch 295 MODESTO CA (124370)
--- chan: 291

KGIG-LP Ch 285 SALIDA CA (123802)
--- chan: 291

KAMV-LP Ch 270 BRIGHTON CO (131484)
--- chan: 275

KWIR-LP Ch 296 COLORADO SPRINGS CO (132100)
--- chan: 229

KLEV-LP Ch 300 LEADVILLE CO (131652)
--- chan: 222 233 235 236 256 260 264 288 292

KPCT-LP Ch 294 PARACHUTE CO (131665)
--- chan: 290 292

KSBP-LP Ch 266 PARACHUTE CO (131912)
--- chan: 280 284 291

WCSE-LP Ch 261 LEDYARD CT (126693)
--- chan: 225

WRBG-LP Ch 300 MILLSBORO DE (131943)
--- chan: 243 257

WEKJ-LP Ch 244 CHASSAHOWITZKA FL (133416)
--- chan: 223 275 276 300

WLPM-LP Ch 239 CHRISTMAS FL (135433)
--- chan: 230

WIKD-LP Ch 256 DAYTONA BEACH FL (133962)
--- chan: 236 273 274 296

WRWS-LP Ch 256 DAYTONA BEACH FL (134386)
--- chan: 236 296

WBOF-LP Ch 290 FORT PIERCE FL (134028)
--- chan: 264

WVFP-LP Ch 234 GAINESVILLE FL (135063)
--- chan: 290

WERF-LP Ch 239 GAINESVILLE FL (134753)
--- chan: 290

WGLJ-LP Ch 234 GAINESVILLE FL (135119)
--- chan: 290

WGOT-LP Ch 234 GAINESVILLE FL (133958)
--- chan: 290

WCFQ-LP Ch 244 INVERNESS FL (133419)
--- chan: 285

WJTW-LP Ch 262 JUPITER FL (133909)
--- chan: 245

WIMR-LP Ch 243 MCINTOSH FL (133396)
--- chan: 250

WJPP-LP Ch 261 PALM CITY FL (134533)
--- chan: 264

WEHR-LP Ch 261 PORT SAINT LUCIE FL (135196)
--- chan: 264

WJTR-LP Ch 274 ASHBURN GA (124451)
--- chan: 255 276

WDRW-LP Ch 300 ATHENS GA (123738)
--- chan: 227 229 233 288

WLOJ-LP Ch 275 CALHOUN GA (124819)
--- chan: 251 281 299

WGGR-LP Ch 237 CARROLLTON GA (124527)
--- chan: 265 284

WBLY-LP Ch 268 SYCAMORE GA (123596)
--- chan: 255

KLUI-LP Ch 247 KULA HI (132241)
--- chan: 255 256 257 267 268 269 270

WJAF-LP Ch 279 CENTRALIA IL (126517)
--- chan: 258 275

WHJG-LP Ch 227 ROCKFORD IL (126983)
--- chan: 270

WQSW-LP Ch 263 FORT WAYNE IN (124483)
--- chan: 239

WIOE-LP Ch 252 WARSAW IN (123939)
--- chan: 300

WFBR-LP Ch 230 MT WASHINGTON KY (135114)
--- chan: 245 292

WLPV-LP Ch 300 GREENFIELD MA (132955)
--- chan: 222

WMCB-LP Ch 300 GREENFIELD MA (134902)
--- chan: 222

KSDC-LP Ch 235 CENTRALIA MO (132448)
--- chan: 281

KLJE-LP Ch 300 COLUMBIA MO (132417)
--- chan: 298

KJTR-LP Ch 269 ROLLA MO (132400)
--- chan: 233 234 240 242 246 247 267

KCTD-LP Ch 250 DIXON MT (135470)
--- chan: 230 232 238 239 286

WFWC-LP Ch 257 FREMONT NC (134126)
--- chan: 296

WMTG-LP Ch 201 MOUNT GILEAD NC (135479)
--- chan: 234 268 288 289 290

WEHB-LP Ch 252 WADESBORO NC (134857)
--- chan: 233 234 248 256 264 269 274 289

WSCA-LP Ch 291 PORTSMOUTH NH (126863)
--- chan: 241

WMRH-LP Ch 269 LINWOOD NJ (134532)
--- chan: 300

KYHW-LP Ch 234 GARDNERVILLE NV (126654)
--- chan: 227

WNAR-LP Ch 262 ARCADE NY (132453)
--- chan: 296

WELV-LP Ch 300 ELLENVILLE NY (131711)
--- chan: 229 230 281 294

WOGM-LP Ch 284 JAMESTOWN NY (131804)
--- chan: 219

WMUD-LP Ch 207 MORIAH NY (132393)
--- chan: 234 235 236 265 297

WNYP-LP Ch 254 RIPLEY NY (131558)
--- chan: 247 268 282 288 297 298 299 300

WCYC-LP Ch 286 LONDON OH (131831)
--- chan: 253 270

WZLP-LP Ch 239 LOUDONVILLE OH (131748)
--- chan: 241

KZAS-LP Ch 236 HOOD RIVER OR (133172)
--- chan: 260

KZSO-LP Ch 293 SISTERS OR (133837)
--- chan: 222 228 272

WXNM-LP Ch 240 ERIE PA (135021)
--- chan: 300

WSUB-LP Ch 244 ASHAWAY RI (124671)
--- chan: 296

WPLS-LP Ch 240 GREENVILLE SC (132033)
--- chan: 269

WHZK-LP Ch 249 GREENWOOD SC (131832)
--- chan: 239 240 260 269 270 284 285 294

WYMA-LP Ch 250 CALHOUN TN (135022)
--- chan: 246 297

WUCP-LP Ch 291 FARRAGUT TN (133919)
--- chan: 209 265 274

KDLP-LP Ch 284 ACE TX (134601)
--- chan: 240 242 270

KJHV-LP Ch 242 KILLEEN TX (135336)
--- chan: 232 236 279

KFGG-LP Ch 270 MARBLE FALLS TX (134870)
--- chan: 258 259 261

KCSA-LP Ch 239 SAN ANGELO TX (134304)
--- chan: 273

KCCP-LP Ch 272 SOUTH PADRE ISLAND TX (135175)
--- chan: 269 291

WKJV-LP Ch 293 BRISTOL VA (126574)
--- chan: 261 288 289

WDER-LP Ch 252 DERBY VT (133838)
--- chan: 258 259 287

WYTC-LP Ch 206 HYDE PARK VT (134111)
--- chan: 243 244 245 246 287

WMRW-LP Ch 236 WARREN VT (133683)
--- chan: 232

KGHO-LP Ch 253 HOQUIAM WA (134721)
--- chan: 260

The following stations may be able to upgrade but will have to change to a different channel and a second adjacent waiver may be needed:

KONR-LP Ch 285 ANCHORAGE AK (124266)
--- chan: 227 231 232 291

WUAC-LP Ch 277 TUSCALOOSA AL (133695)
--- chan: 227 267

WTUS-LP Ch 277 TUSCALOOSA AL (134739)
--- chan: 227 267

KRLY-LP Ch 300 ALPINE CA (124224)
--- chan: 266 277 281 291

KKDS-LP Ch 249 EUREKA CA (124327)
--- chan: 234 244 270 271 286

KFXM-LP Ch 244 LANCASTER CA (124198)
--- chan: 224

KWVS-LP Ch 268 MALIBU CA (124207)
--- chan: 248 256

KHHS-LP Ch 298 SAN DIEGO CA (124381) *
--- chan: 249 266 291 295

KNJR-LP Ch 300 THOUSAND OAKS CA (123947)
--- chan: 256

KNFS-LP Ch 251 TULARE CA (124351)
--- chan: 222 223 237

KAPU-LP Ch 284 WATSONVILLE CA (124331)
--- chan: 247 260

KBDL-LP Ch 300 CARBONDALE CO (131677)
--- chan: 267

KDVW-LP Ch 265 MONTROSE CO (132045)
--- chan: 268 272 291

WZPH-LP Ch 244 DADE CITY FL (133204)
--- chan: 225 237 256

WFHA-LP Ch 231 MELBOURNE FL (134001)
--- chan: 224 225 276 288

WCPL-LP Ch 238 MERRITT ISLAND FL (133184)
--- chan: 204 220 245 268 288

WSRD-LP Ch 226 ALBANY GA (124853)
--- chan: 221 236 244 245 260 267 280 281 297

WAAK-LP Ch 234 BOYNTON GA (124182)
--- chan: 245

WBFC-LP Ch 279 BOYNTON GA (124312)
--- chan: 245 262 298

WPCG-LP Ch 300 CANTON GA (124395)
--- chan: 223 227 229 244 251 270 279

WCUA-LP Ch 270 PEORIA IL (126290)
--- chan: 201 208 220 229 249 251 258

WVRG-LP Ch 230 CRAWFORDSVILLE IN (124827)
--- chan: 241

WCFY-LP Ch 274 EVANSVILLE IN (124387)
--- chan: 239 249 255 256 278 279

WJJD-LP Ch 267 KOKOMO IN (123669)
--- chan: 231 232 248 255 261 265 285 293

WVLP-LP Ch 252 VALPARAISO IN (123821)
--- chan: 276

WFHS-LP Ch 224 FERN CREEK KY (135516)
--- chan: 222 241 245 246 261 292 293

WXBH-LP Ch 224 LOUISVILLE KY (134599)
--- chan: 222 241 245 246 261 292 293

WTQT-LP Ch 235 BATON ROUGE LA (124366)
--- chan: 226 253 254 262 266 270 271 290 291 295

KOCZ-LP Ch 279 OPELOUSAS LA (123513)
--- chan: 225 227 231 235 236 241 258 298

WBCR-LP Ch 249 GREAT BARRINGTON MA (135676)
--- chan: 245 297

WREA-LP Ch 285 HOLYOKE MA (134302)
--- chan: 273

WXOJ-LP Ch 277 NORTHAMPTON MA (133520)
--- chan: 273 299

WEES-LP Ch 300 OCEAN CITY MD (123612)
--- chan: 226 242 244 258 271 275 292 293 297

WLEZ-LP Ch 279 JACKSON MS (126684)
--- chan: 232 236 251 252 261 273 292 296 300

WBYJ-LP Ch 250 BURLINGTON NC (134952)
--- chan: 228 256 260 279 283 300

WCOM-LP Ch 278 CHAPEL HILL NC (135187)
--- chan: 216 228

WICE-LP Ch 246 HENDERSONVILLE NC (134678)
--- chan: 221 239

WFHC-LP Ch 247 HENDERSONVILLE NC (135228)
--- chan: 221 225 231 239

WJOF-LP Ch 250 LIBERTY NC (134948)
--- chan: 228 256 260 264 300

WVDJ-LP Ch 300 RALEIGH NC (133917)
--- chan: 228 232 239 277 278

WEOM-LP Ch 276 THOMASVILLE NC (135688)
--- chan: 220 224 243 256 264 268 269 286 287 291 295 296

WNHN-LP Ch 234 CONCORD NH (126127)
--- chan: 237 246 270 274

WKEG-LP Ch 284 LIMESTONE NY (131940)
--- chan: 224 242 246 250 263

WVQC-LP Ch 239 CINCINNATI OH (132345)
--- chan: 221 237 268 288

WCRX-LP Ch 271 COLUMBUS OH (132165) *
--- chan: 225 240

WCRS-LP Ch 271 COLUMBUS OH (132329) *
--- chan: 225 240

WINF-LP Ch 270 DELAWARE OH (132375)
--- chan: 257 296

WGJM-LP Ch 250 ENGLEWOOD OH (132271)
--- chan: 262 297

WSWO-LP Ch 248 HUBER HEIGHTS OH (131375)
--- chan: 282

WNCG-LP Ch 239 MANSFIELD OH (132055)
--- chan: 285

KCGP-LP Ch 294 GRANTS PASS OR (133956)
--- chan: 231 232 243

KQRZ-LP Ch 242 HILLSBORO OR (134266)
--- chan: 232 236 244 264 268

KKJC-LP Ch 242 MCMINNVILLE OR (135679)
--- chan: 228 232 272 288

KQSO-LP Ch 242 NEWBERG OR (135128)
--- chan: 232 256 264

KSHD-LP Ch 256 SHADY COVE OR (134026)
--- chan: 231 247 260 280 288 300

KPIK-LP Ch 275 STAYTON OR (133093)
--- chan: 248 264

KPCN-LP Ch 242 WOODBURN OR (133049)
--- chan: 232 264 288

KPVN-LP Ch 242 WOODBURN OR (134373)
--- chan: 232 264 288

WXCS-LP Ch 225 CAMBRIDGE SPRINGS PA (133366)
--- chan: 238 277 281 290

WHBI-LP Ch 226 GRANTVILLE PA (135426)
--- chan: 239 251 283

WLEB-LP Ch 226 LEBANON PA (134395)
--- chan: 284

WHMN-LP Ch 297 PLYMOUTH PA (135235)
--- chan: 248

WMXP-LP Ch 238 GREENVILLE SC (132472)
--- chan: 257 258 268 282 290 299

WWOK-LP Ch 237 GREENVILLE SC (131869)
--- chan: 221 257 258 275 299

WNMI-LP Ch 254 NORTH MYRTLE BEACH SC (132503)
--- chan: 207 219 223 245

WNGR-LP Ch 238 TIGERVILLE SC (131638)
--- chan: 221

WOOP-LP Ch 260 CLEVELAND TN (134415)
--- chan: 241 245 298

WMYU-LP Ch 259 OOLTEWAH TN (133726)
--- chan: 245 262 291

KXVR-LP Ch 300 CORPUS CHRISTI TX (134465)
--- chan: 226 236 245 246 250 254 258 262

KDRP-LP Ch 276 DRIPPING SPRINGS TX (134579)
--- chan: 231 232

KQAT-LP Ch 285 HALLSVILLE TX (133370)
--- chan: 224 231 235 239 249 291

KXZX-LP Ch 293 JUILLIARD TX (134198)
--- chan: 222 228 229 247 248 252 256 261 267 268 284 298

KZOS-LP Ch 223 SAN MARCOS TX (134127)
--- chan: 276

KOEZ-LP Ch 286 ST. GEORGE UT (123829)
--- chan: 257 258 266 270 274 293

WRPC-LP Ch 279 HAMPTON VA (125841)
--- chan: 261 265 281 285 293

WOMM-LP Ch 290 BURLINGTON VT (135702)
--- chan: 246 257 258 262 279 280 288

KYAB-LP Ch 232 ABERDEEN WA (134524)
--- chan: 209 210 231 239 243 247 251 255 286 287 291

KMRE-LP Ch 272 BELLINGHAM WA (134425)
--- chan: 231 235 239 243 247

KWPA-LP Ch 245 COUPEVILLE WA (134411)
--- chan: 284

KAVZ-LP Ch 273 DEMING WA (135120)
--- chan: 231 235 239 243 247

KZFX-LP Ch 283 FALL CITY WA (134276)
--- chan: 245 253 262 266 281 285 289 297

KLOI-LP Ch 275 LOPEZ ISLAND WA (135113)
--- chan: 272

KZLF-LP Ch 253 PULLMAN WA (133223)
--- chan: 235

KVFS-LP Ch 210 SPOKANE WA (135324)
--- chan: 218 227 231 235 239 243 249 264 268 274 278 287 298

The following stations may not be able to upgrade to LP-250:

KGIC-LP Ch 288 CORONA CA (124903)

KOWS-LP Ch 297 OCCIDENTAL CA (124420)

KSHC-LP Ch 293 ST. HELENA CA (124879)

KFSC-LP Ch 231 VISALIA CA (124319)

KVLP-LP Ch 268 VISALIA CA (123672)

KGJN-LP Ch 294 GRAND JUNCTION CO (131667)

KELS-LP Ch 284 GREELEY CO (131356)

WFEL-LP Ch 260 ANTIOCH IL (126337)

WRLR-LP Ch 252 ROUND LAKE HEIGHTS IL (125575)

WMLZ-LP Ch 300 TEMPERANCE MI (124218)

WKHP-LP Ch 235 KEENE NH (125834)

WFPC-LP Ch 287 RINDGE NH (126082)

WMDI-LP Ch 300 LAKEWOOD NJ (134469) *

WLIX-LP Ch 234 RIDGE NY (131740)

KRAD-LP Ch 235 MILLERSBURG OR (135784)

WBBY-LP Ch 262 BERWICK PA (134940)

WQDD-LP Ch 300 GIRARDVILLE PA (134862)

KOWA-LP Ch 293 OLYMPIA WA (135604)

Categories: Michi's Other Blogs

Comments filed in the 4th FNPRM

REC Networks - Tue, 05/08/2012 - 02:35

This page includes a summary of comments filed by various entities in the 4th LPFM NPRM and can be used as guidance for the writing of reply comments which are due on May 21, 2012.   This time, we will divide the document by subject matter.  Numbers in parenthesis indicate the paragraph or page numbers where this information is found.

DISCLAIMER: While you may use this as a guide, please actually read the comments of the organization we are paraphrasing as we may not catch everything they had to say or have taken something out of context and reading the full comments may give you some additional insight on their position.  We are not responsible for any omissions or errors in this summary.  This working document is used by REC to develop reply comments, but we read the comments before we reply. The comments reviewed are linked at the bottom so you can do your own review.  If you wish for us to reword our paraphrase of your organization's comments, please contact Michi Eyre at REC through the "Contact REC Networks" link above.

This is a living document that will be updated through the reply comment period.  Please check it often.

A. Third Adjacent Channel

REC: Supports a heavy schedule of announcements for the first 15-days of LPFM operation, a reduced schedule for days 16 through 30 and once per day from days 31 through 365. (6) LPFM should be allowed to co-locate with third adjacent channel stations even if the move would normally require a major change. (9)  The "New Jersey Rule" should not apply to Puerto Rico. (10) Supports the 2/10km Potential Interference Area (PIA) for translator inputs with the ability for LPFM applicants to otherwise show that the translator input will not receive interference. (14)
Amherst: "New Jersey Rule" only applies to NJ and not to PR. (17)
Arso: "New Jersey Rule" also applies to PR (3).
CF: FCC should require FX stations to upgrade their primary station information. (12)
Friend: Allow LPFM to get waiver from 3rd-adjacent station from announcement obligations. (3)
Monster: Use existing translator processes for remediation. (3)
PRP: 7(1) and 7(3) are distinct interference protection and remediation regimes.  (23) For translator inputs, information in CDBS is not complete and there should be alternative methods. (25)
Sibert: Announcements no more than once a day in the first 3 months and once per week for the last 9 months. Translators in the PIA should be allowed but have a condition they must mitigate interference in the first year of operation. LPFM over 10km from the transmitter should submit an exhibit stating compliance with the MITRE report or "that proposed in the FNPRM". (3)
Turner: Announcement and complaint process is "Russian roulette" for LPFM stations. (1)
WIBI: Proposed translator input protections are acceptable and should also include daisy-chained translators. (1) Supports alternate delivery of primary station. (1)
WSWO-LP: LCRA 7(1) and 7(3) contain conflicting direction. Prefers a single standard for all stations. (1) If the FCC adheres strictly to 74.1203, then announcements are not required. (2.1.2.2)  "New Jersey Rule" does not apply to PR. (2.1.2.4)

B. Second Adjacent Channel

REC: Congress has delegated to the FCC the authority to define "interference". (18) Since LPFM originates programming, the Living Way policy of no interference in an overlap area should not apply to LPFM but instead, the minimal population overlap in Education Information Corporation should be used. (19) Expresses concerns about the welfare of current LP100 stations on waivers in light of a statuatory examination of the definition of interference. (22) Applicants should be able to request second-adjacent waiver channel even if fully spaced channels are available. (16)
CF: Living Way should apply to LPFM. (2) Showing that there are no fully spaced channels should not be required. (3)
CMAP: Supports second adjacnet channel waivers. Directional antennas should be allowed. Allows more proposals to be approved without interference. (1)
dLR: LPFM should not be allowed to operate directional antennas. (4)
EMF: Expresses concern that many LPFM stations on 2nd-waivers may be forced to go off the air in the future and the investment made in those stations will go out the door.  EMF suggests the Commission take a "slow" approach to 2nd-waivers and to have LPFMs service the full power stations they plan to waiver on. 
Friend: Use NCE to Channel 6 standards for overlap that allows population. (1)
NAB: LCRA generally prohibits LPFM operations on second adjacent channels and they should only be available on a limited basis. (5) Degrades audio quality. (7)
NLG: Process should be similar to translator proecess. (5)
NPR: Waivers should only be considered if there are no fully spaced channels. (9)
PRP: Need a simple but flexible standard. (17) LPFM 2nd Waiver standard should be substantially identifical to translators. (17) LCRA allows contours for second adjacent in waiver cases. (18) Waiver applicants should not be required to make any showings other than 2nd adjacent channel non-interference. (19) LPFM should have flexibility to use directional antennas a variable power for addressing interference. (20)
Sibert: LPFM applicants should be allowed to demonstrate no actual interference will result to second-adjacent channel stations such as translators do today. (1) Interference does not discriminate based on licensed service or programming. (1) Directional antennas should be allowed with provisions similar to §74.1235. (1) Cost of directional antennas may limit those with the resources to use them. (1) Applicants should be able to request second-adjacent waiver channel even if fully spaced channels are available. (2)
Turner: Supports waivers. LPFM is disadvantaged. (2)
WNKR: 74.1204(d) does not comply with the LCRA as it does not take into consideration that population may eventually move into the area (1).
WSWO-LP: Standard should still account for balancing interference with loss of community service. (2.1.1)

C. Interference Mitigation

REC: LPFM should not be dumbed down because of inferior receivers and antennas in radios. (24)
Alpine: Limit interference complaints to the 60dBu service contour of the primary station. (2)
Monster: Use existing translator processes for remediation. (4)
PRP: Second adjacent channel waiver complaints should be handled similar to translators. (22)
Sibert: The FCC should set a heavy burden for those complaining of interference.  Too low of a bar would financially ruin LPFM stations. (2)
WNKR: Because of identity theft, listeners may be unwilling to give information necessary to facilitate an interference complaint. (1)

D. LP-10 and below...

REC: LP10 is spectrally inefficient.  (26) Proposed to replace with LP50. (29)
Amherst: Opposes only licensing LP100 in urban core areas. (10)
Braulick: LP10 is less restrictive than LP100. (3)
CF: LP10 is viable and may be only option for places like NYC, but it should be modified. (13)
CMAP: LP10 should be replaced and replaced with a flexible power (1 watt or more) service. (5)
CRA: Supports elimination of LP10.
dLR: LP10 is spectrally inefficent. (4)
Friend: Establish a 10 watt minimum. There is not enough power density for a 2 watt station. (2)
IBS: Supports retention of LP10.
JCPES: Supports retaining LP10 or other flexible "sub-watt" service. (4)
Leggett: Eliminating LP10 may be seen as discrimination against minority neighborhoods and could be litigated (2).
Monster: Simplify by allowing LPFM to use contour methodology from 1 to 250 watts. (2)
Nexus: LP10 has not received a fair chance but REC's LP50 is a better solution. (2)
NJBA: LP10 interference area almost 2000% larger with respect to Class B. Supports the elimination of LP10. (2)
NLG: Opposes elimination of LP10. (6)
Sibert: Supports keeping LP10. (4)
WNKR: Supports keeping LP10. (2)
WSWO-LP: Eliminate LP10, replace with "hobby broadcasting" service. (2.2.1) 

E. LP-50

REC: Proposed new LP50 service to replace LP10. (29) LP50 would be available nationwide and will not have the "subsecondary" restrictions that LP10 currently has such as being able to be "bumped" by LP100 and translators. (32)
Amherst: Supports LP50 or LP10 in urban core areas with a 1 watt minimum. If the FCC only wants to authorize one class within urban core, it should be LP50 or less. (10)
CF: Supports REC proposed LP50. (15)
NLG: Supports LP50 or flexible power levels. (6)
PRP: Supports REC proposed LP50. (26)  1 watt minimum.  (28) LPFM in urban areas can reach audiences larger than today's LP100 stations. (29)

F. LP-250

REC: LP250 should be available to new entrants, not just upgrades of existing stations. (35) Power upgrades from LP100 to LP250 should be considered a minor change as long as all other requirements of minor changes are met.  With this, LP100 stations should be permitted to upgrade to 250 before the filing winodw. (36) Opposes complete market restriction of LP250 (39).  LP250 should not be initally allowed in metro cores (30km of markets 1~20, 20km of SL mkts 21~50, REC does NOT support the restrictions on SL markets 51-100 (40)) but once applications have been filed, if a LP50/100 applicant can upgrade to 250 without creating new MX situations and other LPFM stations can also upgrade. (41)
Amherst: Supports LP250 except in urban core. Upgrading LP100s should be given a bonus point. (12)
Braulick: Supports LP250. (2)  Should not be limited to just existing stations. (2)
Brown: Supports LP250 but at 52m HAAT. (1)  LP250 should be available everywhere. (5)
CF: LP250 should be available everywhere but only after initial licensing at LP100. (16)  No applicant should be permitted to file LP250 in the window. (18)  Class changes should be minor changes. (18)
CRA: Supports LP250 outside urban core (7).
Dymoke: Exsting LP100 should be able to upgrade to 250 if spectrum available. New stations will be licensed as 100 but protected to 250.  After a 2-year "shakedown cruise", the station can then upgrade to 250. (2)
Friend: Supports LP250 in urban core. "Build and operate" statements are a regulatory departure. (1)
JCPES: Supports LP250 in urban and rural. (4)
KWMV-LP: Supports LP250. (1)
LPFMhelp: Supports 250 to 500 watts. (2)
Monster: Supports LP250. (1)
Nexus: Supports LP250 at 100m HAAT.  Supports contour spacing between LPFMs with a single class of service between 1 to 250 watts. (2)
NLG: Supports rural LP250 service. LP250 should not "crowd out" LP100. Supports FCC's market-wide proposal. (7)
NPR: Opposes LP250, claims violates LCRA legislative history. (7)  Class-A already allows 250 watt stations. (7)
PRP: Supports LP250. (30) Upgrades of existing stations should not take place until after the filing window. (30)  During window, applicants in urban core should file for 100 and then upgrade to 250 as minor mod. (32) Upgrades limited to where both LPFM stations could potentially upgrade. (32)  Does not support restricting upgrades to existing LP100 stations. (33)  Stations on second adjacent channel waivers should be allowed to upgrade. (34)
Sibert: Supports LP250 including urban core. LP250 should be allowed at 100m HAAT. It will not undermine LCRA section 3.
Turner: Supports LP250. Should equate to translator standards. (1)  Supports 250 ERP and any power and antenna height "up to the maximum that covers the 'hole' for LPFM". (3)
WNKR: Opposes LP250. "At what point does this service cease to be 'low power'?" (2). 
WQIN-LP: Supports LP250.
WSWO-LP: Supports LP250 but urban core restriction may prevent them from upgrading. (2.2.1)

G. Intermediate Frequency (IF)

REC: Supports changing the rules for LPFM and translators to define the waiver for IF to change from "less than 100 watts" to "100 watts or less". (42)
Braulick: "LPFM stations are no less needy of maximizing their coverage and should no be straddled by restrictions that do not apply to like kind services." (3)
CF: Supports removal of IF (19)
CRA: Supports the removal of IF (10).
dLR: It may be possible that IF protections are no longer required for up to 250 watts. Additional research should be done. (5)
Monster: Supports removal of IF restrictions. (2)
Nexus: IF should have been "removed from the rules long ago." (2)
NLG: Supports changing the rules for LPFM to define the waiver for IF to change from "less than 100 watts" to "100 watts or less" otherwise, only LP10 would benefit. (9)
NPR: Opposes removal of IF restrictions.  Further studies on the impacts of translators operating with the exemption should be done first. (8)
PRP: Supports changing the rules for LPFM to define the waiver for IF to change from "less than 100 watts" to "100 watts or less". (34)
Sibert: Supports removing IF for LP10 and LP100.  IF should be extended to stations operating "up to" 100 watts. (5)
WSWO-LP: Supports removal of IF protections. (2.2.2)
 

H. Native Nations (Cross-ownership & multiple ownership)

REC: Supports cross-ownership (44) and multiple-ownership(47)  when the proposed station has at least 50% of the land area of the service contour within tribal land consistent with FCC Tribal Priority policy.  Supports a selection point for Native Nations that are using LPFM as their introduction to broadcasting. (78)
Amherst: Suports multiple-ownership and cross-ownership of translators. (15)
CF: Supports tribal ownership of LPFM and Tribal Priority. (20) Cross-ownership should prove that LPFM station will serve a majority tribal (assuming vs.non-tribal) population. (20)  Supports multiple ownership. (20)  Points should be limited to proposals in tribal areas. (21)
CRA: Supports cross-ownership for not just Native Nations but all organizations. (12)  Supports multiple-ownership for Native Nations. (13)
Monster: Native Nations should be afforded every right to LPFM allocations. (3)
NLG: Supports multiple-ownership on Native Lands. (9)
NPM: Amend §73.853 to "recognize the intrinsitically 'local' nature of a Tribal applicant throughout its Tribal Lands."  Concerned about "local ownership" requirements for Tribal applicants since it is more likely they will be 20 miles away from the transmitter. (5) Supports tribal priority (points) based on "Tribal Coverage" and not service to a Native Nation "Community" and not require transmitter to be on Tribal Lands. (6) Supports relaxing multiple and cross ownership. (7)
PRP: Supports tribal priority in LPFM. (47)
Sibert: Opposes Tribal Priority.  Keeps the playing field level.  Tribal applicants should be able to place a major change application to resolve MX. (5)
Turner: Opposes multiple-ownership, "why create discrimination for the sake of giving one racial entity an upper hand over the other[?]" (2)

I. LPFM Cross-ownership of Translators

REC: Supports limited availability of cross-owned translators. (48)  Translators must relay the LPFM's primary analog signal. (50) Service contour of LPFM and translator must overlap. (51) Alternate forms of transmision (except satellite) should be permitted. (52) Cross-owned translators limited to a 7.3km service contour nationwide. (51)
Amherst: Supports cross-ownership "in general". (15)
Braulick: Supports cross-ownership.
CF: No preference but does not want promote the building of LPFM-centered translator networks. (20)
Friend: Supports cross-ownership. Should be limited to same SMSA or within 50 km of primary station. Translators may be hard to obtain and may need a "protected" window. (2)
LPFMhelp: Supports cross-ownership. (1)
Monster: Supports cross-ownership. (3)
Nexus: Supports cross-ownership. (2)
NLG: Supports cross-ownership, translator must carry LPFM signal, contours must overlap with LPFM, limited to one translator and no satellite fed. (9)
NPR: Cross-ownership undermines the local nature of LPFM. (15)
PRP: Supports limited cross-ownership. (48) Limited to one or two stations. (48)  Service contour overlap. (48)  Primary station must be LPFM. (48)  Opposes alternative delivery due to potential for abuse. (48)
Sibert: Opposes translators but would support the use of (same frequency) boosters. (5)
Turner: Supports cross-ownerhip. (2)
WNKR: Opposes. Translators not required to provide city grade service, no requirement that a translator applicant document there is an area that actually needs filling in, no interference documentation other than contour overlap needed for a CP, translators allowed to operate with power exceeding LPFM. (2)  Concerned about leap-frogging, making the LPFM the weakest link, carrying HD-2 and the local nature of LPFM replaced by a mini-network of translators (2).
WSWO-LP: Supports but translators should be allowed to originate at times. Alternative delivery should be allwoed. (2.2.2.3)

J. Consortia, Point Aggregation, Successive Licensing

REC: Does not support.  Will lead to speculation and fraud as in the previous window. (56) Also, it can be used as a discriminatory method to silence already-oppressed voices by majority applicants with more influence and resources. (57) Supports the elimination of point aggregation, partial settlements and successive licensing. (113)
Amherst: Opposes consortia. (13)
Braulick: Consortia should not receive additional points, it's still one station. (4)
Brown: Partial settlements should be allowed. (7)
BSR: Supports elimination of point aggregation (1).
CF: Opposes consortia. (22)  Has discrimination concerns. (23)
CMAP: Opposes successive licensing. (6)
NLG: Supports consortia and point aggregation. (8)
PRP: Opposes consortia. (53)  Consortium shuts out non-particpating applicants and applicants competing against a consortium will likely lose out. (54)
Sibert: Opposes consortia. Prone to abuse. (6)

K. Point System, Local Programming, Community Presence, Local Ownership

REC: Recommends a 9-point comparative system which includes local community presence (20 miles urban/rural) (59), local programming (20 hours per week) (61), public safety (with new requirements certifying government part 90 eligible or endorsement from a government part 90 eligible) (63), radio training programs (student stations) (66), children's radio programming (68), main studio staff presence (71), voluntary public file (74), Native Nation introduction into broadcasting (78) and public access broadcasting (like public access TV) (80). A "trigger point" will be used if the applicant is willing to accept an involuntary time share agreement. (84) If tied in points, longest community presence dates will prevail. (94)
Amherst: Oppose raising community presence to 4 years. (12) Feels LPFM (and translators) can ramp up local programming from 2 hours to 8 hours a day over a two year preriod. (3) Rural areas should not be exempt from any local programming requirements. (3) LPFM (and translators) carrying local programming should be able to "bump" LPFM (and translators) that are not. (3) Supports extending board member residency from 10 to 20 miles in rural areas. (4)
Braulick: LPFM applicants should be local but an exception should be made "where the applicant certifies to the FCC under oath that it is their intention to move to the community and become a permanent resident of the community." (3)
CF: 2 year community presence. (21)  Do not award extra points for longer presence. (22)  Extend boards to 20 miles in all areas. (22)  Point for local programming. (23)  Points for main studio and public access. (26)
CMAP: Local DJs between songs constitutes local programming.  Stations should publish lists of their local programs. (5)
CRA: Should be community based after licensing. (11)  Does not appear to support more points for longer community presence. (14)   Community presence is more dubious than local programming. (16)
Friend: FCC should discourage applicants who don't broadcast local programming or timeshift programming. (2)
JCPES: Retain two year established community presence and award additional points to those who surpass that requirement. (5)  More points for local programming. (6)
LPFMhelp: Organizations should be formed just for broadcasting. (2) LPFMs should file reports with the FCC to show they are in compliance with each pledge they make. (2)
Monster: Supports extending to 20 miles for applicant to be based. (2)  Keep point system as is. (3)
Nexus: Supports extending board members to 20 miles. (2)
NLG: Community presence should be kept at 2 years or reduced to 1 year. (7) Adopt a local programming requirement. (8)
PRP: Local programming should be required. (35) Supports 20 hours a week of local programming. (44) LCRA 5(2) should be read as a localism mandate. (36) Without an obligation, many will fail to conform to the FCC's expectation that they will offer local programming. (41) Eliminate the 12-hour a day point. (55) FCC should prioritize some points over others. (43) FCC needs to tightly define "local programming". (45) LPFM stations websites should have schedules that denote local programming. (46) "One person operation" stations should be discouraged. (46)  LPFM stations have 6-months of ramp-up to comply with local programming. (46)  Stations must remain local. (47)  Points for local news and staff presence and offers a "tiered" evalulation alternate proposal. (50) Retain community presence and local origination point if no requirement is adopted. (50)  Retain 2-year community presence and extend board members to 20 miles in urban and rural areas. (51)  A multi-stage "waterfall" criteria-evaluation system should be implemented. (61)
Sibert: Local origination is poorly defined and points should not be awarded.
Turner: Local is local. (2)
WNKR: LPFM stations could be easily programmed out of an Ipod. Would that be local programming? (3)
WSWO-LP: Must remain a local owner after receiving the license (2.2.3.1, also 2.2.4.1.1)  Local programming should be a "bulk" of the day (2.2.4.1.2)

L. Time Sharing, Operation Schedule

REC: Developed an involuntary time share system where if no full settlement can be reached, the top 2 or 3 applicants (based on establish dates) will share a channel for an equal number of hours. (90)  Processes are in place if a time share station "drops out".  (101) Process varies based on if the stations claimed the involuntary time share "trigger point". (103-106)
CF: Online system to handle settlements. (27)
CMAP: Supports involuntary time share where each proponent would be assigned an equal amount of hours per week. (*6)
CRA: Time sharing is not an attractive outcome and should be avoided. (17)
WSWO-LP: Eligibility should go first to unsuccessful MX members who express interest in remaining eligible if time share is required including going to lower scoring applicants. (2.2.4.2)  There should be no reason why an LPFM station can't broadcast 12 hours a day. (2.2.5)

M. Other Issues Channel 200 (87.9) / "J-Band" (76~88 MHz)

Friend: Allow Channel 200 (2).

Filing Windows

CF: Initial short form (5).
CMAP: Supports REC's proposed 2-window process.  Applications should be kept private until after the second window has concluded in the event of MX between the two windows.  Filing freezes for LPFM and Translators should be extended to cover both windows.  Windows should be announced with 6-months advance notice. (2)
PRP: Short form/long form filing process with technical details deferred until tentative selectee chosen. (9) Give 6-9 months from final rules to window. (13) Supports REC's proposed 2-window process. (15)

Foreign Stations

CF: Stations near border should be able to use contours to comply with international agreement since foreign stations are not covered by LCRA. (19)

Ownership

LTR: Section 73.858(b) should be deleted pertaining to local chapters of a larger organization that may have attributable interests.  Citing Montmorenci United Methodist Church.

Student Operated LPFM Stations / Webcasting / Part 15

REC: Supports lifting the rule requiring student LPFM stations (where the university has a broadcast license for another AM or FM station) to be dismissed if there are competing applications. (53)
Amherst: Revisiting licensing eligbility criteria to make it easier for experienced Part 15 operators, internet radio and carrier current stations to compete with other LPFM applicants. (13)
CF: Supports lifting of student station restriction. (24)

Translators

Amherst: Translators should be permitted to provide local programming for 2 hours a day ramping up to 8 hours a day.  Translators should be capped in urban areas at the maximum allowed for LPFM. (3)
dLR: Advocates adding a new "tier" of translator protections (similar to REC's subclass) to cover translators with service contours that exceed 21km.  Also supports extending the "buffer zone" to translators. (2)

Transmission Systems

NLG: A seperate rulemaking should remove the transmitter certificaton requirement.

TV Channel 6 Protections

Friend: Protect "legit" TV 6 stations and not those that are "illegally operated FM stations". (3)

Key to Commenters:

REC: REC Networks
Alpine: Alpine Broadcast Corporation
Amherst: The Amherst Alliance
Arso: Arso Radio Corporation
Braulick: Justin M. Braulick
Brown: Brown Broadcast Services
BSR: Brown Student Radio
CF: Common Frequency
CMAP: Community Media Assistance Project
CRA: Catholic Radio Assocation.
dLR: du Treil, Lundin & Rackley, Inc. Consulting Engineers
Dymoke: Wesli Annemarie Dymoke and Don Schellhardt, Esquire
EMF: Educational Media Foundation
Friend: Mike Friend
IBS: Intercollegiate Broadcasting System
JCPES: Joint Center for Political and Economic Studies.
KWMV-LP: Wet Mountain Broadcasting Corp.
Leggett: Nickolaus E. Leggett, N3NL
LPFMhelp: LPFMhelp.com / E. Anderson
LTR: LifeTalk Radio (Seventh Day Adventist Church)
Monster: MonsterFM.com / LPFMradio.com / Broadcast Technical Services
Nexus: Nexus Broadacst (also Conexus.fm)
NJBA: New Jersey Broadcasters Association
NLG: National Lawyers Guild Committee on Democratic Communications and Media Alliance.
NPM: Native Public Media & National Congress of American Indians
NPR: National Public Radio
PRP: Prometheus Radio Project
Sibert: Jeff Sibert
Turner: Bill Turner
WIBI: Western Inpsirational Broadcasters, Inc.
WNKR: Grant County Broadcasters, Inc.
WQIN-LP: 3 Angels Broadcasting Messengers
WSWO-LP: Southwestern Ohio Public Radio

 

Categories: Michi's Other Blogs

REC files comments, proposes 50 watt LPFM, new MX handling process

REC Networks - Mon, 05/07/2012 - 16:25

REC has filed comments with the Federal Communications Commission in response to the FCC's Fourth Notice of Proposed Rulemaking in the Low Power FM (LPFM) radio service.

In comments, REC:

  • Supported the creation of a 50 watt service to replace the 10 watt LPFM service that the FCC has proposed to discontinue.
  • Supported the creation of a 250 watt service in rural areas and once it has been determined that lower power stations are not needed, in urban areas.
  • Supports Native Nations entry into broadcasting while assuring that additional opportunities do not preclude potential LPFM opportunities off tribal land.
  • Supports the cross-ownership of FM Translators and LPFM stations with restrictions that will assure that LPFM stations remain local.
  • Proposed a 10-point comparative review process that would reduce the instances of ties.
  • Proposed scrapping the current processes of "partial settlements", "point aggregation" and "successive licensing" in favor of a new time sharing process that assures that competing applicants who can't completely settle would have a chance to get on the air without having to wait up to 7 years.

Reply comments are due to the FCC by May 21.

More details about our comments can be found below:

Categories: Michi's Other Blogs

Recent LPFM Tool changes restores population support, improves protected channel/points support

REC Networks - Thu, 05/03/2012 - 07:54

On Monday, the FCC had released software that can be used to determine the protected channel/points of LPFM stations.

REC has ran this software and used the results to rebuild our protected channel/points database. In the past, this was done through the REC Channel Search technology but now that we know exactly which channel points the FCC is intending on protecting, the LPFM Tool has been updated with those channel/points.

To see the protected channel points for every market, visit the REC Channel Points viewer:
http://cdbs.recnet.net:8080/chanpoints.php

This week, REC has restored the highly requested population support. We are now also using 2010 census data. When you do a search, the tool will return the estimated population at the census block level within the service contour of the proposed station. The census block is the lowest level reporting area used by the US Census Bureau.

The Tool can also give overlap area population information on channels that may be potential second-adjacent channel waivers. As always, if you are considering a second adjacent channel waiver, please seek the services of a qualified consulting engineer.

The Tool also supports population within Native Nations. If the 60 dBu service contour of the proposed site includes tribal land, the Tool will return a separate population for the area within tribal land and what percentage is tribal over the entire population of the service area. This functionality is being added to support REC initiatives that address the FCC's proposed handling of LPFM stations for Native Nations.

We are planning no major changes to the Tool between now and the comment filing deadline date of May 7. We hope you participate in the rulemaking process.

Categories: Michi's Other Blogs

Upcoming 2010 Census Upgrades for REC Broadcast Tools

REC Networks - Sun, 04/29/2012 - 07:10

Starting in mid-May, REC will begin development on revamping the Census support across the REC Broadcast Services family of products including the LPFM Search Tool and ENAC.

This project will include updating our existing products (front end and back end) from vintage 2000 census data to vintage 2010.

Unlike other REC projects, this project will likely be done on a "flash cut" basis where 2000 vintage census data will be used until we have cleared the 2010 versions from testing. Keep watching the Home Page and the LPFM Tool release notes for updates on this project.

This project may take some time as there are differences in the 2010 census datasets vs. 2000.

We are also going to attempt to restore census block data. This will allow us to provide new offerings (as well as bring back some old offerings) that involve the need for very accurate population readings. The primary application for this data will be for determining population within overlap zones for second adjacent channel waivers. We note that the FCC may not base waiver eligibility on census block data alone (remember also, the FCC may look at commercial locations and nearby roads when determining potential population for an overlap area). Our services are designed to provide you with a way to test the potential for a second adjacent channel waiver. As always, obtain the services of a consulting engineer, especially if the station you are proposing may require a second adjacent channel waiver. REC Broadcast Services tools do not replace the services that a qualified consulting engineer can provide you.

We will also be looking at ways to provide limited demographic information at the census tract level. This is a function the LPFM Tool provided at one time when the US Census Bureau had their TIGER Mapping Service online. With this data, we hope to provide you with information about your station's potential listeners.

The US Census Bureau provides data in three different levels:

Census Block - This is the lowest level of data down to just a few houses or an apartment building.

Census Block Group - Normally a portion of a neighborhood consisting of a few blocks.

Census Tract - Normally about the size of a neighborhood.

We hope these products make our tools more valuable to you as you plan your new LPFM station.

We wish all applicants the best of luck.

Categories: Michi's Other Blogs

Short URLs for LPFM Search

REC Networks - Thu, 04/26/2012 - 05:49

REC now supports short URLs for both LPFM Search and Broadcast Query using our lpfm.ws domain name.

LPFM Search

Just going to lpfm.ws will take you right to the LPFM Search Tool.

On LPFM Search results, you will see a short URL under the map. You can copy and save that URL to put in e-mails or anywhere you would use a short URL. Use that URL to retrieve that search (it will search the current condition at the time the URL is accessed again).

Broadcast Query

To easily look up a station in the broadcast query, type lpfm.ws/? and the station's call sign.

Examples:

lpfm.ws/?kfi - KFI - Los Angeles

lpfm.ws/?kfwb - KFWB - Los Angeles

lpfm.ws/?wabc - If there are multiple stations under the call sign, you will get a pick list. Of course, you can always go directly to the station by adding the suffix (you must use a dash with the suffix):

lpfm.ws/?wabc-tv - WABC-TV - New York

lpfm.ws/?wjz-tv - WJZ-TV - Baltimore

lpfm.ws/?xesct - XESCT - Ensenada

lpfm.ws/?kcsn-fm1 - KCSN-1 booster, West Los Angeles

lpfm.ws/?k200aa - K200AA translator

lpfm.ws/?k38iz - K38IZ TV translator - Phoenix, AZ

You can also put in a facility ID (which would be the best way since if the call sign for the station changes, the facility ID will always remain the same):

lpfm.ws/?134485 - KWSS-LP Scottsdale AZ

Categories: Michi's Other Blogs

New functionality in LPFM Channel Search Tool helps applicants near the Canadian and Mexican borders find the best potential channel to use.

REC Networks - Thu, 04/26/2012 - 00:56

The distance spacing tables used by the REC LPFM Search Tool will be updated for foreign allotments to show the maximum spacing necessary to prevent interference. 

Currently, the FCC provides for domestic distance spacing between LPFM and full power and translator facilities on co-channel and first-adjacent channels, both the legally required minimum as well as the spacing required to assure that LPFM station service contours will not receive any overlap from the full power station’s interference contour.  The higher “full spacing” figures are not legally binding but they assist LPFM applicants to find the best possible channels.  REC has presented these channels as available but “with potential interference”. The FCC has never provided this on the Canadian and Mexican facility protection charts.  This is also the value that will appear on the Channel Report under RCIC (Required to Clear Interference Contour).  This functionality was also added to allow REC back-end tools such as SuperCoordinator choose the best possible channel for locations near the international borders.

The FCC rules for LPFM protections for Canadian and Mexican stations require that the interference contours of LPFM stations do not overlap the service contours of foreign stations.  This is similar to protecting domestic stations with one major difference.  There is no 20 km “buffer zone” around the service contour of the full power station like there is with domestic stations.  This is why the required distance separations between compatible Mexican allotments are exactly 20 km less than the US allotments on co-channel.  Canada’s differences are shorter because Canada protects their FM stations to larger service and interference contours:

United States

Canada

Mexico

Class

Service Contour*

Class

Service Contour

Class

Service Contour

A

28.3 km (60 dBu)

A

38.7 km (54 dBu)

AA**

28.3 km (60 dBu)

B1

C3

44.7 km (57 dBu)

39.1 km (60 dBu)

B1

50.8 km (54 dBu)

B1

44.7 km (57 dBu)

B

C2

65.1 km (54 dBu)

52.2 km (60 dBu)

B

65.1 km (54 dBu)

B

65.1 km (54 dBu)

C1

72.3 km (60 dBu)

C1

86.4 km (54 dBu)

C1

72.3 km (60 dBu)

C

91.8 km (60 dBu)

C

96.7 km (58 dBu)

C

91.8 km (60 dBu)

* - US service contours do not include 20 km “buffer zone” that applies to LP10 and LP100.

** - Mexico also as a Class A service which is similar to the old US Class A service (3kw @ 100m HAAT) and has a service contour of 18.6km (60 dBu).

REC will update our distance separation charts for Canada as follows for no interference received:

Foreign Station Class

LP10

LP50

LP100

LP250

Co-channel

First-adjacent

Co-channel

First-adjacent

Co-channel

First-adjacent

Co-channel

First-adjacent

Low Pwr.

63

31

65

32

66

33

67

35

A1

63

31

65

32

66

33

67

35

A

116

63

117

64

118

65

120

67

B1

146

83

150

85

152

86

153

87

B

172

102

177

103

178

104

179

106

C1

206

133

210

135

211

136

212

137

C

209

148

213

149

214

150

216

152

There are no changes to the minimum required distances We are only adding these recommended distances to distinguish LPFM channels that may not be subject to interference.

REC will update our distance separation charts for Mexico as follows for no interference received:

Foreign Station Class

LP10

LP50

LP100

LP250

Co-channel

First-adjacent

Co-channel

First-adjacent

Co-channel

First-adjacent

Co-channel

First-adjacent

Low Pwr.

32

15

34

17

35

18

36

19

A

79

40

81

41

82

42

83

44

AA

90

47

91

48

92

49

94

51

B1

134

73

135

74

136

75

138

77

B

175

102

177

103

178

104

179

106

C1

175

108

177

110

178

111

179

112

C

201

140

202

141

203

142

205

144

There are no changes to the minimum required distances We are only adding these recommended distances to distinguish LPFM channels that may not be subject to interference.

Categories: Michi's Other Blogs

REC LPFM position updates for current rulemaking...

REC Networks - Mon, 04/16/2012 - 18:52

Since the release of the NPRM, REC has been busy analyzing information, interacting with our allies and supporters, listening to those who use our services and overloading our sever with data products (some we have shared with everyone and others that we are still working on)..

Based on this, REC plans to take positions on various aspects of the LPFM rulemaking. Please understand that these are subject to change based on new information (such as comments from allies or data discoveries). We must stress, our playbook is not closed.

Second Adjacent Channel Waivers

We feel that these should be available to all applicants and based on the how the FCC defined the protected channel/points, they are anticipating waivers on original CPs. We also want a reasonable definition of interference especially in light of interference mitigation processes.

Elimination of LP-10

REC supports specifically the elimination of LP-10 but we do not support the elimination of a sub-100 watt service. Instead, we are proposing a LP-50 (50 watts at 30m HAAT) service to replace LP-10 using similar methodology that the FCC used when proposing LP-250. In some markets like Los Angeles, LP-50 may be the only way to bring enough diversity to the area.

New LP-250 Service

REC supports a new LPFM service at 250 watts at 30m HAAT. We feel this service should be available to all applicants and not just existing LP-100 stations. REC is currently evaluating data models to determine if the FCC proposed geographic restrictions on LP-250 are warranted and whether to consider LP-250 as a replacement for LP-100 (meaning all new LPFM stations could be LP-50 and LP-250 only.) We are looking at all options. The playboook is wide open on LP-250.

IF Channels

We are asking that for the purpose of IF channels only that translators operating at exactly 100 watts be considered "class D" and therefore subject to a waiver of IF channel protections on domestic allotments. IF channel protection would also be eliminated for all LP-100 stations (not just those "less than 100 watts") as well as LP-10 or LP-50 stations.

Cross-ownership/Multiple Ownership

REC feels that student-operated LPFM station proposals at universities that have an NPR station where students are shut out should be able to be processed like any other LPFM application and not be the first to be dismissed. We are also examining policy regarding Native Nations. We feel that the student station situation is different than the needs of Native Nations to broadcast within their territory. REC feels that cross-ownership and multiple-ownership by Native Nations should be permitted as long as it does not create a substantial burden on the availability of channels outside of the Native Nation. We support the elimination of the "public safety" definition and multiple ownership allowance of local governments, especially in light of the nationwide availability of AM spectrum for TIS.

Translators Owned by LPFM Stations

We will support LPFM owned translators in order to expand service areas especially in awkward geographical situations. Specifically, translators owned by LPFM licensees should be at similar or inferior field strength to the LPFM and should have an overlap (even if very small) between the LPFM and translator service contours and must carry the LPFM station at all times.

Consortia

We feel that the concept of encouraging consortia in LPFM will promulgate fraud by rewarding points to "ghost organizations" who stack their points. We saw cases of point stacking in the 2000/01 windows and we feel that this behavior should not be encouraged or rewarded. We also see enforcement issues, especially when one consortia member does something illegal on the air. REC would rather see time share agreements with a shared transmitter site (and shared EAS/CAP). Each member of the share site is individually qualified and broadcasts with their own callsign and is responsible for their own compliance.

Selection Points

REC is currently considering our position on selection points. We feel that this will likely be championed by another organization such as Prometheus. We feel that the opportunities for settlements will be far greater in this window than in the previous window due to the wider availability. With that, we are fairly happy with the existing point policies (with the exception of point aggregating for time share/consortia proponents) and we will work with our allies to propose a policy that would work for everyone.

Again, our playbook is still open.

Categories: Michi's Other Blogs

Expand FCC rules to allow more student-operated radio stations

REC Networks - Mon, 04/16/2012 - 17:53

REC considers student-operated college radio to be vitally important to not just provide our next generation with real-world skills but to bring a diverse voice to the student body and the local community surrounding the college.

Over the past decade, we have seen a substantial decline of student-operated over-the-air radio stations, such as KUSF in San Francisco. Many college stations are operating over internet streaming and/or they may be operating a radio station using carrier current AM or over the school's cable TV system.

REC views LPFM as a low cost method for universities and student government to restore over the air broadcasting and hopefully revitalize their broadcasting, journalism and communications programs for the future.

The FCC rules (73.860(b)) allows a university that has a full power radio broadcast station that is not student run to also have a LPFM station that will be managed and operated by students on a day-to-day basis.

The only provision of the rule is that applicants proposing a student operated LPFM station at a university that already has a full power radio station must not be facing competing applications that would be "mutually exclusive" (where the grant of the other applications would cause the stations to interfere with each other).

The overall university exception was put in place by the FCC in September, 2000 by stating that the exception would:

"...promote our goals of maximizing diversity of ownership in a community and providing a medium for new speakers, including students, to gain experience in the broadcast field." (First MO&O at 84)

In justifying making student LPFM applications only proceed if unchallenged, the FCC states:

"We believe this exception properly balances the interests of local groups in acquiring a first broadcast facility and of university licenses that desire to provide a distinct media outlet for students." (First MO&O at 84)

For those of us who have been following the state of college radio, we know how much things have substantially changed since 2000. Also, with the Local Community Radio Act of 2010 and the Auction 83 FM translator processes being put in place, we are seeing a substantial number of openings for new LPFM stations nationwide in urban, suburban and rural areas.

REC feels that the rule (73.860(b)(4)) is outdated and with the substantial number of channels available now, is less of an issue. We also feel that student LPFM applicants should be able to enter into settlement agreements (where they and the competing applicant(s) amend their application to propose an engineering solution that works for everyone) or enter into a time-share agreement (where the student station is on the radio at certain times of the day with the other applicant(s) using the channel at other times).

REC is asking those of you who care about the future of student-run college radio to allow it to have every opportunity possible.

The FCC is currently accepting comments on proposed changes to the LPFM service until May 7, 2012. While the FCC is not specifically proposing to change this rule, they are soliciting comments on the selection process if there are multiple applications for the same channel. We feel that this is an excellent opportunity to support the removal of 73.860(b)(4) and allow student stations a full opportunity for a radio future.

CLICK HERE TO TELL THE FCC THAT APPLICATIONS FOR NEW STUDENT OPERATED LPFM STATIONS SHOULD BE PROCESSED LIKE ALL OTHER APPLICATIONS.

Categories: Michi's Other Blogs

Why does REC's LPFM Search Tool results differ from the FCC's tool?

REC Networks - Thu, 04/12/2012 - 18:32

The FCC is going to announce the re-release of their Low Power FM (LPFM) Channel Search Tool. It will be available at the following URL:
http://www.fcc.gov/encyclopedia/low-power-fm-lpfm-channel-finder-0

What we have found is the tool is not much different than the tool from the filing windows 12 years ago other than it now allows users to toggle second adjacent and IF channel protections.

Why is my result different on their tool?

<!--break-->
From our use of the FCC's tool, we have noticed that their tool does not exclude translators that we predict may be dismissed if they do not amend their applications as they may conflict with what we predict to the be the LPFM protected channel/points.

As a government agency, the FCC is not in a position to make that kind of speculation, especially prior to issuing a public notice actually defining the actual protected channel points.

At the same time, REC is taking significant latitude by making such predictions but as we point out in the language of the user interface of the LPFM Tool, these are channels that are presumed to be dismissed. We are reminding our Channel Search users that the results, especially on the channels identified with the blue "presumed dismissed" identifiers are subject to change based on FCC disclosure of policy as well as application activity by the translator applicant.

With that, you could say that REC is giving a fairly liberal result while the FCC is giving a more conservative result. As the FCC continues to provide more definition, REC's search tools will "true up" to those definitions.

Should I use the FCC Tool instead of REC's Tool?

The FCC Tool should be seen as a cross-check to our tool knowing that you will not always get matching results. The results from the FCC Tool are no more official for filing an application than the REC Tool is. Neither tool replace the services of a qualified consulting engineer.

The REC LPFM Channel Search Tool actually predates the LPFM Search Tool established by the FCC for the original LPFM filing windows in 2000 and 2001 and unlike the FCC Tool, the REC Tool has been updated weekly over the past decade.

The user interface of the REC Tool currently provides eight different ways of entering your location therefore you do not need to know your geographic coordinates to use the tool. The output of the REC Tool provides you the big picture on a single screen with additional information such as channel reports and second-adjacent overlap zone information just a single click away.

The REC Tool also provides features to support the proposed LP250 services as well as supports current LPFM licensees through the NOTCH feature and for new applicants, gives much more information about a particular site.

The REC LPFM Channel Search Tool will remain operational and constantly updated.

Just as a reminder, if you do contact REC requesting assistance with results received in any of our tools, please make sure that you copy and paste the full URL (with all of the parameters) in your browser's address bar (as well as the one from the FCC's result page if you are needing to compare). This will help us isolate any issues. REC's tools are not perfect but we are constantly looking for ways to improve our prequalification results.

REC thanks everyone for their support over the years.

Categories: Michi's Other Blogs

REC LPFM availability information now playing at Prometheus

REC Networks - Mon, 04/09/2012 - 17:33

Today, Prometheus Radio Project and REC Networks debuts a new quick LPFM Availability Check solution on the Prometheus Radio Project website to assist in their efforts to mobilize local community groups to support LPFM and to eventually come on the air.

REC has provided a ZIP Code level search using a dataset constructed by REC's ENAC (Every Nook And Cranny) channel search. This allows for quick retrieval of potential availability information and allows the search tools to be used in shared environments and in conjunction with content management packages such as Drupal where fast database response times are necessary.

The package also includes an interface to the FCC's Electronic Comment Filing System that allows users to make comments to the FCC with dynamic content based on the search results. The solution includes a complete "back office" workflow system for handling users with incompatible browsers as well as management of spam.

In a statement, REC founder Michi Eyre said: "Prometheus is currently the strongest organization that supports the LPFM service at the political and regulatory level. REC has had a long history of working closely with Prometheus and other organizations such as Common Frequency. The past year's joint proposal by Prometheus, Common Frequency and REC is an excellent example of how when entities work together, our voices become stronger and more likely to be heard. REC will continue to work closely with Prometheus and our other allies through this proceeding and into the future."

Categories: Michi's Other Blogs

FCC accepting public comments on LPFM until May 7

REC Networks - Sat, 04/07/2012 - 17:16

The current Low Power FM Notice of Proposed Rulemaking has been published in the Federal Register.

Comment deadline is: May 7, 2012

Reply comments are due: May 21, 2012

Categories: Michi's Other Blogs

REC releases new version of LPFM Channel Search for mobile

REC Networks - Fri, 04/06/2012 - 00:42

REC has released a new version of the mobile friendly LPFM Channel Search Tool.

This new version has received revisions similar to what was recently put into the desktop (PC) version:

  • LP-250
  • REC's proposed LP-50
  • Elevation, HAAT & ERP support
  • Location search expanded to 1 minute increments
  • Translator Interference Zone support
  • Channel/Point Protection support
  • Radio reading services

In addition, this version of the mobile tool has features never offered in the mobile version in the past:

  • Geocoding (search by street address)
  • Service area map

The desktop version of the LPFM Tool has a QR code that can be scanned by a smartphone and then bookmarked so you can save searches you did for later retrieval on your smartphone.

The LPFM Search for Mobile works with your smartphone's web browser and does not require the installation of any apps.

You can access the tool by using your mobile web browser and going to recnet.com and then click on LPFM Search.

Categories: Michi's Other Blogs

REC Networks statement on Media Access Project

REC Networks - Tue, 04/03/2012 - 20:52

I was saddened when I read the news that Media Access Project will be suspending operations as of May 1, 2012.

MAP worked "behind the scenes" for over a decade providing the legal support for ally organizations such as Prometheus Radio Project on LPFM and other media justice issues.

Unfortunately, in this current economy, many non-profits are being impacted by dwindling budgets due to declines in fundraising.

During the past decade+ that I have been involved in LPFM, MAP was very instrumental in what we are all fighting for.

Let's hope this suspension is just that, a suspension and hopefully someday, the organization will resume operations.

Michi Eyre
founder, REC Networks

Categories: Michi's Other Blogs

More on LP-250

REC Networks - Sun, 04/01/2012 - 00:07

With REC's recent release of a list of LP-100 stations that we predicted may be eligible for an upgrade to 250 watts, we received a mixed response and I thank you for the feedback.

Let's talk about why it seems like we have so many stations that are predicted to be able to upgrade to 250 watts.

You may be familiar with the infamous "buffer zone". When the FCC created the LPFM service over a decade ago, they decided to place a "buffer zone" outside a full power station's maximum service contour (based on class), thus giving it a 20 km extension. A LP-100 or LP-10's interference contour could not cross into that buffer zone. The idea of the buffer zone was to allow the full power station to make facility moves and other changes within that 20km buffer with minimal impacts to the LP-100.

Section 3(b)(1) of the Local Community Radio Act (LCRA) states:

IN GENERAL- The Federal Communications Commission shall not amend its rules to reduce the minimum co-channel and first- and second-adjacent channel distance separation requirements in effect on the date of enactment of this Act between--

    (A) low-power FM stations; and

    (B) full-service FM stations.

The FCC has interpreted that to mean the current power levels in effect at the time the LCRA was passed (LP-10 and LP-100). While the buffer zone is specifically not in the LCRA, language specifying that the distance can't be reduced is.

Now let's say that the FCC created an LP-250 service without a buffer zone. If they could, an LP-250 could be as close as 52 km to a full power Class-A station. LP-100 with the buffer zone is 67km. Since that would put the LP-250 at closer spacing than even LP-10, it would be in violation of the LCRA. So what the FCC did was keep the 20km buffer zone but allowed the interference contours of LP-250 stations to cross into the zone. The result was a LP-250 distance spacing chart where on co-channel and first-adjacent channels, the required minimum distance separations between LPFM and full power stations are exactly the same. The only differences are in second adjacent, IF (which is still going to be required for LP-250), translators and foreign stations. As the FCC states, the LP-250 co-channel 34dBu interference contour in respect to a Class B FM station crosses 8.8 km into the buffer zone but still does not cause the LPFM interference contour to overlap the full power station's service contour.

This is why many LPFM stations are able to stay at their current locations and still upgrade on their own channel. Stations required to change channels likely became short spaced by subsequent application activity by full power FM stations.

LP-250 "psuedo-Buffer Zone" sizes ~ (distance from the edge of the Full Power FM service contour to the edge of the LPFM interference contour):

  • Primary Station is Class B: Co-Channel 11.2km, First-adjacent Channel 17.3km.
  • Primary Station is Class B1: Co-Channel 13.9km, First-adjacent Channel 17.6km.
  • Primary Station is not Class B or B1: Co-Channel 14.8km, First-adjacent channel 17.9km.

There were concerns raised about the LP-250 list REC published on March 30. This list was developed to show the potential for LPFM stations in general to consider upgrading to LP-250. Because the FCC has interpreted the use of contours, especially on co- and first adjacent channels to be a violation of the LCRA, minimum distance spacing for LPFM is here to stay for now.

We advise stations that no matter where they are on that list (which was intended only as a prediction) to work with a qualified consulting engineer to verify their current status and work on solutions for maximizing their station. As we mention very frequently, the use of the REC tools are intended for prequalification and do not replace the services of a qualified consulting engineer.

The diagram below compares a LP-100 station at the closest point to be properly spaced to a Class A station and shows a LP-250 station at similar distance in relation to the Class A:

Categories: Michi's Other Blogs

REC LPFM Search Tool for mobile ~ updated.

REC Networks - Thu, 03/29/2012 - 05:25

Today, REC Networks released a new version of the popular LPFM Search Tool optimized for mobile phones.

The new version includes functionality related to the recent FCC decisions and petitions for rulemaking. In addition, the mobile version now handles second adjacent waiver and LP-FLEX.

The new mobile version contains the functionality found on the desktop version except for mapping or geocoding functions. Geocoding functionality (the ability to look up by street address) is subject to Google licensing agreements and since the mobile tool does not use Google Maps, we can't do geocoding.

On the desktop version of the LPFM Channel Search Tool, there is a QR code that you can scan with your mobile phone and then save your searches as bookmarks. You can do an address search on the desktop version, use the QR code to save the information and recall it later on your smartphone.

The REC LPFM Channel Search Tool for mobile uses your smartphone's browser and does not require any apps to install.

To try it, go to recnet.com on your mobile browser and click on LPFM Search.

Categories: Michi's Other Blogs

ロリータ!!!!

Michi's Japan Blog - Thu, 03/29/2012 - 01:35



私は日本からパッケージを受け取った!
I received a package from Japan!



BODYLINEから!!!
From Bodyline!!!!



私は普通のためにキャンディーのプリントのスウィートロリータが好きではありません。
しかし、これらは、カルーセルの馬です!
I normally do not like sweet lolita because of the candy prints.
But these are carousel horses!!!!






他のドレスはカントリーロリータです。私は本当にカントリーロリータスタイルが大好きです。
The other dress is country lolita. I really love the country lolita style.



私は日本にいつかそれらを身に着けて楽しみにしています!
I look forward to wearing them in Japan someday!



LOVE!!
-michiko <3

Categories: Michi's Other Blogs

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