What is REC's position on FM6 operations?
Overall, we consider these to be secondary LPTV stations that are subject to displacement, no different than any other LPTV station needing to make way for new primary services. During the many years that LPTV stations have been operating FM6, they have used their channel in a manner that is similar to a commercial FM broadcast station without the payment of regulatory fees that are consistent with full-service FM broadcast stations. They also were never required to protect adjacent channel FM facilities (even though secondary FM facilities had to overprotect them). Being on Channel 6, they had enjoyed a "quasi-primary" service status because they were only subject to displacement as a result of full-service TV application activity on Channels 5 and 6, in which more full-service TV stations are leaving these channels as opposed to moving to them and those that are still there have either a a spectral or financial reason why they are not moving to VHF high band or UHF. FM6 operations should not be "rewarded" with a replacement commercial allotment. However, some at the FCC does find some kind of public interest benefit to these stations and as a result, we will include "recommendations", which are not necessarily "proposals" that would set aside 87.7 in the 13 markets where the FCC has authorized FM6 operation by STA. The diverse audiences that some of these stations reach could be better served by noncommercial educational facilities that can reach these communities without commercial motivation. REC supports maintaining the FM6 operations under STA until a time when the Channel 6 band (82.1~87.9) is needed for primary full-service FM stations.
What will happen to the existing FM6 stations under the REC recommendations?
We will be offering two options to the FCC. One option would permit the existing LPTV FM6 license to be converted to a commercial allotment on Channel 199 (87.7) and subject to the radio rules and pay the filing and regulatory fees appropriate to primary radio broadcasting as opposed to secondary LPTV service. The other option would be for the FCC to add Channel 199 to the FM Table of Allotments for the 13 markets and putting the allotments up for auction. The latter may be statutorily required, but we are not sure of that, so we will leave both options over. If the FCC requires auctions, we do support the existing FM6 licensees to get a substantial bidding credit to retain their allotment.
Why do we need to displace the LPTV stations?
When you weigh the opportunity for about a dozen new free-to-air FM stations in the same spectrum as one TV station with an analog carrier and a limited amount of bandwidth for multicasting, which can include subscription/encrypted services above the one TV stream that is required, the public interest could favor analog radio service with a dozen different diverse owners over a single TV station with one owner. Displacement is necessary to make room for the new FM stations. REC does share the concerns of maintaining the niche radio services provided by some FM6 stations and while we feel that these niche services are best provided by noncommercial FM and LPFM stations, we will make provisions for a commercial allotment at 87.7 if the FCC wishes to move forward with retaining the audio services provided by FM6 LPTV stations.
Why does the effective radiated power (ERP) have to be reduced at some 87.7 stations?
This is to address the differences between the TV and radio rules. LPTV has a 3kW effective radiated power (ERP) limit, but no real height above average terrain (HAAT) limit. Some FM6 operations, such as the one in Los Angeles exceeds the maximum power and HAAT combination that are allowed to FM radio stations. When we came up with the 87.7 allotments, we attempted to make them comparable to an FM service class. While some markets saw a decrease in ERP, some saw an increase.