[BC] LPFM's

[Black, Mike]

One of the problems of LPFM was that the service as the FCC granted was
neither low power nor was it allocated correctly. Some of these granted
facilities had better coverage than some minimal Class A FM, and less
technical and operational requirements (EAS, Studio, etc.).

The FCC missed a golden opportunity of giving back to legitimate
licenses a true local service, by putting in loopholes that allowed for
these stations to be over glorified translators of the established
services. They also missed the opportunity to reform the translator
abuse that exists today, with all the satellite fed translator networks.
I don't want to get into a spitting match of pro or con on the types of
programming carried by LPFM or translators. However, considering the
intent of what translators are supposed to do, extend signals of
stations that are terrain shielded or poor signals of nearby stations to
communities that would not get a signal, why would I need a station from
California or Alabama in New York? It is not local nor does it really
serve the public interest. The Commission could have taken another look
(and they still could) on changing the regulations and while not
prohibiting satellite fed distant(let's say 400 miles from the
originating station would be Protected") existing translators from
operating, they otherwise could be bumped for local rebroadcasters or
LPFM allocations. This would go a long way to solving some of the issues
that have been raised of the inability of the LPFM service to live up to
its intent and correct some of the wrongs that have been occurring in
the translator area. 

The other thing that LPFM station have to realize, is that they are
non-profit stations. That means that while they can recoup expenses, no
one is expected to be making money on these, especially considering the
limitations. The FCC has already cited stations for illegal
announcements and operating deficiencies. And to be honest, some of the
organizations are a sham. They are individuals posing as non-profits, or
are "local" churches of the larger national licensees of some of the
satellator networks, that with the exception of a local church service,
are just recording and time shifting network feeds of their big brother
church network. 

What a majority of those truly interested in this service and the most
passionate wanted, was something akin to the former Class D 10 watt FM
service that the FCC gutted for "spectrum efficiency. While this had
some merit, in allowing the reserved band to be developed, it caused a
lot of damage in terms of disenfranchising many, especially when
translators of the same wattage were allowed to come in, but a local
station could not. There were a few that wanted it to be a commercial
service, but this was doomed from the start, including Mr. Skinner's
1000 watt "low power" idea. 

The Commission has a lot on its plate, and some of the recent rulemaking
proposals have attempted to further muddy the waters, with allowing AM
stations to have FM translators, and FM translators to originate local
programming. Both, IMHO, are disasters waiting to happen. Perhaps the
time has come for the Commission to take a pause and reconsider what it
can do to address some of the concerns that existing broadcasters have.
This includes the mess that was caused by the last translator window,
and the continued lack of opportunities for local non-profit groups,
primarily schools, community groups, and other non-profits, that can
truly offer something different than satellite fed or automated
programming from thousands of miles away.

Mike Black
Geneva, NY