On July 27, 2015 the Lower Power FM Advocacy Group (LPFM-AG) filed a Petition for Rulemaking with the FCC, asking the Commission to institute a number of changes that would fundamentally alter the nature of the LPFM service. On September 2nd, the State Associations filed comments opposing the Petition, focusing on three main concerns: the Petitioner’s requests to (i) grant LPFM stations primary status; (ii) increase LPFM operating power; and (iii) allow LPFM stations to operate commercially.
It was argued that amending the rules to grant primary status to LPFM stations would compromise the integrity of FM spectrum by increasing the risk to full-power FM licensees in ways the FCC specifically found unacceptable in adopting the current rules.
We opposed any increase to LPFM power on the grounds that such increase would further strain an already overcrowded FM band. Granting this request would block licensing opportunities for FM translators (including for AM revitalization) and boosters, as well as undercut the hyperlocal nature of LPFM stations that the FCC intended to be the very essence of the service.
Finally, we urged the FCC to reject the Petitioner’s request to allow LPFM stations to operate commercially.
It was noted that the State Associations are supportive of LPFM service, but urged the FCC to recognize that granting Petitioner’s requests would essentially replace the current LPFM service with an entirely different service—in contravention of the public interest and statutory mandates.