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Radio World: Reprinted from February 16, 2000
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LPFM Rasises Hopes, Questions and Threats
by Leslie Stimson

WASHINGTON - As details about the FCC's decision to create a new class of low-power FM stations have emerged, reaction has been swift, and in some cases, volatile.

The Consumer Electronics Association joined NAB in opposing elimination of certain interference protections in order to create the new service.

LPFM supporters, as expected, are pleased with the FCC ruling. Some supporters have tempered their enthusiasm as they expect opposition to the service to grow and delay, or possibly, halt its implementation. Placed in the middle of this political and technical debate are equipment suppliers, who see a potential new source of low-end but high-volume business.

Within days of the FCC vote, several RF manufacturers announced products suitable for low-power FM. Broadcast Electronics said it would demonstrate two versions of low-power transmitters at NAB 2000, the Plug-N-Play 150 for the new LP100 stations, and the Plug-N-Play FM20, for LP10s.

Armstrong Transmitter Corp. said its FMX transmitter line and 707 antennas would be suitable for LPFMs. LPB Communications Inc. has developed LPFM packages that include licensing, equipment and installation for under $10,000. LPB President Tom Spadea said the company was taking inquiries and was prepared to walk potential buyers through the application process.

"It opens up a new market for us," said Spadea, whose firm has focused on non-traditional station installations such as AM carrier current and radiating cable installations under Part 15 of the FCC rules.

And if LPFM does not happen
"This has brought to the forefront the need for small stations, on a budget. Whether or not LPFM goes through as it is, people can do (this) legally now," said Spadea.

The commission's Report and Order was released several days after its vote to create stations at power levels of 50 to 100 W and 1 to 10 W (RW, Feb. 2). Following the vote, most observers and participants were still studying the details.

An NAB spokesman said the association was considering all options to the ruling, including possible court action. The association also again urged members to support a bill sponsored by Rep. Mike Oxley, R-Ohio, (H.R.3439), which, if passed, would prevent the commission from implementing the service.

One industry source lamented the bill has no "legs" because members of Congress will be faced with how to offend the least number of constituents. Considering the number of broadcasters in each district vs. the number of churches, minority groups and other LPFM supporters, elected officials, the observer said, would likely choose to please the latter, larger group.

NAB's recourse
A source close to NAB said the group was leaning toward appealing the decision in court, rather than filing a Petition for Reconsideration to get the FCC to change or reverse its decision. The source said NABwould need to prove the decision was arbitrary and capricious to win a court case.

That debate hinges on potential interference to existing stations from LPFMs. The FCC has concluded that "any risk of interference from LPFM stations of 100 watts or less is small, and, on balance, is outweighed by the benefits of this new service." That is why the FCC chose to eliminate third-adjacent protection requirements to or from LPFMs.

The FCC also said it does not believe LPFMs at 100 watts "are likely to have an adverse effect on digital IBOC signals."

NAB and CEA disagree. CEA President/CEO Gary Shapiro stated, "We share the FCC's worthy commitment to promoting greater access to the airwaves. Unfortunately, we have found that the method chosen by the commission specifically, the removal of third-adjacent channel protection may result in interference to existing FM radio service and would adversely affect consumers' investment in the 710 million FM receivers currently in use in the U.S."

Of four studies considering the ability of stationary and mobile receivers to reject interference, the FCC said all of them, including its own, used different measurements to determine when interference occurs and the quality of service to be protected, making a direct comparison difficult.

One thing the studies had in common, said the FCC, is they concluded auto receivers and home units were better able to reject interference than portable, personal and clock radios.

"We find that automobile radios and home stereo/component receivers generally are better able to provide -40 dB rejection of third-adjacent channel signals and therefore generally will provide acceptable service in the absence of third adjacent channel protection.

Under the new rules, a low-power FM station must protect full-power stations on co-channel, first- and second-adjacent channels, but does not have to protect a full-power on a third-adjacent channel. "A full-power doesn't have to protect an LPFM at all," said Peter Doyle of the Audio Services Division of the FCC Mass Media Bureau.

An LPFM has to meet minimum separation distances to protect the service contours of authorized commercial, noncommercial FM stations for all classes, including Class D, and translators, boosters and LPI00 stations, the FCC ruled.

The 1 to 10 W stations would be a secondary service, not a primary one as the LP100s are.

In addition to normal separation requirements, LPFMs would need to factor in an additional 20 kilometer "buffer zone" between them and a fullpower station.

To illustrate, Mass Media Assistant Bureau Chief, Engineering, Keith Larson said, "The smallest full-power class (for FM) is Class A. Ordinarily, to protect that station against co-channel interference you would have to be spaced 47 kilometers from that station. To provide extra protection, we have said you need to be spaced 67 kilometers from that station. It allows that full-service station to move 20 kilometers toward the LP station."

The FCC said current Class As that are 100 W, the same as the LP100s, would not be re-classified as LPFMs. The new stations would be required to adhere to many of the requirements of Part 73 of the FCC Rules, which addresses technical operations. The commission said it would not authorize directional antennas for LP stations as it is relying on minimum-distance channel separation methodology, rather than a contour-based approach to provide interference protection.

LPFMs will have to adhere to the 200 kHz channel bandwidth of other FMs and protect the radiation antenna patterns of AM stations. Because of their small service areas, the FCC expects most to co-locate their studios and transmission facilities, and not need STLs. But the commission did not rule such use out. It said LPFMs may use broadcast auxiliary frequencies and remote pickup frequencies governed by Part 74 on a secondary basis to full-service stations and other primary users.

LPFMs will be required to use transmitters that have been type-certified by the commission. And the stations must install and operate emergency alert system decoders, to pass along national emergency messages to listeners. They would not be required to install encoders.

Potential pirate owners
Former pirates who stopped broadcasting illegally when told to by the FCC may be eligible to apply for an LPFM. A supporter group called the Prometheus Radio Project said it would "assist stations in making the transition from their campaign of civil disobedience" to help members understand "the essentials of good radio practice."

A Prometheus member and former pirate operator who goes by the pseudonym Pete triDish said the rules are a good start and he would like the commission to make sure LPFMs have an opportunity to go digital. "The current IBOC proposals are designed to protect incumbents and don't allow for new entrants," he said. The FCC's order did not specify how or whether LPFMs can make a digital transition. When asked about this, FCC officials said the potential cost of digital equipment might be a concern to LPFM supporters. One of the original low?power petitioners agreed. Nick Leggett said low-power supporters most likely will insist on having a voice in the digital transition in the future. For now, he's pleased with the ruling. Asked if he would he join NAB if it created a new membership category for LPFMs, Leggett said yes. "Some of the LP people are former employees of high-power stations .... Some are former NAB members and some are current members. One precondition, they'd have to drop the Oxley bill."