9/5/05  Reply Comments can be filed here; the deadline was extended to September 22 thanks to RECNET.  Reply Comments should be specific and directed toward supporting or rebutting Comments by LPFM friends and foes.  Do not use the Express Comment system (which is not designed to handle Replies) and answer "Reply Comments" to question 12 on the Expert Comment system here.

More than 12,000 Comments were filed from  July 7 to August 22.  More than 99% were form remarks generated by Free Press, Prometheus Radio Project, Protect Radio and WPVM-LP Asheville.


Read Christian Community Broadcasters Plan for the Future of LPFM  - Support this bold eight-point CCB Plan with your Reply Comments

RECNET summarizes and critiques 32 pro and con Comments!  Must Reading!

Bill Turner: Cyprus. TX - newcomer to LPFM advocacy.  Bill has many years full-power experience and now wants to own his own LPFM station.  His comments are continued here.

Michael Birdsill; Chico, CA - six pages of Comments supporting LPFM

Thomas Smith, Sun Prairie, WI - nine pages of pro-LPFM Comments

REPLY COMMENTS - only non-form Reply Comments

Taylor University Broadcasting concerned about their translator applications getting dismissed

Eric S. Bueneman supports Amherst's LP AM with C-QUAM Stereo

Joseph D'Alessandro WRBG-LP - faces fatal encroachment; passionate legal plea for survival

Big Bend Broadcasting suggests cooperation between LPFM and translator operators

NAB Wants "Status Quo" to Remain, Favoring Full-Power & Translators

In its Comments, NAB requests that the third-channel rule to remain, the translator freeze to be lifted, and LPFM / translators should remain co-equal.  NAB argues that "Pending applications from the 2003 FM translator window have not 
impeded, in any measure, the commission's ability to process LPFM 
applications under the existing rules." 

NAB further suggests that displaced LPFMs, like displaced LPTVs, be allowed to move when displaced by full-power move-ins or upgrades and that giving new protection to LPFM could thwart full-power upgrades and impede Digital Radio.  NAB further claims that "only one LPFM has been shut down because of full-power displacement."

Response by CCB: Maybe only one operating LPFM has been shut down so far, but many LPFMs have never gone on the air because of full-power encroachment and many current LPFMs will be shut down in the future for the same reason.  Further, Digital Radio will severely hurt LPFM, not the other way around.

Free Press does not consider it unusual that nearly 12,000 people responded to its LPFM campaign; it has an email list of 200,000 and generated 92,000 comments related to media reform and 15,000 emails to Congress supporting LPFM.  Members are encouraged to use an online form to invite other people to make Comments.  Started in 2002, Free Press now has a paid staff of 14 in Washington and Massachusetts.

While public support is great, if you think we will "definitely" get Primary Status, you need to wake up and listen to encroaching full-power stations!  Hopefully FCC staffers will say "Free Press is an effective lobbying organization." 

List member Rick Shaftan used to work in D.C.; his job was to send out mass-produced "vague responses" to everyone who participated in a mass campaign.  When someone sent a unique personal letter to a Congressman, the letter was read and often received a personal response.

Read the FCC Proposal

If you have not yet read the Notice of Proposed Rulemaking click here - it is the most important document on Low Power FM since its founding 2000. It was released by the FCC on March 17, 2005; nearly four months later on July 7 it appeared in the Federal Register, beginning the Comment period.  

Three types of actions, comments, and questions are covered in this 31-page document: 
(1) Changes in the rules (i.e., LPFM stations can now move 5.6km anytime as a minor modification and processing of translator applications are frozen for six months)
(2) The FCC is allowing various changes on a waiver basis (i.e., 18-month extension to CPs and sale of LPFM stations)
(3) The FCC asks dozens of questions about everything from interference / encroachment concerns to the maximum number of stations an LPFM operator should own. 

The Notice invites comments on some of the bigger issues around LPFM. A key issue is whether low power radio stations should be displaced "at the whim of a hat" by full power stations. Comments might explore whether local low power stations should be able to displace non-locally-programmed translator stations. The Notice also asks whether low power stations should be able to be bought, sold, or transferred from one licensee to another entity. 

Free Press Wording Used in 10,000+ Filings

The FCC should make every effort to protect low power FM (LPFM) and the community-oriented content it provides. Unlike the consolidated commercial radio landscape, LPFM stations provide quality local programming and enhance the diversity of local voices available to their communities.

Full power stations should not be allowed to cut into the coverage area of LPFM stations and knock them off the air. The FCC should adopt a policy that denies a full power station\'s modification application if granting the application would reduce the coverage area available to LPFM stations.

LPFM stations also should be afforded higher priority than translators.  Translators only repeat programming, sometimes from hundreds of miles away. Every new translator takes the place of a potential LPFM station that would provide original local programming. The FCC should give locally controlled and operated LPFM station applications precedence over translator applications.

The FCC should consider the circumstances under which low power stations operate when determining the rules for their licensing. For LPFM service to be more accessible to community groups, the FCC should modify its rules so that typical changes on a non-profit board would be permissible under FCC rules. Similarly, the FCC should allow low power stations a greater amount of time to construct stations and to shift ownership.

The FCC has the responsibility to protect the service of low power radio and nurture its growth. Congress is considering legislation to expand the service by removing the restrictions on the third-adjacent channel, which could allow LPFM to expand into larger communities. The FCC should take every opportunity to tell Congress that the technological landscape is ready for this change.

A loyal listener of WPVM-LP comments: I would love to hear WPVM-LP when I travel 60 minutes at least each day to and from my clients' homes.  As it is, I have to PULL MY CAR OVER TO THE SIDE OF THE INTERSTATE just so I don't miss my favorite show.  Amazingly enough, we do receive WPVM's signal in the attic of our home in Horse Shoe but it is INCREDIBLY HOT up there so we rarely get to hear it. 

I have a very hard time listening to WNCW because every other song in Bluegrass and all bluegrass songs sound the same to me.  Please LET ME KEEP MY SANITY and increase the SIGNAL STRENGTH of WPVM. (CCB NOTE: WNCW is a nearby full-power NCE station.)