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Prometheus Radio’s Brandy Doyle on the road ahead for LPFM

The famous Prometheus Radio Project logo.

The Local Community Radio Act has been law now for a little more than three weeks, and since then the hardy radio activists at the Prometheus Radio Project have been hard at work mapping the road ahead. We here at Radio Survivor have many questions about what’s next for low-power radio, and we’ve also fielded questions from several RS readers. Lucky for us, Prometheus policy director Brandy Doyle was willing to fill in some of the blanks.

What does the FCC have to do first?

Those of us who’ve been watching the FCC for years know that just because the Act was signed into law doesn’t mean the Commission would be launching right in to issuing licenses. So, I first asked her if the FCC first would have to open up a proceeding to take public comment.

“Yes,” she says, “we think the FCC will need to do a rulemaking to clarify the intent of the new law and update the rules going forward. Hopefully that rulemaking will open this spring, probably after the Auction 83 translator situation is addressed.”

That translator situation refers to the fact that the Commission has a queue of repeater station applications to resolve that have been frozen since 2003. According to Doyle, “the pending translator applications are the number one issue impacting LPFM availability. In many markets, translator applications flood nearly all available channels, leaving almost nothing for LPFM.” At the same time, “the Local Community Radio Act requires the FCC to ensure spectrum availability for LPFM, and we know the Commission is working on solutions that comply with the law.”

As to how the FCC will resolve this conflict, Doyle says that, “we (at Prometheus) think the FCC can sort the translator situation without a new rulemaking, but we don’t know yet what they will do.”

Will there be room for new LPFMs in the most crowded markets?

As a resident of Chicago, the third largest market in the US with a very crowded radio dial, I have a real concern about whether there will be an opportunity for any LPFM stations at all within the city. The same concern goes for other big markets like Los Angeles and Chicago.

Doyle answers this concern with some optimism. “In the centers of top markets such as Chicago,” she says, “the FCC will likely need to use its authority to grant second-adjacent channel waivers to locate new LPFM stations.” These waivers would allow an LPFM to be situated just two spaces on the dial away from a full-power station. For example, a low-power station could be at 101.5 when there’s a full-power station at 101.1. Doyle says that Prometheus hopes “such waivers will go to any station that can demonstrate an absence of predicted interference using the contour method, which accounts for terrain in allocating stations.”

Are old TV channels 5 & 6 new frontiers for LPFM?

With the digital television transition behind us there are now some more useable frequencies on the far left end of the FM dial. Additionally there’s been some talk about opening up the space just left of the FM dial–formerly used by analog TV channels 5 and 6–to be used for radio. The possibility of more FM real estate has many would-be community broadcasters wondering if that means more space for LPFMs.

Doyle expresses a bit of caution about proposals to open up more FM space. “We want to see LPFMs throughout the dial, however, so we’re against any proposal that might relegate LPFMs to the newly available spectrum or assumes that this new space is a complete solution for LPFM availability. We’re also concerned about proposals that require people to buy new radios (an issue with the lower TV channels).”

Nevertheless, she says that, “with that caveat, we’re excited about any new spectrum for low power FM.”

10 watt stations — ever?

“Haven’t heard anything.”


Big thanks go to Brandy for taking the time to answer my long questions and make some difficult prognostications. A lot of work lies ahead for Prometheus and community radio advocates this year. But at least in 2011 the focus will be on getting stations licensed and built.

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2 Responses to Prometheus Radio’s Brandy Doyle on the road ahead for LPFM

  1. John Broomall February 1, 2011 at 6:35 am #

    We have just completed an analysis of the top thirty radio markets for a available frequencies based on using second and third adjacent channels for 100 or 10 watt LPFMs.

    Nothing is available in Chicago, even considering 2nd adj. In fact, the largest market with anything available based on LCRA is Phoenix, market #15. Only three other top thirty markets have 100 watt openings and three have 10 watts frequencies.

    John Broomall

    Christian Community Broadcasters

  2. Michi Eyre-REC Networks February 1, 2011 at 8:46 pm #

    On Auction 83

    I feel that we should go through an LPFM rulemaking first. I would like to now just see the FCC take the LCRA into consideration but also take into consideration other changes to expand availability of LPFM stations and to remove unnecessary restrictions that only exist in the LPFM service. This includes additional subclassing of translators, removal of IF protection requirements and restructure of protection to LPTV and Class A TV stations on Channel 6.

    Auction 83 “Ten-Cap”

    REC agrees with Prometheus and EMF that the 10-cap may not work out, especially given the situation expressed by Common Frequency (something that REC has known about for years, especially in Los Angeles). REC has developed a process where translator applications would not be able to advance unless within at least 70% of a translator’s service contour (based on census blocks), an LP-100 station can be placed on at least two channels. This will address EMF’s concern about the impact of the 10-cap on placing translators in rural areas. We are still doing the analysis on how many translators meet this guideline but even in areas where the translator does not meet the 70% guideline, LPFM may still be available in some portions of the proposed translator’s service area. The EMF/Prometheus concept may also work but I fear much more speculation and a bigger mess for the FCC to clean up. We would support the concept if it comes up as an FCC proposed policy.

    Clean the records

    We feel that two significant things need to take place before any translators are considered. We must go through and remove translators that with defective parameters (such as the Gold Coast groups in Los Angeles) and groups with more than one channel with significantly overlapping service areas should be reduced to one channel. In addition, we need to remove the speculators, those who prior to the 2003 had no broadcast holdings. In order to balance LPFM and translators and integrate them into the FCC’s localism doctrine, we must assure that those who are applying for translators already have a primary station ready to be placed on them instead of seeing paper translators being sold off. RAM/Edgewater has already done enough damage in this department. If I had come up with that idea, I would not be unemployed and living in a trailer.

    The use of Channel 5 and 6

    This is one area where REC and Prometheus is about 100 miles apart on. I would rather see 30 or 60 new channels of FM radio being shared by LPFM stations in a new batch of real estate which a new radio receiver which is widely available in Japan can be used. I feel that if someone wants to hear a broadcast because it meets their specific cultural needs, they will go out of the way to purchase a radio. Purchasing a Japanese FM radio would overall be a lot less expensive than a subscription service (such as TJS in Los Angeles and other foreign language SCA services) or purchasing broadband service and equipment. As I mentioned after the KUSF story broke, imagine 10 new diverse voices just in the city alone? Plus, more voices in the East Bay, Berkeley, Oakland, new voices in Marin County and the South Bay. All of this without the interference and encroachment issues. I totally support 6 or 12 MHz of spectrum fairly useless to digital television being used as a haven for localism and diversity or in the case of Venture Technologies markets, 6 MHz of space being wasted on one FM audio service. I do not consider REC’s or anyone else’s proposal to add spectrum as “relegation” as we are not proposing any changes to the LPFM service in the 88-108 band. If there are channels available in the main band, they should be able to get them but going into the new-band would mean that less threats from encroachment and interference and in some metro areas, it may be the only choice.

    Room in the crowded markets

    We agree that it is not possible to place LPFM in many major cities. In addition to Phoenix (which is a fairly wide area availability) as John Broomall suggests, we have been able to find pockets in various metros. I will be releasing information soon based on ENAC reports we have ran on metro areas where channel availability is possible in pockets.

    With Prometheus running under new leadership, it’s time they think outside the box and be willing to take risks where it comes to new methods of achieving goals of localism. I am willing to buy a new radio.. In fact, I will pick one or two up when I am in Akihabara when I go to Japan next year.

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