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todayJune 21, 2021 120

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Today is the last day members of the public can offer comments on whether 100-LP-FM Radio Stations should be granted permission to broadcast at 250-LP-FM. We are currently broadcasting at 100W and if this petition gets approved we’ll be able to broadcast at a higher wattage, 250W, and might be able to reach a little bit further around the hills and valleys of Kohala where KNKR is currently not available.

You can express your comments on the FCC website by filling out this form.
In the top part where it says Proceeding enter RM-11909

The FCC has recently accepted a petition for rulemaking proposing an upgrade to Low Power FM service’s maximum power to 250 watts.  REC Networks Petition for Rulemaking (PRM), RM-11909, filed over a year ago, proposes a simplified approach for a 250 watt Low Power FM (LPFM) class.  The current maximum wattage for LPFM is 100 watts.  Many LPFM operators have been presented with limitations at that wattage level, including interference due more FM translators being added to the FM band and the poor wall-penetration of 100 watts.

The FCC has announced it will start taking comments concerning REC’s PRM, which gives the public until June 21 to weigh-in on the matter.  Two previous proposals were denied by the FCC for being too complex.  There is some hope for this PRM gain traction due to the pending Democratic majority on the Commission, which the previous Commission overtly sided with the commercial radio industry, and there was hint within the footnotes of a recent Draft Order denying Petition for Reconsideration concerning LP-250 that the Commission would take a look at a more simplified LP-250 proposal. The Petition can be read here. (5.3MB PDF)
It is important the members of the public provide comments if they are in support of this.

Existing LPFM stations (and their listeners) should provide comment to the FCC describing their station:

(1) What limitations is the station faced with coverage-wise?  This includes ability to penetrate walls, hills, weak signal areas, the station doesn’t cover the whole community, coverage within a rural community is too spread-out for 100 watts, urban coverage is blocked by buildings and/or trees, interference is a problem, etc.  In general: (A) How is your signal penetration, (B) do you have HD interference, (C) is there a rim-shot or grandfathered full power station causing interference on your same channel, (D) is the excessive interference from newly licensed FM translators, (E) is your signal too faint to even cover your licensed area, (F) is there susceptibility to tropospheric ducting, and (G) does your target audience and “sphere of local community” extend outside your coverage area?

(2) What unique community service do you offer that now other station offers?  Explain your local emphasis?  Are there no other community stations or Low Power services in the area?  Are there too many FM translators providing no local programming?

(3) How does your coverage relate to your income and sustainability of the station?

(4) Are there specific audiences that you serve that are underserved by other media outlets?Comments are filed by any member of the public at FCC’s Electronic Comment Filing System (ECFS) visit  At the top of the webpage, click on “Submit a filing”.  You can either submit a standard filing, where you create a PDF you attach, or an “Express Filing”, where you can create a short text statement on the website.  In either case, under “Proceeding” enter “RM-11909“.  All members of the public may comment. Make your voice heard!

Written by: knkr

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