RM-9208, RM-9242 and RM-9246: Difference between revisions

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RM-9208, RM-9242 and RM-9246 (view source)

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'''''This article is currently under active development.'''''  
'''''This article is currently under active development.'''''  


RM-9208 was a Petition for Rulemaking written by Nickolaus E. Leggett and Donald J. Schellhardt and was one of two petitions that became the catalyst for the creation of the Low Power FM (LPFM) radio service through the creation of one watt "microstations" in the AM and FM broadcast bands.
In the late 1990s, three separate ''Petitions for Rulemaking'' were filed with the FCC which would become the catalyst for today's Low Power FM (LPFM) radio service.


RM-9242 was a Petition for Rulemaking written by Rodger Skinner
'''RM-9208''' was written by Nickolaus E. Leggett and Donald J. Schellhardt proposed a community and neighborhood broadcast service through the creation of one watt "microstations" in the AM and FM broadcast bands.


Because of how the FCC would eventually "combine" these two rulemaking petitions through actions during the process, this article will discuss them both as many comments received in the proceeding address various aspects of the different proposals.
'''RM-9242''' was written by Rodger Skinner which featured a comprehensive plan for primary, secondary and temporary special event radio stations operating between one and 3,000 watts.
 
'''RM-9246''' was written by Web SportsNet, Inc. which proposed the use of low power FM broadcast transmitters for special events and sports venue broadcasting.


== The Leggett/Schellhardt proposal (RM-9208) ==
== The Leggett/Schellhardt proposal (RM-9208) ==
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During this proceeding, Leggett and Schellhardt sent the FCC Commissioners a videocassette of "[[Wikipedia:Pump Up the Volume (film)|Pump Up The Volume]]", a 1990 film about a fictional pirate radio station operator.  
During this proceeding, Leggett and Schellhardt sent the FCC Commissioners a videocassette of "[[Wikipedia:Pump Up the Volume (film)|Pump Up The Volume]]", a 1990 film about a fictional pirate radio station operator.  


=== Supporting comments ===
Initial comments in support of the petition came from various individuals, some who to this day, remain involved in the LPFM movement.  Dave Solomon, who would later form the Low Power FM Advocacy Group supported the concept of allowing FM translators to be able to originate their own programming.<ref>https://www.fcc.gov/ecfs/search/search-filings/filing/201375</ref>  In February, 1998, Michael Reynolds, who at the time was the owner of the [[Wikipedia:w0kie|W0KIE Satellite Radio Network]] and currently the principal of KOKT-LP, Tulsa, Oklahoma, suggested that the service be unlicensed and allow up to 15 watts.<ref>https://www.fcc.gov/ecfs/search/search-filings/filing/201239</ref>  The Puerto Rico Radio Broadcasters Association, which generally supported the creation of a microradio service on the mainland, requested that Puerto Rico be excluded from the service due to the unique terrain and the need to protect the [[Wikipedia:Arecibo Observatory|Arecibo Radio Astronomy Observatory]].<ref>https://www.fcc.gov/ecfs/search/search-filings/filing/201286</ref>  On February 16, 1998, REC Networks filed comments supporting the concept of LPFM and Low Power AM (LPAM) broadcasting but opposing the "cell" concept.  Instead, REC called for the ability for stations to use the AM band with 1620~1710 as a first choice before choosing lower frequencies and for FM, the ability to use 87.5, 87.7, 87.9 as well as the normal 100 FM channels. In more rural areas, the FCC could reintroduce Class D FM stations with a maximum of 10 watts TPO and that the station operation be supervised by someone who has proven a level of radio aptitude through the possession of an Amateur Radio Service license of General class or greater.<ref>https://www.fcc.gov/ecfs/search/search-filings/filing/201569</ref>


On March 5, 1998, the FCC would extend the comment period on RM-9208 by nearly two months.<ref>https://www.fcc.gov/ecfs/search/search-filings/filing/201887</ref>
On March 5, 1998, the FCC would extend the comment period on RM-9208 by nearly two months.<ref>https://www.fcc.gov/ecfs/search/search-filings/filing/201887</ref>


On May 22, 1998, the FCC would extend the reply comment period on RM-9208, RM-9242 and RM-9246 (event broadcasting) for a period of two months.<ref>https://www.fcc.gov/ecfs/search/search-filings/filing/208876</ref>
On May 22, 1998, the FCC would extend the reply comment period on RM-9208, RM-9242 and RM-9246 (event broadcasting) for a period of two months.<ref>https://www.fcc.gov/ecfs/search/search-filings/filing/208876</ref>
=== Comments in Opposition ===
In opposition, Susquehanna Radio cited the equipment available from Free Radio Berkeley that would permit the microstations to be able to broadcast at over 40 watts, instead of the one watt proposed.<ref>https://www.fcc.gov/ecfs/search/search-filings/filing/204645</ref>  JEM Broadcasting Company offered insight in to the plight of daytime AM stations at the time and instead of the proposal as written, the FCC should reinstate the Class D service and allow for one way broadcasting in the Citizens Band radio service.<ref>https://www.fcc.gov/ecfs/search/search-filings/filing/204703</ref> The New Jersey Broadcasters Association called the petition severely flawed and may not be workable, especially on FM and suggests that the FCC proceed very slowly before approving any radical changes.<ref>https://www.fcc.gov/ecfs/search/search-filings/filing/204822</ref> Rodger Skinner, the author of the competing LPFM petition [[RM-9242]] cites the fact that Leggett and Schellhardt have no experience in broadcasting citing various small issues with the petition and promotes RM-9242 as a more comprehensive proposal. Skinner also takes issue with Leggett and Schellhardt sending a copy of the film "Pump Up The Volume" to the Commissioners.<ref>https://www.fcc.gov/ecfs/search/search-filings/filing/204817</ref>  Many comments filed were comments jointly addressing the RM-9208 and RM-9242 petitions such as the one from National Public Radio, which states that the FM band is too crowded and that any kind of new LPFM service could forestall the development of In Band On Channel (IBOC) digital radio (later to be known as [[HD Radio]]).<ref>https://www.fcc.gov/ecfs/search/search-filings/filing/204871</ref>  Greater Media called the petition would have disastrous consequences to the current allocation scheme and create massive areas of interference degrading the quality of radio service while providing no realistic economic opportunity, suggesting that the internet would be a better method for new voices.<ref>https://www.fcc.gov/ecfs/search/search-filings/filing/204866</ref> The National Association of Broadcasters (NAB) states that 1 watt microstations would be an inefficient use of spectrum and would cause issues if existing stations are forced to change channels in order to clear spectrum for a low power FM service. NAB would cite the 1978 decision that discontinued any new 10-watt Class D FM stations citing that higher powered stations are a more efficient use of spectrum. They would also state that any new low power service would have impacts on the ability to implement IBOC, especially if low power stations are permitted on first adjacent channels. NAB states that LPFM is not the way to curb pirate radio broadcasters and that other options are available such as time purchase on existing stations, citing the case of Beat Radio in Minneapolis and that the internet can be used for broadcasting.<ref>https://www.fcc.gov/ecfs/search/search-filings/filing/204876</ref>  Additional opposing comments would be received by USA Digital Radio, the predecessor to what would become HD Radio<ref>https://www.fcc.gov/ecfs/search/search-filings/filing/204867</ref> and various state broadcaster associations.


=== The "cease fire" demand letter ===
=== The "cease fire" demand letter ===
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== The Skinner proposal (RM-9242) ==
== The Skinner proposal (RM-9242) ==
== The Web SportsNet proposal (RM-9246) ==
== Comments received in these proceedings ==
=== Comments in support ===
Comments in support of the concept of LPFM broadcasting were received mainly by members of the community as well as from community organizations, civil rights organizations and media justice organizations.  Commenters discussed how, because of the lifting of broadcast ownership caps in the ''Telecommunications Act of 1996,'' that consolidation of radio stations, especially by Clear Channel Communications, now iHeart Media has reduced the diversity and uniqueness of local radio broadcasting through the use of "national playlists" and consolidated operations. They would state that many local neighborhoods, ethnic groups and other special interests deserve to have their own voice.  Some supporters of the LPFM concept state that the service can be easily implemented through permitting existing FM Translator stations to be able to originate programming.<ref>https://www.fcc.gov/ecfs/search/search-filings/filing/201375</ref>
=== Comments in opposition ===
Very strong opposition to the concept of LPFM broadcasting came from incumbent broadcast owners, the state broadcasters associations and from national interests such as the National Association of Broadcasters, National Public Radio and Educational Media Foundation.  Comments opposing LPFM were mainly along the lines of concerns over increased interference in the band, potential displacement of existing stations in order to create dedicated channels like what was proposed in RM-9208, economic impacts to incumbent broadcasters, especially AM daytime stations and will impede the development of In Band On Channel (IBOC) digital audio broadcasting, now known as HD Radio.  Some of the opposing comments stated that LPFM stations were inefficient use of spectrum citing the 1978 Commission actions that froze the assignment of new 10-watt Class D radio stations in all areas except Alaska as a recognition by the Commission that higher powered FM stations are a more efficient use of the spectrum.


== Other LPFM concepts suggested ==
== Other LPFM concepts suggested ==
During the proceeding, other organizations had suggested various different concepts for a low power radio service through comments.
While some organizations supported the concept of LPFM, they opposed certain technical elements of the petitions that were already filed.  There were also opposing comments filed by petitioners towards the other petition's concept.  Some of the concepts for a new LPFM service from organizations other than the petitioners are shown here:


=== The Committee on Democratic Communications/National Lawyers Guild Concept ===
=== The Committee on Democratic Communications/National Lawyers Guild Concept ===
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