Part 73, Subpart G, Section 73.825 is a regulation that addresses the minimum distance separations between LPFM stations operating on the Reserved Band channels 201 through 220 (88.1 to 91.9 MHz) with television stations operating on Channel 6.
Protection of TV Channel 6
LPFM stations operating on the reserved band frequencies 88.1 to 91.9 (Channels 201 to 220) must provide protection to TV stations operating on radio frequency (RF) channel 6 (82-88 MHz). LPFM stations can demonstrate protection through the use of a distance separation chart. There are separate distance separation charts for full-power TV stations and for low-power TV (LPTV) facilities including LPTV stations, class A TV stations, TV translators and digital replacement translator stations.
LPFM stations may waive the distance separation requirements by getting a letter of consent from the impacted TV station.
LPFM stations that do not meet the distance separation requirements may conduct a technical study and request a waiver using the contour method that applies to FM translators as outlined in §74.1205 of the FCC Rules. Applicants using the waiver method must notify the impacted TV station of the LPFM proposal.
Rule being considered for elimination
FM facilities in the reserved band must provide protection to TV stations operating on Channel 6. The original rules for full-service noncommercial FM stations and FM translators was created in 1985 to address concerns that older TV receivers from the 1960s and 1970s would receive interference from FM stations. This LPFM rule is a byproduct of the full-service FM rule.
The FCC is currently considering in MB Docket 03-185 to completely repeal the three FM to TV6 rules (§§ 73.525, 73,825 and 74.1205). In the larger part of the proceeding, the FCC is considering the future of LPTV stations operating analog audio carriers on 87.75 MHz (also referred to as "FM6" or "Franken FM") and the potential for FM expansion into the Channel 6 spectrum on a shared basis with TV stations.
In support to repealing the rule, National Public Radio noted that the rule applies to analog television since the digital transition, there has been a 100 percent change in consumer receiving equipment and that modern receivers are more resistant to this type of interference.
Opposing the rule repeal includes National Association of Broadcasters, America's Public Television Stations (PBS) and WPVI-TV, Philadelphia, PA.
Regulatory history
This rule was enacted in the original 2000 LPFM Report and Order with distance separation charts for LP-10 and LP-100 stations in respect to "all TV Channel 6 stations". Later that year in the Order on Reconsideration, the FCC realized their calculation error and reduced the minimum distance separation table, clarified that table is for full-power TV stations and then added a separate table for protections to low power TV stations. In the 2012 Sixth Report and Order, the LP-10 class of service was removed and the appropriate distance separation tables were removed. In the 2020 LPFM Tech Order, a circulation draft of the order included a complete elimination of the rule, but due to some last minute protesting from WPVI, Philadelphia, the FCC tabled the complete repeal of the rule, instead opting for a rule that would allow LPFM stations to obtain letters of consent and to address the original request made by REC Networks in this proceeding to allow LPFM stations to use the FM translator to TV6 rule in lieu of the distance separations, by allowing contour studies by waiver request conditioned on the LPFM station advising the impacted TV 6 station of the application.
Federal Register citation
65 FR 67303, Nov. 9, 2000, as amended at 78 FR 2106, Jan. 9, 2013; 85 FR 35573, June 11, 2020
Text of regulation 47 CFR §73.825
§ 73.825 Protection to reception of TV channel 6.
The following spacing requirements will apply to LPFM applications on Channels 201 through 220 unless the application is accompanied by a written agreement between the LPFM applicant and each affected TV Channel 6 broadcast station concurring with the proposed LPFM facilities.
(a) LPFM stations will be authorized on Channels 201 through 220 only if the pertinent minimum separation distances in the following table are met with respect to all full power TV Channel 6 stations.
| FM channel number | LPFM to TV
channel 6 (km) |
|---|---|
| 201 | 140 |
| 202 | 138 |
| 203 | 137 |
| 204 | 136 |
| 205 | 135 |
| 206 | 133 |
| 207 | 133 |
| 208 | 133 |
| 209 | 133 |
| 210 | 133 |
| 211 | 133 |
| 212 | 132 |
| 213 | 132 |
| 214 | 132 |
| 215 | 131 |
| 216 | 131 |
| 217 | 131 |
| 218 | 131 |
| 219 | 130 |
| 220 | 130 |
(b) LPFM stations will be authorized on Channels 201 through 220 only if the pertinent minimum separation distances in the following table are met with respect to all low power TV, TV translator, and Class A TV stations authorized on TV Channel 6.
| FM channel number | LPFM to TV
channel 6 (km) |
|---|---|
| 201 | 98 |
| 202 | 97 |
| 203 | 95 |
| 204 | 94 |
| 205 | 93 |
| 206 | 91 |
| 207 | 91 |
| 208 | 91 |
| 209 | 91 |
| 210 | 91 |
| 211 | 91 |
| 212 | 90 |
| 213 | 90 |
| 214 | 90 |
| 215 | 90 |
| 216 | 89 |
| 217 | 89 |
| 218 | 89 |
| 219 | 89 |
| 220 | 89 |