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FCC filing regarding encroachment and translators - 9/26/2005

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FCC filing regarding encroachment and translators - 9/26/2005

Prometheus Radio has filed numerous comments to the FCC regarding its decisions on Low-Power FM radio. Here is a comment from September 26, 2005, in regards to the issues of enroachment and the spectral priority of translators and LPFM. To read the entire comment, visit FCC filing regarding encroachment and translators - 9/26/2005

In the Matter of: Creation of a Low Power Radio Service

1. Introduction
2. Encroachment (Get up! Get Out The Way! Move!)
   ---The Very Real Threat of Encroachment and the Need for
      Displacement Relief
   ---Current State of Interference Protection
   ---FCC Authority to Waive 2nd and 3rd Adjacency Requirements
   ---The Possibility of LCFM
   ---Outdated Claims of Interference to Digital Broadcast
   --- Issues With the MITRE Report
3. Spectral Priority of Translators and LPFM
   ---Claim That There Is No Proof of Problem
   ---Claim That Nothing Has Changed
   ---Faulty Translator Application Process
   ---Emergency Alert Issues
   ---Public Interest Arguments
   ---Localism
   ---Daisy Chain Disruption
   ---Speculation on the Future
   ---Claim of Spectrum Inefficiency of Small Transmitters
   ---Extension of the Freeze and Expectancy Issues
   ---Alternative Proposal
4. Less Contentious Matters
   ---Underwriting Abuse
   ---Multiple and Local Ownership Requirements for LPFMs
   ---Christian Community Broadcasters Proposals on Locally
      Produced Programming
5. Conclusion

Introduction
“In the words of the President of New Hampshire Public Radio, “We are all – public radio and LPFM
stations – here to serve the public. I believe judgments should be made on the basis of public service.”

Comments of the Station Resource Group Page 2, paragraph 3 (Apparently refers to former President Mark
Handley, who built a strong relationship between the public station and a local low power radio station.)

By these reply comments, Citizen Petitioners respond to the objections to and support for
improvements in the LPFM service by the National Association Of Broadcasters (NAB),
National Public Radio (NPR), the Named State Associations of Broadcasters,
Edbgewater/Radio assist Ministries, Public Radio FM Translator Licensees, Saga
Communications, Station Resource Group, Educational Media Foundation (EMF),
National Translator Association), REC Networks (REC), Pacifica Foundation, Christian
Community Broadcasters, and others. Our original requests in the Comment phase of
this Further Notice Of Proposed Rulemaking (FNPRM) stand largely unchanged, though
in response to some comments we have described our proposals in greater detail.
Contrary to the assertions of some in this proceeding, the FCC has more than adequate
record to determine a new balance between translator stations and locally originating
LPFMs. And contrary to the assertions of some in this proceeding, the FCC has more
than adequate regulatory authority to give low power stations more options when faced
with encroachment. There were supporting comments for many of the proposals that
have been put forward by Citizen Advocates, REC, and others. We call upon the FCC to
move forward with these proposals to improve the availability and stability of the low
power radio service.

To read the entire comment, visit FCC filing regarding encroachment and translators - 9/26/2005