CGC 763 LPFM response by Chris Hays, Oct 2, 2006

I think your statement, "LPFMs serve relatively small areas while causing interference over broad areas. That's why the FCC stopped allocating 10-watt Educational stations aeons ago" is incorrect.

Webster's New World Dictionary defines "aeon" or "eon" as "an extremely long, indefinite period of time; thousands and thousands of years." 10 watt Non-Commercial FMs were removed much more recently. The reason they stopped allocating them was not for the noble purpose you indicate, but rather because NPR in an attempt to find more non-commercial frequencies for networked stations, lobbied the FCC for it. They even had a computer program to model the result. This program when run on the Los Angeles market came up with exactly zero new available frequencies, by the way.

Grand fathered stations on Mt Wilson are only protected to their "on paper" class B coverage contour, so these overlaps are inevitable and will occur just as the occasional fringe coverage obliteration will occur due to a new class A somewhere.

There is still a need for low power stations. But it would have been better to just reactivate the old class-D rules. The new rules allow for up to 100 watts ERP at a height of 100 ft. The old rules allowed for just about anything with a TPO of 10 watts. 100 watts ERP would only have been possible with a gain of 10 at the antenna.

Chris Hays

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