From: FmAtlas@aol.com Date sent: Mon, 2 Aug 1999 01:14:56 EDT Subject: Comments regarding LPFM 99-25 or 99-200 To: ecfs@fcc.gov Before the Federal Communications Commission The Portals Washington DC August 2, 1999 Re: LPFM 99-25 or 99-200 (From Bruce F. Elving, Ph.D. Low power FM proceeding (PO Box 336, Esko MN 55733-0336 (Phone (218) 879-XXXX (FAX (218) 879-XXXX (FmAtlas@aol.com Comes now Bruce F. Elving, Ph.D., publisher FM Atlas and FMedia! newsletter, and owner of translator station W280CT 103.9 Hermantown MN. These comments amplify what I earlier said in support of the FCC's LPFM proposal. I would like to point out that nationally several translators are operating on second adjacent channels to primary stations, apparently without interference. Take the case of K214DF *90.7 Golden Valley MN, with transmitter in downtown Minneapolis. It is midway on the dial between KNOW *91.1 St. Paul MN and KFAI *90.3 Minneapolis. I have considerable experience with FM receiver design and modification, and have discovered that with ceramic filters in widespread use, FM radios are far more selective than they were 20 years ago. Ceramic filters started to appear in about 1978, along with widespread use of integrated circuits. Thus, virtually all post-1978 FM radios can receive satisfactory signals from stations spaced 400 kHz from each other in the same market. This even includes subcarrier reception out to 92 kHz. The argument of the Audio Information Services for the blind that SCSes will be impaired does not appear to hold true. Radios can be both selective and wide-banded enough to pass the entire monophonic main channel, the stereo subcarriers and all ancillary services at such frequencies as 57, 67 and 92 kHz. Similarly, in-band, on channel digital audio broadcasting should also be possible in most cases at 400 kHz local spacings, especially when the "low power" station is considerably lower in its effective radiated power than the originally-licensed station. Certainly, at 600 kHz spacing there should be no problem. I envision a system where low power stations can be locally operated with individual residency requirements for the owner, limits placed on how many low power stations one person or company can have, no co-ownership of low power with high power stations in the same market (nor LMAs either), but with provision for translators to "grow up" and become either fulltime low power stations, or hybrid parttime translators and low power stations. I would propose, for example, that my W280CT 103.9 Hermantown MN, which is currently off the air because it lost its transmitter site, and which is awaiting the lifting of the current freeze to relocate to a new site, be selected as a station to test whether or not the concept of low power FM can function in a major market. W280CT is 400 kHz away from KZIO 104.3 Two Harbors MN and 600 kHz from KUMD 103.3 Duluth MN. Licensees of low power FM stations, as I see it, should be individuals, small businesses or nonprofit groups such as churches and clubs, with time sharing a possibility among several local stations as a means of avoiding auctions. I am neutral whether or not the stations should be commercial or noncommercial. Indeed, some of the stations might perform a function on main channel FM--in stereo--that many services are offering only over SCS. With consolidation rampant in commercial and even noncommercial FM, the opportunities for individual operators to become subcarrier lessees are becoming limited. The picture with a digital system would probably be no better. Broadcasters would have the channel capacity, but might be exceedingly loathe to make use of that capacity--even to groups that could afford to pay the going rate, much less to nonprofit entities, such as reading services. There is a prejudice that adding subcarriers or ancillary services might negatively affect the quality of the main channel--plus owners of large broadcasting entities are often in distant cities, impersonal, and difficult to reach by the average would-be subcarrier operator. In summary: Low power FM can succeed now because radios are better designed with wide-bandwidth for the channel they are tuned to, but having excellent alternate channel selectivity. Consolidation in the industry limits entry into the marketplace, even for those desiring to be on subcarriers. My FM Atlas shows a declining interest on the part of broadcasters embracing subcarriers--something on the order of 10 percent or less of the stations. This is down from 28 percent in the early 1980s, when the FCC used FM Atlas data on subcarrier utilization nationally as a reason for expanding the FM baseband to include the 92 kHz SCS channel. Politically, it makes good sense for the FCC to pursue low power FM at this time. I am sure that even the organizations that presently oppose it will come around to realize it is a good thing. Groups such as state broadcasters' associations should, as the result of new low power stations being authorized, realize membership gains, more stations subscribing to their newsletters, more dues collected from member stations, and more voices to serve the nation, and thereby help the other positive public service type causes the broadcast industry so typically espouses. FCC: Do your job and help usher in the era of low power FM! Respectfully submitted, Bruce F. Elving, Ph.D.