When Congress gutted the low power FM service enacted by the FCC in 2000, it reduced the number of available LPFM frequencies around the country by more than two-thirds by implementing “third-adjacent channel spacing protections.” This forced LPFM stations to find a clear frequency with at least three channels separating it from existing local stations, which in urban areas is all but impossible. This single fact alone cut the number of potential LPFM stations from thousands to a few hundred at best, with most of those located in rural or suburban areas.
The passage of the “Radio Broadcasting Preservation Act,” however, did contain one caveat: the FCC was mandated to conduct an interference study to make sure the third-adjacent channel protections were necessary. The study was to be completed by February 21, 2001. It was actually finished in March, 2003, by the MITRE Corporation, who subcontracted the field testing of temporary LPFM stations in seven communities around the country.
The Amherst Alliance, upon discovering the report was finished but the FCC was sitting on it, filed a Freedom of Information Act request in May to make it public. The FCC blew it off, and correspondence escalated to a point where members of Congress might have gotten involved and/or a lawsuit to force the disclosure might have been filed.
This week, mysteriously, the 700+ page report was published in the FCC’s Electronic Comment Filing System. No fanfare whatsoever, not even a note to those of us behind the FOIA effort to let us know it was available. The reason may be due to the following conclusions:
“Based on the measurements and analysis reported herein, existing third-adjacent channel distance restrictions should be waived to allow LPFM operation at locations that meet all other FCC requirements [after four small revisions]…
The FCC should not undertake the additional expense of a formal listener test program or a Phase II economic analysis of the potential radio interference impact to LPFM on incumbent FPFM [full-power FM] stations…Perceptible interference caused during the tests by temporary LPFM stations operating on third-adjacent channels occurred too seldom, especially outside the immediate vicinity of the sites where the stations were operating, to warrant the additional expense that those follow-on activities would entail.”
And the National Association of Broadcasters and National Public Radio, who played Congress like a fiddle by claiming that LPFM stations would wreak havoc with their signals, may want to chew on this tidbit especially thoughtfully:
“In terms of the impact of an LPFM station due to interference on the audience of an FPFM station, in the worst case measured, the fraction of the protected coverage area of an existing station that could be subjected to harmful interference is 0.13%. In most other cases, this fraction is orders of magnitude smaller.”
Download the four main documents from the LPFM interference report here, in .pdf format:
Section 1 (MITRE Final Report, 4.4 MB)
Section 2 (Comsearch Field Test Plan, 2.4 MB)
Section 3 (Comsearch Test Procedures Plan, 664K)
Section 4 (Comsearch Field Measurement Data, 5.1 MB)
A cursory glance through the field data collected for the report brings up some additional interesting tidbits.
Comsearch (the subcontractor who conducted the field tests) placed public notices in each test location’s major newspaper and had announcements of the LPFM interference test played on the full-power FM station in the area closest to the frequency on which the test would take place. In each instance, no public complaints of LPFM interference were received, although interference complaints were received at some test locations that involved sources other than the test LPFM transmitter.
Most interesting quote from the field data section: “During the measurements at Avon [CT], locating a third-adjacent channel LPFM station relatively close to an FPFM [full-power FM] station did not seem to cause seriously degraded audio quality, except for the Walkman when located approximately 50 feet from the LPFM. This exemplifies how occurrences of degraded audio quality tend to be fewer, the closer the LPFM is located to the FPFM station.” (emphasis added)
Now that the hard data calls the NAB/NPR on their bullsh*t and justifies the original version of LPFM as laid out by the FCC in January, 2000 – will the agency follow through and revise its rules to allow for more stations to flourish? And what about all of those potential LPFM applicants who were ready to roll before the congressional meddling cut them out of the game? The FCC is accepting public comment on the study until September 12, although whether anything comes of it remains a huge question mark.
The political climate in D.C. is a lot different now than it was during the height of the LPFM policymaking saga three years ago. Mikey Powell split his vote on the LPFM service itself and has been reluctant at best to continue the rollout of LPFM stations. Mikey may want to re-think that now. There are other threats to an LPFM expansion as well, like the invasion of FM translator applications currently awaiting action at the FCC.
One lesson learned here is the fact that tenaciousness from the little guy can pay off. The Amherst Alliance (specifically, outgoing National Coordinator Don Schellhardt) stuck to its guns and was prepared to force the FCC to release the report. Otherwise, this news would’ve remained buried in the agency’s bureaucratic maw, as LPFM is supposedly safely off the mainstream political radar.
That is highly ironic considering the larger issue of media reform is now a hot potato in Washington. Those most-often quoted as the leaders of the media reform lobby – some of whom also worked on the LPFM battle – might want to refocus on what was considered a lost cause. Perhaps an amendment to pending legislation on media ownership is in order, one that would repeal the “Radio Broadcasting Preservation Act” entirely. That would combine a coup with fitting vindication.
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