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LPFM—what's next: a summary for applicants

February 9, 2002
By Michael Brown

1. Public notice for window 4/5 soon!

According to FCC staff, sometime in the next several weeks the FCC will release a Public Notice of the Singleton LPFM applicants from Window 4/5 that are Accepted for Filing. These are applicants in which there are no other Mutually Exclusive (MX) applications that can possibly be in conflict. If there are other MX applicants, even if your application might eventually win on points, you will not appear on this Public Notice. Getting to the Accepted for Filing status also means that the FCC found no immediate glaring errors and omissions in your application. It usually, but not always, means that your application will be granted if there are no Petitions to Deny filed.

The Public Notice will state a date, usually 30 days later, by which all formal Petitions to Deny (PTD) must be filed.

Minimum separation to other LPFM applicants for no MX:

Co-channel: 24km (23.51km with rounding)
1st Adjacent Channel 14km (13.51km with rounding)

2. Singletons get ready

Singletons that have no PTD filed against them will likely be granted in the weeks and months following the PTD deadline. The FCC will issue Construction Permits (CPs), specifying the location and Effective Radiated Power that will be allowed, along with any special conditions that have to be met.1 CPs expire in 18 months. They cannot be extended, except under unusual circumstances totally beyond the permitteeês control, and with copious documentation of same. Studios can be built at any time. Transmitter sites are not supposed to be built until a Construction Permit is issued. However, if an FAA tower issue is not involved (see section 7), applicants can start preliminary construction, but may not put transmitter power into the antenna, even for a moment, without a CP. Since a CP is never a 100% sure thing until it is issued, applicants are advised not to expend too much money that cannot be recovered, before approval.

3. Make-up filing window

After the Window 4/5 singletons are processed, the FCC is expected to open what has been termed as a "make-up window"—probably in Summer, 2002. This apparently will only be for those applicants in Windows 1 and 2 who were affected by the change in the Rules adding 3rd-adjacent spacing requirements. Those applicants will be able to file Major Change applications, if they can find a replacement channel and/or location that will meet the new Rules.

4. MX groups

After the make-up window, the FCC is expected to process the MX groups. The FCC will issue a Public Notice, including details on the procedures that will be followed. Some of these procedures and rule interpretations are still in limbo, so the following is based on the latest "best guess" of FCC staff:

a. The grantee(s) may be decided on the basis of the point system as set forth in the rules.

b. The FCC probably will allow voluntary time-share agreements using the transmitter site and the frequency of one of the applicants (or a minor change from that site), even if that transmitter site is more than 2km from the applied-for transmitter sites of the other applicants, and the frequency is different (one channel away) from the other applicants, as long as all other distance requirements are met.

c. Another settlement strategy may consist of all parties, except one, withdrawing their application. The CP would then be issued in the name of the one remaining applicant. The grantee would be under no legal obligation to allow the other applicants any air time, and would bear the full responsibility for what is on the air.

5. Amendments and changes

Minor Change applications can be filed at any time. Major Changes must wait for a filing window (which could be years away).

As a Minor Change, the only technical changes that can be made to pending applications, are changes in location less than 2km. No Minor Change frequency changes can be made to a pending application.

Approved but unbuilt CPs, and Licensed Stations can be Minor Changed to a new location (less than 2km), or frequency (to an adjacent or I.F. channel). If previous convention is followed, this would include 2nd and 3rd adjacent channels.

6. Call letters

Once the CP is issued, a search and request for call letters must be done at www.fcc.gov/mmb/asd/seacall.html. No call letters can be reserved before that time. No licenses will be issued without call letters. You can call your station anything, as long as the call letters are announced at the top of each hour.

7. FAA and zoning issues

If you are erecting a new tower, make sure there are no FAA issues. Towers within 5 miles of airports (even very short towers on top of buildings), often need separate FAA approval before construction. 200 foot towers always need FAA approval.

Most jurisdictions have local tower ordinances, that must be adhered to. Getting approval can be very time consuming. Start now.

8. Build what the CP says!

The conditions of a CP are set in concrete. The only leeway you have is the antenna height above ground: +1 meter (3 ft higher) and -2 meters (6.5 ft lower). Because coordinates are rounded to the nearest second, you may have about 20 feet horizontal leeway, also. All other changes, including tower height, require a modifying application and a new CP. Building a transmitter site in variance from the CP can be grounds for serious fines, and being taken off the air. The FCC also takes FAA, tower lighting, RF radiation, and EAS issues very seriously.

If the ERP youêre granted seems odd, have an engineer check it. The FCC sometimes makes errors on HAAT calculations, especially near coastlines.

9. After construction—more paperwork

During construction, you may engage in brief Equipment Test Operations, but only for purposes of testing the transmitter and transmission line. Unless otherwise indicated in the CP, you may start regular operation with normal programming via Automatic Program Test Authority, immediately after finishing construction, and testing. A letter notifying the FCC of the commencement of operations with Program Test Authority must immediately be sent to the FCC.3 You then have 10 days to electronically file an Application for Station License, Form 319. If Form 319 is not filed by the expiration date, the CP will be revoked and the station will be forced to permanently shut down.

Itês a very good idea to have the final installation checked out by a professional engineering consultant, and a spectrum analysis performed to make sure that the station is not emitting spurious products. The modulation levels and other parameters should also be checked. Many LPFM transmitters do not have sufficient metering to accurately verify these parameters. The station is not required to own a modulation monitor, but the installation should be checked with one before commencing regular operation. Nothing will get an FCC inspector out to your station faster than complaints of interference.

10. Studio-transmitter link systems

The options are licensed 950mhz point-to-point microwave, unlicenced spread spectrum microwave, equalized analog phone lines, ISDN and T1 lines, or piggybacking on the subcarriers of other links (i.e.: video links). Ethernet/IP/WAN audio distribution is an emerging option.

For most permittees, microwave still makes the most sense. LPFM grantees have free access to the 950mhz microwave frequencies that are reserved for that purpose. Frequency coordination and licensing is required, but the FCC grant is almost automatic. For most applicants, this will require an engineer to wade through the complexities of the process. Youêll need true line-of-sight for microwave hops. Two or even three hop links are possible.

11. Remote control

LPFM stations must have sufficient control to be reasonably assured that the transmitter is operating within legal limits at all times. At the absolute minimum, all stations must have a way to turn off the transmitter within 3 hours. If the transmitter is at a site that may not be accessible year round, a positive method for turning it off remotely is a must. A simple way to do this is to have the transmitter automatically go off the air if the microwave link is lost, or if there is no audio for a few minutes. Some sort of dial-up remote control is recommended, but not required, for all unattended transmitters.

12. EAS

At the moment, stations are still required to install EAS systems. Prices start in the teens. Scaled-down decode-only systems (that would meet LPFM requirements) are still not available. Some stations have applied for temporary waivers, but none have been issued. We recommend that applicants budget for a full blown EAS system, but delay purchase until close to sign-on time, in case the situation changes.

13. Other equipment hints

Control room mixing consoles should have some way of cuing material off-air, and should have single pots for both the left and right channels of stereo inputs. Some inexpensive mini-mixers do not have these capabilities, and will be frustrating to use. If there will be a separate production mixer, we suggest that the on-air mixer be a simple but rugged unit designed for that purpose. (i.e.: AEQ BC300)

14. Useful FCC links

Retrieve LPFM applications and CPs: www.fcc.gov/mmb/asd/lpfm/index.html#SEARCH

FCC LPFM pages: www.fcc.gov/mmb/asd/lpfm (usually updated)
www.fcc.gov/lpfm (not updated)

FCC Radio Tools (engineering utilities): www.fcc.gov/mmb/asd/bickel/radio_tools2.html

15. Keep your nose clean

If there is widespread abuse and rule violations, the opponents of LPFM will have won. Letês build and run our stations completely legally, and be ready for FCC inspections that may occur at any time. Together, letês prove that the LPFM fear mongers were wrong.

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