LPFM Comments

7/14/98 - I've received a pile more comments from ITS.  I don't have time to scan them before the reply comment deadline, so I'll add summaries for now.

8/18/98 - Additional original comments are being scanned slowly.  Once these are complete, reply comments will be ordered and scanned (assuming the FCC does not have its ECFS up and running by then).  For now, my reply comments are available here.

9/26/98 - The FCC has the Electronic Comment Filing System up and running!  I'll add summaries of comments I haven't OCR'd as yet to the list below.  These summaries will include links to the PDF files on file at the FCC, where you can see the comments as submitted.

Harold Hallikainen
harold@hallikainen.com
http://hallikainen.com - General info
http://hallikainen.com/lpfm - LPFM info
http://hallikainen.com/lpfm/comments/reply - Reply comments
http://hallikainen.com/FccRules - Hypertext FCC Rules

• ACRN-FM - Supports proposal to serve students and town population in Athens Ohio.
• adventure Radio Group - Opposes proposals.  Commenter suffered severe financial consequences as a result of docket 80-90.  They are not looking forward to "round two."  Proposals will complicate the introduction of IBOC DAB.  Most stations strive to promote and encourage diversity and community service.
• Alaska Broadcasters Association, et al - Supplemental Pleading adding Alaska Broadcasters Association, Georgia Association of Broadcasters, Hawaii Association of Broadcasters, and the South Dakota Broadcasters Association as co-sponsors to the Joint Statement filed by numerous state broadcasters associations.  Certificate of Service.
• City of Allentown - Supports the establishment of a low power broadcast service to provide information and music to the occupants of more than 70,000 vehicles who tour their "Holiday Light Display" each December.  At other times, such a station could be used to provide information about community events, road projects, etc.
• Daryl E. Anderson - Duplicates the comments of Wes and Jane Hare (below).
• Americans for Radio Diversity - Supports proposal for an LPFM service.  Suggests a power limit of 100 watts.  Suggests a residency requirement of 25 miles.  Suggests an ownership limit of one station per owner.  Equipment would have to meet minimum specifications.  Once the DTV transition is complete, convert TV channel 6 to an expansion of the FM band.  LPFM stations should not be required to be noncommercial.  Supports a minimum hours of broadcast requirement or a share-time arrangement.  Supports a local content requirement.  Supports self-regulation with appeal to FCC.
• Athens Broadcasting Company, Inc. - Opposes proposals.  Compares proposals to existing FM translator stations.  "There are people actually operating translators as 'for profit' centers.  In some situations translators are also creating interference to receivable signals therein reducing coverage.  The existing FM translator situation in this area is harmful to local radio which serves local needs and interests."  Lists variety of public service programs and fund-raising efforts of commenter's stations.
• Bayview Communications, Inc. - Opposes proposals.  Expresses concern that low power stations may not have access to news, leaving their listeners uninformed.  Questions whether the proposed stations would participate in EAS.  "What if there's an emergency and their listeners are unaware of it?"  Will these stations be held to the same standards as full power station (decency, public inspection files, regulatory fees, monitoring of transmitters to insure against interference)?  Would these stations present unfair competition to full power stations in small towns, where the low power station covers the same population as the full power station, but does not have the costs of operating a full power station.  Expresses concern that full power stations may not be able to financially survive if the advertising market is further split amongst more stations.  Lists public service programming provided by commenter's stations.
• John R. Benjamin - In a letter to Chairman Kennard, urges him to file comments in support of LPFM.  Provides instructions for filing comments.  Suggests commenting on RM-9208 as amended.  States that microstations are not something new, referencing previous licensing of class D NCE FM stations.  They have now, however, gained importance as the only major counterweight to a handful of large corporations, along with NPR, that now dominate the airwaves.  Ownership consolidation has resulted in numerous small towns being without a local station or being with a local station fed "canned" programming from hundreds of miles away.  Explains the authorized power levels of RM-9208 and RM-9242.  Explains ownership restrictions. Explains that microstations could not be "bumped".  Would authorize commercial advertising.  [Identical email sent to Susan Ness not reproduced here.  hh]
• Mark Blake - Supports efforts to give the public a voice on the airwaves, but feels the 1 watt power limit proposed in RM-9208 would result in "Freedom of Speech would be freedom to whisper."  Says that consolidation of ownership has resulted in public need being pushed aside for corporate interest.
• Mark Bolland - Does not support establishment of a low power broadcast service.  The proposals will hurt the community and negatively affect business.  Low power radio will promote confusion in the marketplace with listeners and advertisers.  They will not promote diversity.  The will not make the "pie" bigger, only cut it into smaller pieces.  If the Commission believes the "super-opolies" created are a mistake, adding more frequencies will not solve the problem, only make it worse.
• Keith Bouldin - Supports allocating frequencies for low power radio stations.  Recent consolidation leaves many without local news, PSAs and programming.  With good oversight, the low power stations pose no risk of violating the current FCC decency guidelines.  Low power stations would give more listening options.
• Bradmark Communications - Opposes petitions.  Adding more stations will cause loss of audience and revenue for existing stations.  "80-90 allowed minorities to own their own radio station.  And what did the do as soon as they got their license?  They sold it for a profit and got out."  Current small broadcasters do serve the small communities.  Adding more stations will weaken the ability of the current stations to do the job properly.
• Chris J. Brunson - Suggests that lower power stations would give more people an opportunity to broadcast.  States that most FM stations are very music oriented.  Very few stations focus on news, and those stations ignore the issues that affect oppressed communities.  There is very little variation in station formats with very little DJ creativity.  Suggests low power stations (10 to 50 watts) for individuals.
• Teri Brown - Duplicate of comments of Wes and Jane Hare (below).
• Stephen Burke - Former operator of an unlicensed FM station.  Presents various comments on the details of the petitions.  Does not favor auctions.  Gives details of a "common law and Constitutionally Lawful LPFM station."  Presents evidence of community support for station.
• Eric Burnette - Supports proposals.  Fees and licensing procedures should be minimized and streamlined so average individuals, schools, churches, and community organizations can have access to the public airwaves.  Modern equipment is very stable and should not cause interference.  Microbroadcasters will be able to better serve local areas than larger stations.  Microbroadcasters can offer local merchants lower advertising rates.  Programming and advertising competition may affect programming of larger stations, causing them to better serve local communities, and lower local advertising rates.  Power should be increased from the proposed 1 watt to 3 to 5 watts.  Microbreweries brought renewed competition and higher quality beer.  Microbroadcasting can bring about higher quality radio.
• Eric Burnette - These ex parte comments state that the commenter feels "that Micro Stations could do for broadcasting what the Web has done for computing."  Urges adoption of a low power broadcast service.
• Robert L. Caron - Opposes proposals.  The FCC is already understaffed without having to deal with thousands of new broadcast stations.  Petitioners have not shown a bona fide need for additional aural services.  Petitioners do not address EAS.  Will the proposed stations participate in EAS?  Would the public be served if they are listening to stations that do not participate in EAS?  Questions petitioners' interpretation of "public" radio spectrum.  Rewarding "pirate" stations with newfound legality would encourage other violations of law.  Those who get a low power license will want more power, and perhaps get it illegally.  Would stations with a minimal investment have enough "at stake" to make complying with technical requirements worthwhile?  Asks whether those desiring additional radio services have approached "public" radio stations or college radio stations, which may have a surplus of airtime.  The petitioners have not given concern to the spectral requirements of IBOC digital radio.
• Carlson Communications, International - The nation was previously flooded with new low power stations under docket 80-90.  Don't let that happen again.  Once authorized, low power stations will be tempted to keep increasing power "on the sly", and the FCC would have a mess on its hands.  Radio provides plenty of opportunity to discuss issues and public service on present stations.
• Fred Compton - "LPFM is desperately needed by many small communities throughout the country and is long overdue."  Believes the details in the Community Radio Coalition petition would be the most reasonable method of establishing LPFM.  Includes the CRC petition as "exhibit A".
• Citicasters Co. - Strongly opposes proposals.  Interference from low power stations could hinder public safety (interference to aviation, cellular, emergency services, etc.).  They would also interfere with existing broadcasters.  "'Legalized pirate' radio will not serve a broader community, but hinder the community already being served."  Lists monetary and other contributions to the community by their stations.  Expresses concern about a permanent amnesty for pirate operators who have a proven record of arrogant disregard for the FCC rules.  Creation of a service with thousands of new stations without any realistic way for the FCC to regulate these operations.  Creation of a class of stations capable of competing with existing stations, but without the public interest obligations of existing stations.
• Chester P. Coleman - Opposes proposals.  There is no current need for such a service.  There are many underutilized audio distribution outlets including radio stations that sell blocks of time, cable access channels, and streaming audio on the Internet.  LPFM, by its nature, will be low budget.  Such low budget operations are likely to use outdated equipment and lack the funds to hire professional technical personnel to install and maintain the equipment.  Overpower and off frequency operation are likely to be commonplace, leading to interference with full power stations.  The FCC, with its reduced staff, will not be able to adequately enforce these technical requirements.  With IBOC FM DAB pending, the FCC should not change adjacent channel protection requirements.  Squeezing in more stations just because it can be done, without considering the actual need for such a station, is damaging to the broadcast industry and the public service (as demonstrated by Docket 80-90).  Should LPFM be adopted, it should be restricted to class D NCE with all stations not licensed to governments or accredited educational institutions be licensed to local "boards".
• Kevin Coan - Supports LPFM.  Gives an example of a station that promotes they are the source of emergency weather info, but would not interrupt a game to tell of a storm.
• Columbine Investments, Inc. - Supports proposals.  Columbine believes that establishment of a low power radio service would serve the public interest in a number of ways. First, a low power radio broadcasting service would serve as a vehicle by which a variety of programming choices could be offered to small communities or niche segments of communities in urban areas. Second, such a service could serve as a vehicle for

entrepreneurs to develop new types of programming or uses designed to enhance the
broadcasting service. Third, the establishment of a low power radio broadcasting service would help to alleviate barriers to entry within the broadcast industry.
• Cosmopolitan Enterprises of Victoria Texas & John J. (Joe) Tibiletti - Opposes proposals.  Petitions should be dismissed since they use feet and miles instead of meters and kilometers.  Questions whether low power stations could survive financially (due to costs not being as low as petitioners claim and potential income limited by small coverage area).  Suggests a "prototype" station to determine whether such a station could survive economically.  Since various low power stations (such as class IV AM and class A FM) have, over time, increased power, commenter wonders if LPFM is a "foot in the door" towards eventual higher power.  Petitioner has submitted no research indicating that use of adjacent channels is possible without interference.  Local ownership is a good idea (Telecommunications Act of 1996 is a bad idea).
• Ed Crook - Agrees that there is a need for a local broadcast service to supplement those areas where there is a lack of community coverage.  The petitions are overly complex.  A low power FM service could be easily implemented by permitting existing and future FM translators stations to originate programming.  A new LPFM station would not have the right to "bump" an existing translator, however.
• Cox Radio, Inc. - In sum, consideration of TRA's proposal in a formal rulemaking proceeding is unwarranted. The Commission already has considered and rejected numerous proposals to create a primary low power FM service The same rationale which supported these prior decisions applies equally here. Authorizing a new low power FM service on a primary basis would violate Section 307(b) of the Act and would not result in any benefit (and indeed would be harmful) to the public. LPFM service would result in unacceptable crowding in an already concentrated FM band, would result in substantial interference to existing full power FM facilities and air navigation signals, and in some cases would preclude the authorization of new full power FM services. These results cannot be reconciled with the FCC's mandate to ensure the fair, equitable and efficient distribution of radio services. Accordingly, TRA's petition should be dismissed without further consideration.
• Joseph D'Alessandro - Asks "Why don't you help these people help the poor."  Includes extensive information on Black Liberation Radio.  Numerous comments filed.  These are summarized as: 8/13/98 - Asks congress to hold hearings on the FCC violating the Communications Acts of 1927 and 1934.  Suggests that power levels the FCC authorizes do not serve the community, but much larger areas.  8/12/98 - Another letter to congress.  Suggests that when there are not enough criminals, the government makes more things crimes, making the average citizen a criminal.  Also suggests the current rules support the rich at the expense of the poor.  8/8/98 - Another letter to congress.  Charges the FCC with violating the civil rights of 99% of the population, those unable to own broadcast stations.  Quotes a portion of NBC v. US.  8/6-7/98 - Three letters.  Various subjects covered.  Prior to removing ownership limits, it was stated the public would benefit through more diverse programming.  Now that we have ownership consolidation, radio is homogenized.  Includes a quote from a Kansas advertising buyer who fears increased advertising pricing due to consolidation.  Includes quotes on antitrust concerns in Grand Junction, Colorado.  Includes portions of a report by the Benton Foundation and Media Access Project showing that a station typically devotes 0.35% of its airtime to local public affairs programming.  8/6/98 - An email complaining about ownership consolidation in Wichita, Kansas and Grand Junction, Colorado.  8/5/98 (date received) - Accuses FCC of misusing US Supreme Court decision in NBC v. US (1943) to discriminate against minorities.  "You have use the supreme court ruleing to surpress the less fortunate, and advocate, support, big business, radio congolomerates, investment firms, and the NAB.  Mom and pop never had a chance.  It's all about money, and our elected officials."  8/1/98 - Suggests the FCC be brought before the Senate and be dismantled since its rules don't serve 99.5% of the population (instead serving only "rich fat cats"). 8/1/98 - "Charges the FCC with dishonesty" for awarding licenses to group owners instead of smaller owners.  Cites NBC v. US (1943). States that the FCC's rules do not "fit" 99.5% of the nation's population.  8/2/98 - Again suggests that the FCC rules do not "fit" 99.5% of the population and suggests the FCC be brought before a senate hearing to be dismantled. 7/30/98 -  Accuses the FCC of discriminating against various minorities for its licensing policies.  Cites NBC v. FCC (1943).  7/31/98 - Email to Commissioner Ness regarding her speech to the California Broadcasters Association.  7/31/98 - Email commenting on a speech by Commissioner Powell. 7/30/98 - Email charges FCC with discriminating against minorities.  Cites NBC v. FCC (1943).  States that the FCC has used this ruling to justify suppression of minorities and advancement of big business radio conglomerates.  7/30/98 - States that the FCC rule prohibiting women and blacks from applying for a license for a station running under 100 watts is unconstitutional.  "Please send my license."  Requests an NCE license to "play music and teach about Black Rythem & Blues Doo-Wop Music, which is an American Cultural, A Music Art Form, and a Part of American Heritage, which was abused and Denied Air Play During the 1950's because the Boys and Girls and I mean Pre-Teenagers and Teenagers, where Black, and the Radio Station back then where Predominantly White, you know what it is in 1998 and it is still the same as a matter of knowlege it is worse extent."  7/29/98 - Suggests that it is unconstitutional for the FCC to issue a public notice announcing the application for a broadcast license, possibly allowing others to apply for the frequency "found" by the original applicant. 7/28/98 - Describes "more rules that are unconstitutional."  The quantity and size of the legal documents to be filed for a station license excludes those without unlimited wealth.  Minorities cannot deal with the "applied sciences you have established," once again, excluding the unwealthy. Claims that minorities can start and run a 53 watt station that meets FCC interference requirements for $3,000 or less.  Includes a letter to the ACLU.  Questions the "custom" of spending $1,000,000 and still having no guarantee of being granted a license.  Gives more detail on why public notice of applications is unconstitutional (an applicant who "finds a frequency" may lose it to another applicant after the "find" is announced).  7/28/98 - Includes text of a web page describing a speech by congressman Tauzin.  Includes a letter to members of congress urging they support LPFM.  Commenter has access to the world wide web and can "campaign relentlessly" for those who support LPFM.  Advises congress that LPFM is not illegal, as the NAB would have them believe.  Suggests congress not "whimp up to the NAB."  Includes a letter to the FCC commissioners advising them of their responsibilities:  1.  [Authorize] citizens to own and operate radio stations for their community.  3,000 watts is all that is required.  2.  To direct the development of the nation's broadcasting system.  Includes an article announcing protests at the meetings of state broadcast associations by micro-power radio advocates.  7/27/98 - Duplicates email of 7/28/98 (above) 7/27/98 - Three additional copies of comments letter to ACLU included in comments of  7/28/98 (above).  7/27/98 - Another copy of the letter to ACLU.
• Christopher DiPaola - Supports proposals.  Commenter previously proposed a similar service that would allow a commercial "TIS-like" service in the expanded AM band.  A copy of that petition is included with the comments.
• Shannon E. Dodge - Letter in support of micropower radio stations.  "While theoretically the airwaves belong to everyone, it is too expensive and onerous in practice to launch even a small local station.  This impedes free speech."
• ECI License Company, LP - Opposes Leggett petition.  Multitude of stations would fragment audiences, financially undermining existing stations, causing public to be served less than they are now.  An increase in the number of stations would result in a substantial increase in interference, and the FCC is short resources to adequately police these new stations.
• Educational Media Foundation - Opposes the proposal of RM-9208.  Questions the "genuine wealth" statement of the petition, suggesting an owner of five LPFM stations each 50 miles from the other would instead gain genuine frustration.  Also expresses concern that a new LPFM station could cause interference to an existing translator, or to an existing FM station in the area beyond its protected contour.  Notes that there are listeners out there who are currently receiving service.  Extensive comments on RM-9242 include: Consideration of the ability of current receivers to receive a signal far beyond their protected contours as well as their greater selectivity (as was suggested in the petition).  Should listeners in the nonprotected area that are currently receiving service be protected?  Suggest that current FM translators should be grandfathered against displacement by a new primary LPFM service.  Suggests that this new class of station would have difficult surviving economically.  The "pirate radio problem" will likely not be solved by licensing those who currently disregard FCC regulations.  Available FCC resources (to govern a large number of additional stations) should be considered.  Adjacent channel separation rules should be revisited for all stations, not just LPFM.
• Bruce F. Elving - Supports establishing an LPFM service.  Suggests authorizing local origination for FM translators.  Also suggests a new class A1 service (1KW ERP, 91 meters HAAT).
• Duke Evans - Supports proposals.  Pirate stations exist because the operators cannot afford lawyer's fees associated in getting a license and cannot find employment in local stations due to ownership consolidation.  Suggests allocating frequencies in the AM and FM broadcast bands; a license fee of $250, disallow home built equipment, stations could not be sold for profit; allow power of 100 watts at 100 feet HAAT; first come - first served with lottery for competing applicants; ownership limit of one station; owner must live in city of license; operate a minimum of 12 hours per day; submit proof of compliance with license renewal application. Suggests amending part 15 of the rules to permit operation with up to 5 watts with antenna at 50 feet HAAT, provided a licensed engineer certifies there is no interference, equipment is professionally built and meets FCC specifications, and that the owner provides the FCC and all local stations with a phone number in case of problems.  Provides information on the effects of ownership consolidation in Santa Rosa, California.  Questions NAB statement on indecency and obscenity by pirates as compared to that on licensed stations.
• Alex W. Fredlani, Jr. - Would like any rules established under these petitions to authorize digital transmission for transfer of Internet or other packet data.
• Joshua Freeze - Ex parte or late filed email comment urges the FCC to leave Black Liberation Radio in Chattanooga alone.  "Shutting down micro-power stations serves no one except for huge radio corporations making profits off the public airwaves, while stations such BLR actually serve the community."
• Fremont Broadcasting, Inc. - Adamantly opposes FCC allowing low power radio stations.  These stations have a long history of serving the community.  Low power operators would congest the airwaves, skim what little "cream" there might be from advertisers, and could not provide the coverage necessary to provide the community with information necessary for national, regional, or local emergencies.
• James Fisher - In favor of deregulation of microbroadcasting.  "Too often these days I find my cities radio stations are ruled by a few, mighty radio empires, three to be exact.  With the exception of PBS and college stations, all radio stations in Orlando are owned by these three corporations, who appear to follow the sign of the all mighty dollar as opposed to offering actual programming which reflects local intrests, and or local musical talents, of which there are many.  I've recently ceased listening to the radio for these reasons."  Questions how the "national interest is served by leaving almost all of the nation's citizens disenfranchised from voice in the radio waves."
• Timothy French - Supports proposal to authorize 1 watt stations.  These stations will not clog the airwaves.  These stations will allow programming and information to the neighborhood level.
• Philip E. Galasso - Supports concept of low power broadcasting as an alternative to stations that are "little more than jukeboxes feeding transmitters, running cookie-cutter programming dictated by a corporate head of programming or an out-of-state consultant."  Congressionally mandated auctions on mutually exclusive applications will squeeze middle-class and minority applicants out of the industry.  The concentration of media within a market make it difficult for an independent station to compete.  Existing pirate stations "often serve their communities with programming unavailable on corporate radio."  Proposes return of class D FM license for both commercial and noncommercial stations.  Phase out FM translators.  Limit low power stations to one station per owner and require the owner to live within the 1 mV contour of the station (FM, or 25 mV/m for AM).  Network programming would be limited to 25% of total broadcast hours.
• Jeff Grammer - Supports proposals.  The large coverage areas of traditional FM stations is too large to serve the smaller community.  Small businesses are not able to afford advertising on larger commercial stations.  "Why is there LPTV without an LPFM?  I would make the stipulation and assumption that the reasons and rationale for LPTV are at the very least similar, if in fact not exactly, the same.  Why was this not done at the same time?"
• Greater Media, Inc. - Opposes proposals.  The proposals would have disastrous consequences for the current allocation scheme.  They would create massive new areas of interference, substantially degrade quality of service, and stymie efforts to implement digital radio service.  The proposed service presents no realistic economic opportunities.  The Internet is a better choice for new outlets to permit the expression of additional viewpoints.  High power stations are more spectrum efficient than low power stations.  That is why the FCC eliminated the NCE class D stations.  Proposals to eliminate adjacent and IF interference criteria would result in increased interference.  Studies by NRSC indicate that these criteria are necessary to assure a substantial percentage of the universe of receivers perform adequately.  IBOC digital radio is designed based upon existing spectrum allocations.  Changing that allocation scheme would "clearly doom any hope of implementing an IBOC DAB system."  Addition of stations to the AM band would undo the work the FCC is doing to improve the AM band.  Further examination of the proposals would give encouragement to pirate broadcasters.  Broadcasters do not fear economic competition - they fear interference.  The Internet is a better medium for increasing the number of voices.
• Harold Hallikainen - Separate comments filed on RM-9208 and RM-9242. Supports a low power service.  A licensed service can be most simply implemented by removing the current prohibition of local program origination on FM translators.  Proposes a license-free FM broadcast service in spectrum now used for television channel 6, once DTV transition clears this channel nationwide.  Supports auctions in awarding of licenses.  Supports ownership limit of one (low power) station per licensee.  Does not support program restrictions (commercial limits, local origination requirements, etc.) or licensee residency requirements.
• David Hann - Supports proposal of RM-9242.  "Nowhere else in this community does the local public have the opportunity to express and seek opinions and share knowledge with their fellow citizens over the radio."  "The expression 'freedom of speech' has a hollow ring to it in situations where only those with political or monetary influence (is there a difference?) can speak about their side of the issues."
• Wes & Jane Hare - Supports RM-9242.  Indicates that there are "communities of interest" that receive no progressive jazz blues and news in prime time.  LPFM stations will serve this need.  The citizens of commenter's city deserve the same diversity of programming and local access that other cities have.  Proposes stations of 300 watts or more on the dead spots on the dial.  These stations would serve a 15 mile range and would not interfere with community stations in other cities.  Supports the requirement that all owners live within 50 miles of the transmitter.
• Harlan Communications - Firmly opposes the proposals.  Cites cases of interference with his stations.  Indicates that FCC is stretched beyond its limits to deal with interference.  Unregulated "neighborhood" stations would cause major headaches for commercial broadcasters and other "neighborhood" broadcasters.  His stations present extensive community oriented programming, mostly live.
• Helixing Inc. - Commenter documents the history of a dream.  The FCC granted an STA in October 1993 to test antennae on the AM broadcast band.  The authority was not regranted in 1996.  Tells of local road flooding and no local station to advise drivers.  Tells of attempts to get programming carried on a local cable system and via "leaky coax" on the power company right-of-way.  Suggests increasing the part 15 limits to 800 mW for AM and 400 mW for FM.
• Michael Hemeon - Supports RM-9242 with a few changes.  Agrees that LPFM would serve to increase minority ownership.  Implementation of LPFM would be the most efficient use of the radio spectrum and would not take revenue from existing broadcast facilities, since small advertisers cannot afford the existing rates.  Does not support Special Event stations, though they might be acceptable on AM.  Instead of the various classes of stations, the stations should be authorized as class D (10 watt TPO).  Since the essence of the service is local community radio, the owner should be required to live within 20 or perhaps 10 miles.  Ownership should be restricted to one station.  Transmitters should be type-accepted.
• James J. Henderson - Supports RM-9242.  "Stations in medium and small markets are being taken over by large corporations."  The 1 watt and two channel proposals of RM-9208 are undesirable.
• Lemuel Curtis Hurt - Duplicates the comments of Wes and Jane Hare (above).
• InterNet Associates - Supports establishment of a Low Power FM service using second adjacent channels to existing FM stations.
• Jamar Media - There are still plenty of locally oriented stations in Texas.  Lists examples.  Markets are already crowded with signals due to docket 80-90.  There are plenty of stations available in each market which can be purchased by these groups that want to further their agendas.  Doesn't think it's right for taxpayers to provide these extremist groups with pirate radio stations to clutter up the airways when their views are already being heard.
• JEM Broadcasting Company - Ownership consolidation due to the Telecommunications Act of 1996 is reducing the number of local voices, but that, as an act of Congress, would be very difficult to undo.  Creation of a service that results in thousands of applications and thousands of stations would overwhelm Commission staff.  Daytime AM broadcasters should be granted a short-spaced FM channel to simulcast their AM signal.  No separate programming would be allowed.  The Commission should consider authorizing new class D NCE stations.  Citizens Band Radio could be the basis for low power broadcasting.  Both the transmitters and receivers are widely available.
• Lori Kale - Duplicate of comments of Wess and Jane Hare (above).
• David Kay - Comments on Chairman Kennard's appearance on NPR's Weekend All Things Considered (click here to get to a page with Real Audio links to that broadcast).  In the broadcast, Kennard indicated support for LPFM.  Kay suggests this is a bit hypocritical considering FCC actions at shutting down unlicensed FM stations.  Suggests dismantling the FCC and forming a "Community Communications Commission."
• KCKN/KBCQ - Commenter was not aware that existing stations were not serving their communities.  No one has ever requested to see the issues/programs lists in the public inspection file.  The FCC has not undertaken a study to determine how well broadcasters are serving the public.  The current allocations system is well thought out.  Throwing it out to add thousands of stations will cause severe interference.  The FCC will not be able to regulate a large number of additional stations.  How will it be insured that these stations provide programming useful to the neighborhoods they serve?  "What's to keep militiamen, religious fanatics, drug cultists, alternative life stylists and various and assorted crackpots, hucksters, and con artists from taking over the new service? What's to prevent even the most idealistic licensee from selling/leasing his or her air time to commercial entity for a tidy profit if the cost of running a service cannot be sustained?"  A low power service will confuse the public since a station would be audible in one neighborhood, but not the next.
• Kcountry 93.7FM - Proposed LPFM service would be "absolute disaster to the broadcast industry."  Tells of an instance of a "pirate station" causing interference and asks "Can you imagine what the radio airwaves will be like?"  "This is not about first amendment rights.  Any American can legally apply for and get a broadcast facility."  "We broadcasters continue to serve our communities with Public Affairs shows, PSA's..."  "Allowing low power 'pirates' would limit our ability to serve our communities and meet the requirements of our licenses."
• Eliot A. Keller - Opposes proposals.  Station where commenter is employed provides "extensive support of community activities through public service announcements, news coverage, and general community coverage." Both employer and employees provide direct financial support to various community organizations and projects.  "Anything which puts at risk the financial health of our company and its employees could disrupt such support."  Regarding the possibility of a multitude of voices (stations), "More shouting doesn't necessarily add more substance."  Compares the proposal to Docket 80-90.
• KELP - Opposes proposals.  His station is already suffering from interference from unknown sources.  Low power stations would add to the interference.  Lists community service programs aired by station.  Addition of stations will not result in additional service to the communities.
• KFAY/KKEG - The above proposed rule making will, in my opinion move to the top of the list as the most damaging to the FM band.
• KGRR - Objects to plans that would allow LPFM stations to operate virtually unrestricted.  All stations in their market provide community service programming.  Amateur and experimental stations belong to the earliest days of this century.  Licensing such stations now would be the beginning of the end of responsible broadcasting and create unimaginable interference.  The FCC has difficulty enforcing regulations for the existing 12,000+ broadcast stations.  Adding thousands more would make it worse.
• KIWA -  Opposes creation of a low power broadcast service.  Lists 6 reasons for opposal.  The AM and FM bands are already crowded.  Stations cannot be added without creating interference.  Thousands of low power stations with little commitment to their communities and probably with limited oversight and regulation would be inefficient use of the spectrum.  Home made or low cost transmitters may not be able to meet stringent emission requirements.  With the FCC's limited budget, they would not be able to properly supervise such a service.  The FCC would also be overloaded with license applications.  Existing AM and FM stations have proven their commitment to serving their communities.
• KJJR/KDBR/KBBZ/KKMT - Opposes allowing low power stations in every market.  This will water down the radio industry by "bloating it with frequencies in every market."  Lists community service programming.
• Alan H. Kline - "While there are issues raised in this Petition that warrant further study by the Commission, I believe that this proposal is so seriously flawed, for a variety of reasons, that I respectfully urge the Commission to dismiss the Petition without further action.  It is evident to me, from reading and re-reading the Petition, that the true goals of the Petitioner are:  To seek retaliation against 'evil, corporate broadcasters' for developing digital television and allegedly squeezing some LPTV stations off the air; to craft LPFM rules in such a way where he is exempt from some of the restrictions proposed for other persons; and particularly, to legitimize illegal, 'pirate' radio stations.  None of these issues are in the public interest, and none justify the creation of a new class of broadcast station.  Finally, the Petitioner fails to meet his burden, as required by the Commission's rules, to prove that the changes requested are sufficiently in the public interest.  The Petition presents no data, research, or other evidence to demonstrate that there is a compelling public interest in an LPFM service, as proposed here, or that such a service would be economically viable.  It is not enough for a group of individuals to wish to broadcast; it is also necessary to demonstrate that there is a substantial portion of the public who wishes to listen to them."
• KLXQ/KZBR - Opposes proposals.  Encourages the FCC to not repeat the mistake of Docket 80-90.
• KM Communications - Supports proposal to create an LPFM-1.  Commenter wants any new rules to not preclude smaller, women-owned and minority-owned broadcasters that have recently entered the broadcast industry from being licensees of new LPFM-1 stations.  LPFM-1 stations should not be "secondary" stations.  LPFM-1 service would serve the Commission's goals of localism and diversity of ownership and would serve as a source of alternative programming for local communities that are not well served by larger broadcasters offering programming to attract the broadest and most homogeneous market possible.  LPFM-1 would provide low cost advertising for small businesses.  Comments on ownership limitations and residency requirements.  Supports the use of interference studies and type-accepted equipment.
• KOMW - Opposes proposals.  Station provides lots of public service programming.  Operates in a very competitive marketplace.  Points out possible inequity in having a broadcast service that competes with existing stations but does not have similar expenses, such as EAS.  If low power were allowed, translators should not be allowed to extend the coverage of low power stations (approaching that of full-power stations); EAS should be required; spectrum and regulatory fees, monitoring requirements, etc. should apply equally to low power and full power stations; low power stations would have to meet the existing interference requirements.
• KOWB/KCGY - Opposes proposals.  Gives examples of community service programming.  Allowing dozens or hundreds of "pirate" stations would be total chaos.
• KPRV - The station is already facing significant competition.  Additional stations would make financial survival questionable.  The station carries a significant amount of community service programming.
• KQEN/KRSB-FM/KKMX-FM - The proposals would mean certain doom for broadcasters already abiding by the FCC rules.  Lists community service programming.  Gives examples of interference already existing from unlicensed transmitters.
• KQEZ-FM - Supports LPFM and gives a fairly detailed proposal.  "As a commercial broadcaster, we have witnessed the negative effects of consolidation described in the proposals and have, in part, contributed to them ourselves."
• Lawrence J. Krudwig - Supports proposals.  "What the FCC has done with regard to microbroadcasting... would be the equivalent of outlawing copying machines on the position they are technically inferior in quality and content to the super presses of the big newspapers."  Fairly extensive discussion of emergency communications uses of low power stations, especially by "event" stations.  Various comments on specifics of proposals.
• KSEL - Commenter was not aware that existing stations were not serving their communities.  No one has ever requested to see the issues/programs lists in the public inspection file.  The FCC has not undertaken a study to determine how well broadcasters are serving the public.  The current allocations system is well thought out.  Throwing it out to add thousands of stations will cause severe interference.  The FCC will not be able to regulate a large number of additional stations.  How will it be insured that these stations provide programming useful to the neighborhoods they serve?  "What's to keep militiamen, religious fanatics, drug cultists, alternative life stylists and various and assorted crackpots, hucksters, and con artists from taking over the new service? What's to prevent even the most idealistic licensee from selling/leasing his or her air time to commercial entity for a tidy profit if the cost of running a service cannot be sustained?"  A low power service will confuse the public since a station would be audible in one neighborhood, but not the next.
• KSNM/KXDA - Opposes low power stations.  Has had experience with interference from unlicensed stations.  Lists public service accomplishments of station.  There are already too many stations to be supported financially in many markets.
• KVST - Opposes proposals.  It might be ok for big cities, but small cities already have so much competition that it is difficult to make a profit.  Permitting low power stations would be "changing the rules in the middle of the game."
• KWCK - Opposes proposals.  Asks the FCC to not ask hastily in implementing rules to the detriment of FM radio and the public interest.  "We will always have to live with the interference caused by Docket 80-90."
• KZMK/KWCD - Opposes proposal.  Allowing numerous low power stations could cripple the ability of stations to serve their already limited coverage area.  Commenter's stations are already limited to a fraction of the vast trade area due to concerns about signal overlap.  Many listeners live outside the city grade coverage, but still pick up the station well.  The advent of new low power amateur broadcasters in commenter's market would be very detrimental, especially if commenter is not allowed to increase power.
• Brian K. Landis - Comments duplicate those of Wes and Jane Hare (above).
• Kevin Lange - Supports proposals.  Low power stations would supplement rather than replace mainstream media.  Suggests a protected broadcast radius of 5 miles.  Supports the idea of an expanded band with channels specifically for low power broadcasting.  Supports a preference for school stations, which would act as training ground.  Supports ownership and residency limits.  Supports "first come, first served" licensing (as opposed to lottery or auction).  Supports requirement that an owner or chief operator have a General Radiotelephone Operator License in lieu of requiring type accepted equipment.  Low power stations should be exempt from EAS equipment requirements.
• Nickolaus and Judith Leggett - Special comments request suspension of prosecution of microbroadcasters and, if the current rulemakings establish such a service, dropping charges against existing microbroadcasters.  Argues that the existing prohibition of microbroadcasting is in question, since there is this rulemaking and cases in court.  Further prosecution should be held off until the doubt is eliminated. Should microbroadcasting be made legal, it is argued that those who were broadcasting were correct and the law was not.  An example is made of someone violating the "whites only" laws prior to the elimination of those laws, yet tried for the violation after the laws were eliminated.
• John Lentz - Supports RM-9208.  Up to 100 watts ERP should be considered LPFM.  Supports "first come first served" instead of a lottery in awarding licenses.  LPFM applicants should be home-owners, small businesses, educational organizations, or church groups.  Licensing fees should be reasonable and affordable.  They may be based on the cost of the equipment, coverage area, or advertising revenue.
• Karen Loew - Favors proposals.  Ownership consolidation has put station ownership even farther beyond the reach of most americans.  Current trends promote listener passivity and alienation while a multitude of human-scale stations would foster participation.  A profusion of voices on a variety of subjects would enrich present radio broadcasting and possibly change our understanding of what radio can be.  Evidence indicates the proposed service can be accommodated without interference to existing radio services.  That, along with microbroadcasting's embodiment of democratic values, the FCC has an obligation to launch a public proceeding to consider rules and policies on microbroadcasting.
• Lone Fox - "I WANT RADIO MUTINY BACK ON THE AIR!!!!!!!!  YOUR trashing our freedom of speech!!! DON'T MUTE RADIO MUTINY!!!!  Free rain for microbroadcasters!!!!!"
• Gerald P. Lorentz - Supports RM 9208.  Due to media consolidation, dissenting voices are rarely heard.  The proposals for low power and antenna height are the core of its community-based nature.
• Christopher Maxwell (link to pages 26-49)-  Chages of possible conflict of interest at local PBS station.  Suggests that community radio would have programming generated by local citizens, thus be free of corporate bias.  Includes a copy of a petition to the local PBS station asking that they not move the airtime of Living On Earth.  Includes about 45 pages of signatures.
• Michael P. Mayer - Supports proposals.  Consolidation of ownership has resulted in radio markets gradually turning into corporate monopolies.  This means radio stations cannot focus on local issues and tastes, but must focus on profit for the parent company.
• Henry Mayfield - In summary, since this petition is a subset of the one for LPFM Broadcast Service (RM 9242), I propose that the Commission combine them.  Finally, I propose that the Commission provide very restrictive rules for ownership, control, and assignment of licenses as well as the flexibility for licensees to increase the coverage area by interconnecting with other licensees.
• Media Preservation Foundation - Supports the establishment of an LPFM service.  LPFM should be noncommercial.  LPFM should be limited to one station per owner.  LPFM should be a licensed service.  LPFM licenses should be issued first come first served.  Upon discontinuance of operation, an LPFM license should be returned.  A licensee who returns a license should not later be prohibited from holding another.  LPFM should be permitted on any frequency in the FM band on the same basis as translators.  LPFM could be assigned within predicted contour of a licensed full-power when actual signal levels are less than predicted.  Second adjacent channels should be available for LPFM based on improved receiver performance and low operating power.  LPFM should be primary to translators.  Commercial operation on "Event" LPFM stations should be permitted.  Program content should be market determined instead of FCC mandated.  Shared use of a frequency should be permitted.  Transmitters not approved by the FCC should be permitted to be used if they are used with an FCC approved low pass filter.  LPFM stations should not be required to participate in EAS.  Those not participating would run a daily announcement indicating they are not participating.  Part 15 should be modified to allow operation at 1 watt through a type-accepted low pass filter.  Such operation would require certification that the transmitter is under the supervision of a "Chief Operator" who is at least 18 (or 21) years old.  LPFM stations would be required to announce a phone number where interference complaints can be resolved.  LPFM stations should use call letters that are distinct from full-power stations.  Instead of a local ownership requirement, the primary studio of an LPFM should be within F(50-50) 60 dBu contour with no exceptions.
• Oliver B. Mertz - Supports proposal of low power broadcasters to serve local areas.  These small stations could act as a training ground for new broadcasters.
• James Miles - Supports proposals.  There is a need for more noncommercial stations.  Since it is not illegal to solicit advertising for low power digital TV stations, the same should be permitted for low power radio.  Outlets for school broadcasts and public service groups are a must.  One should have prior professional radio experience and knowledge in order to acquire a low power license.
• Ronnie V. Miller - "I am in favor of the creation of some type of low power broadcast service, (particularly in small communities) but have suggestions for ways to simplify the proposal under consideration.  A service of this type can exist in harmony with full power licensed broadcast stations, and can be implemented with much less need for FCC man-hours than is suggested by the proposal.  Utilization of the services of the Society of Broadcast Engineers (SBE) for technical support, and relatively simple changes to Part 15 of current FCC rules should be considered."
• Minnesota Public Radio - With an already extended workload, MPR is concerned that by authorizing the new class of low power license, the Commission will encounter a fair degree of difficulty in insuring broadcasting excellence and fairness to existing licensees.  Should the Commission adopt an NPRM in response to these petitions, they should carefully craft rules that would require low power broadcasters to maintain all of the spacing, good engineering standards and practices required of all other AM and FM licensees, along with strict enforcement measures.
• David Moore - Argues that the petitions are "moot" in that "there are certain unsettled issues of fact and law which should be addressed and resolved prior to the creation of any new Broadcasting Service."  These unresolved issues are:  The FCC's jurisdiction is limited to interstate and foreign commerce (is microbroadcasting, or indeed most broadcasting interstate or foreign?); The FCC regulations requiring an application for license are "collections of information" pursuant to the 1995 Paperwork Reduction Act and are thus required to display an OMB control number.  Lack of such a control number makes the collection of information unenforceable; The regulations requiring an application for a license do not detail the information to be supplied - this information is instead specified on the application form itself.  This makes the form itself a "rule" that is generally required to be published in the Federal Register to be valid.
• National Association of Broadcasters - Opposes proposals.  The FCC has firmly established that low power radio is not an efficient use of spectrum. Any change to the current FCC allocation rules would be detrimental to the evolution of in-band, on-channel ("IBOC") digital radio. The Commission has already licensed over 12,000 commercial and noncommercial radio stations in the U.S. Each full-power station provides a unique service to its community. Although the radio industry has undergone consolidation due to changes made by the Telecommunications Act of 1996, this consolidation has not decreased the diversity of formats in the industry. In fact, due to greater efficiencies, it may be possible for existing stations to offer new and distinct niche programming that was otherwise unavailable before consolidation.  The Commission must keep in mind that a low power station would not be able to serve communities as well as a larger station. Low power stations would only be heard by a small number of people, and for all practical purposes, would be unavailable to mobile audiences. Supporters of the petitions may have other outlets for their viewpoints without resorting to establishing a new broadcasting service - such as seeking out available time on full-power commercial and noncommercial stations, applying for a noncommercial frequency or expressing their views over the Internet. Most importantly, the Commission should not establish a new service for low power radio in order to curb the proliferation of pirate broadcasters. Finally, the Commission would face many administrative burdens that would stretch limited FCC resources if it were to consider a new service.
• National Hockey League - Supports the establishment of an event radio broadcast service for use inside hockey arenas with very limited radiation beyond the arena.  Also support event broadcasting to support game attendees as they arrive and leave the arena.  Would permit commercial programming to support the operation of the station.  Would like multiple frequencies inside the arena to allow for multiple languages and other multichannel uses.
• National Lawyers Guild Committee on Democratic Communication - Supports RM-9208.  The enormous surge in microradio stations is evidence of a need for such a service.  A detailed counterproposal is presented.  Stations would be noncommercial.  One station per owner.  Local ownership.  Locally programmed with allowance for recorded programs.  Ownership must be individuals or nonprofit.  Any locally unused FM frequency down to 87.5 MHz would be allowed with second adjacent being closest spacing.  Power would be 50 watts urban, 100 watts rural.  Stations would be registered with FCC and a local/regional association of microbroadcasters.  Equipment would have to meet basic technical requirements.  Registration would be valid for four years.  No specific public service requirement would be imposed by FCC.  Problems would first be resolved by local micropower organization, then FCC.  TV channel 6 would be allocated to microbroadcasting after DTV transition.  Event stations need not be registered.  Presents constitutional analysis.  Presents comments of supporters of this proposal.
• National Public Radio - Opposes proposals.  The FCC has determined that higher power stations make more efficient use of the spectrum.  The petitions do not set forth with any degree of specificity the rules being proposed, as required by 47 CFR 1.401(c).  The Communications Act requires a system of competitive bidding for the allocation of commercial broadcast licenses.  The petitions propose other means.  The petitions propose ownership limits while the Act prohibits them.  The proposed stations are likely to create interference with existing stations and undermine the transition to digital radio.  There are likely to be substantial administrative costs in implementing such a service.  While the goal of increasing the diversity of media voices is important, the petitions do not give evidence that they will achieve this goal.  It is unlikely that interests such as "golfing, flying, archery, etc.) would be geographically distributed in the same manner as the low power stations.  The Internet is a viable alternative to the proposed service.
• Douglas J. Neatrour - Supports petitions.  Commenter has seen the air waves disintegrate from "operating in the public domain [interest?]" to "not serving the public and concerned mainly with how large a portfolio of stations can be obtained and how great a bank account can be achieved."  Would require low power stations using AM to be on the expanded band.  One to three low power frequencies should be assigned to each community.  Power should be limited to one watt or less.  Transmitters should be FCC approved.  Stations would pay a small registration fee.  Approval would be on a first come first served basis.  Stations would have to register each year indicating they are on the air and current mailing address.  Low power stations should not be required to have EAS or other expensive equipment.
• Lars Negstad - Supports concept of low power stations.  "It would provide an excellent forum for true community-based voices to be heard, and a very important alternative to the increasingly corporate-controlled megamedia."
• New Jersey Broadcasters Association - Opposes proposals.  The addition of any new broadcast stations to the already crowded broadcast spectrum will cause major interference to existing stations, especially in the Northeast.  The addition of a large number of stations would strain the FCC's ability to regulate them.  Since pirate radio stations already operate illegally, it can be assumed that a pirate radio station operator who is not granted a microstation will continue to broadcast illegally.  The establishment of microstations has the potential to destroy the very fabric of our broadcasting system.
• New Jersey Broadcasting - Opposes the proposals based on the interference they are expected to create.
• Francis A. Ney, Jr. - Agrees with principle of creating a low power radio service.  Recent conglomerates "pay lip service to affairs of the community."  The maximum power for a "low power" station should be 100 W ERP, since that is the minimum for a part 73 FM station.  Proposed restrictions on "special event" stations appear too restrictive.  Suggests using the callsign scheme of LPTV and FM translators.  Suggests transmitters need not be type-accepted, perhaps "self-certified."  On special event stations, the transmit power should be the minimum necessary.  Supports the idea of private coordination of frequencies, provided adequate safeguards are in place.  The proposed 1 watt power limit is too low.  Limitation to crystal controlled transmitters is too limited, suggesting PLL circuitry is adequate.  Licensees should live within the community the LPFM is to serve.  The FCC should not make restrictions on programming (local origination, public service, etc.).
• North Carolina and Virginia Associations of Broadcasters - Opposes the establishment of a micropower radio service.  The petitioners disregard the practical and technical difficulties involved in implementing such a service.  In addition, the creation of such a micropower radio service would undermine the Commission's efforts to crack down on illegal "pirate" radio stations.  Finally, the arguments that the creation of such a service would promote minority ownership and broadcast diversity ignore regulatory and marketplace realities.
• Law Offices of James L. Oyster - Supports adoption of a microbroadcasting service through a reclassification of the noncommercial educational stations.  Proposes three classes.  The first would benefit from government funding, the second would not, but would be permitted to run a limited number of commercial announcements (ten minutes per hour is proposed).  The third class would be the microstations that would be funded by the operators and their listeners.  The commenter supports the establishment of a microstation broadcasting service, provided that existing noncommercial educational stations are protected from the harmful impact (increased competition for donations) which such a new service could engender.
• Oregon Association of Broadcasters - Urges the Commission to not proceed to a rulemaking.  The proposals would have a negative impact on the integrity of broadcasting in America including: increase in interference, amnesty of pirate operators, possibility of thousands of stations without FCC ability to police or regulate, low power stations would compete with full power stations but not have the public interest obligations, a return to the chaos and financial calamity brought on by Docket 80-90, which led to the massive consolidation of the industry.
• Maurice B. Polayes - Requests a license to operate a low power FM station in Needham, MA.  There is a need for a local FM service to "incorporate all local activities, and to be involved in the local civic events.  The present broadcast services do not zero in on local affairs and local civic activities."
• Margie Politzer - Concerned about the corporate domination of broadcasting.  Supports the establishment of an LPFM service.  Stations should be noncommercial, locally owned, with no more than one station owned by an individual or entity.  The power should be between 50 and 100 watts, perhaps depending upon whether the station is urban or not.  One watt is not sufficient power.
• Portland Area Radio Council - Opposes proposals.  Proposed stations will cause interference with broadcast and other radio services.  Through the efforts of existing local radio, the local community is served well.  Should the proposals be approved, the impact on broadcasters will include:  Amnesty for pirate broadcasters who have shown disregard for the FCC's rules; The introduction of thousands of stations without the FCC's ability to regulate them; Creation of a class of stations able to compete with full power broadcasters, but without the public interest obligations of full power broadcasters; A return to the chaos and calamity of Docket 80-90.
• Portland Radio - Opposes proposal.  Commenter's market has a pirate station that can cause interference with two stations.  Lists community service programming.  More signals are not needed.  Our listeners are our business, our neighbors, and our friends.
• Press Communications LLC - Opposes rulemaking.  Adding stations will result in interference to existing stations.  This interference would be aggravated should licensees be permitted to build their own transmitters.  The FCC's enforcement capabilities are limited and would not be able to properly regulate thousands of additional stations.  The FCC would not be able to process applications in a timely manner.  The petitions argue against the use of auctions in determining the awarding of licenses where mutually exclusive applications exist.  Congress mandates the use of auctions.  Should the Commission find a way to not use auctions, no other suitable method of determining award of licenses exists.  Questions the FCC's authority to promote "diversity", however that may be defined.  States that the FCC cannot use any race-based licensing scheme.  Should a method be found to allow use of low power radio to increase "minority" ownership, "... would not that be the equivalent of having the government provide sub-standard housing to 'minorities' in sub-standard neighborhoods."  Promotes web-casting as an alternative to low power broadcasting.
• Bruce Quinn - Supports proposals for an LPFM service.  Diversity of ownership should be increased.  Proposes a class A-1 FM service using the old class A specifications (3 KW at 328 feet HAAT).  Proposes that a frequency that can support an FM translator be authorized for use as a noncommercial low power FM.  Proposes a "neighborhood broadcasting" service with each station authorized 1 watt.  Proposes part 15 of the rules be modified to allow manufacture and sale of transmitters up to 0.1 watt.  These stations must not cause interference and must accept any interference.
• Radio One - Opposes petitions.  Petitions should be summarily dismissed as being unacceptable for filing because it suffers from numerous procedural deficiencies  and proposes an influx of licensing issues that will tax the Commission's limited resources.  "Procedural deficiency requires that the Commission dismiss the petition".  "Petitioner has failed to establish the demand for a new low power FM broadcast service."  "Low power FM broadcast service will tax the Commission's limited resources."  "Petitioner states that the service he proposes will cause the 'bulk of the 'pirate radio' problem' to disappear."  "Petitioner offers no evidence to support this sweeping conclusion.  And, the obdurate conduct of those operating pirate stations contradicts this conclusion."  "Petitioner offers no comfort that by merely making a low power FM service available, those violating the law will hang up their microphones, apply for a license and retreat quietly if a license is not awarded."
• Renard Communications Corp. - Supports the establishment of a microstation broadcasting service by authorizing stations on the AM band using technical parameters almost identical to existing TIS stations, except the frequency response would be extended from 3 KHz to 5 KHz.  AM is suitable for broadcasts of diverse opinions, views, etc.  FM should be reserved for future full-service and FM translator stations.
• Jeremy M. Rowen - Duplicate of comments of Wes and Jane Hare (above).
• Jesse N. Salter - Supports proposals.  Current radio service is inadequate.  Commercial stations, and many noncommercial stations, tend to be narrow in the variety of programming they run.  Microradio stations can provide a wider variety of programming.  In addition, they can serve distinct geographic audiences, such as airing programming in the native language of the inhabitants of concentrated communities of recent immigrants.  The uniformity and duplication offered by commercial radio seems to be a waste of a valuable resource.
• San Francisco Bicycle Coalition - San Francisco Liberation Radio broadcasts the Coalition's meetings in their entirety, thus providing a valuable service to the community.  Urges the Commission to legalize micro-power radio stations on firm constitutional grounds rather than procedural issues.
• Sanji - Hopes the Commission continues its efforts at creating a micropower radio service.
• Ron Schacht - Supports RM-9208.  Since ownership deregulation, many small town radio stations have had their transmitters relocated to serve larger adjacent cities and have moved the studios to the larger cities to attract more advertising.  Those stations that could not be relocated instead rebroadcast a larger station owned by the same group.  Commenter believes ownership deregulation has destroyed "radio as a public servant."  "Allowing small stations to actually serve their communities would be the first step in putting radio back where it should be, serving the public, rather than the bank accounts of large groups."
• Harry Settatestes - Email expressing disapproval of the FCC's "harassment" of Black Liberation Radio and Free Radio Memphis.  States that FCC actions show disregard for the first amendment rights of citizens, and that the FCC rules regarding obtaining a broadcast license disregard the free speech rights of the poor.  Reminds the Commission that, as a taxpayer, he pays their salary.  Suggests the Commission "start acting in the interests of the people."
• Shure Brothers Incorporated - Suggests the requirement for use of Type Accepted transmitting equipment, suggests use of the FM band only, suggests TPO of ten watts with single bay antennae with gain limited to that of a dipole and use of any polarization, suggests antenna height of 15 meters above ground level.  Suggests part 15 be amended to allow license free operation with Type Accepted transmitters operating at powers of up to 10 mW.
• J. Rodger Skinner, Jr. - The power level specified in RM-9208 is insufficient for a low power FM service.  LPFM stations should use FCC type-accepted equipment.  The minimum broadcast hours provision of the petition is vague.
• Southern Minnesota Broadcasting Company - Opposes proposals.  Current allocation scheme serves the public best.  Presents information from a Carl E. Smith study indicating it would be necessary to clear seven channels nationwide to support the proposed service; In many parts of the country, the band is so crowded that it would virtually impossible to find one clear channel; Skywave interference on the AM band would reverse recent improvements in the AM service; International treaty may stifle such a service in many areas; Use of non-type accepted equipment would result in destructive interference.  Gives examples of interference, including recent interference to aircraft communications in Sacrament, California.
• April Smith - Has worked in commercial stations for years and would like to start a low power community station.
• Sorenson Broadcasting - Does not approve of proposals to establish a low power broadcast service.  Gives example of a city with a population of 15,000 in a county of 37,000 is served by 10-11 signals.  How many signals are enough?  Gives examples of public service programming provided by existing stations.
• John Stalnaker - Suggests that the self-policing of the CB operators in the 1960's would work for LPFM, eliminating the need for additional FCC staff.  Discusses the use of "pins in coax" as a means of shutting down an offending station.  LPFM stations would be of benefit to small communities that have been ignored by larger stations.
• State Broadcasters Associations - Comments of 44 state broadcasters associations oppose proposals.  "Through their beguiling use of such terms as the 'national security,' the 'national interest,' 'localism' and 'diversity,' the Petitioners would have the Commission feel morally and legally compelled to give a broadcast microphone and transmitter to virtually anyone who wanted one."  Comments state that the FCC has broad discretion to decline the requested rulemaking an inquiry.  The petitioners have failed to provide sufficient reasons for a rulemaking or inquiry.  The FCC lacks the resources to handle the number of filings and regulatory problems threatened by the petitions.  Creation of the new service will undermine the public service programming of existing broadcasters.  Effective regulation would be impossible.  The uncertainty and technical issues involved in this matter undermine the progress being achieved in other FCC proceedings.
• Robert M. Stevens - Supports proposals with some changes.  Cites "recent massive consolidations in local markets..."  Cites Turner v. FCC, "it has long been a basic tenant of national communications policy that the widest possible dissemination of information from diverse and antagonistic sources is essential to the welfare of the public."  However, adding more stations would hurt the existing stations at the bottom of the "food chain" (daytime AM stations), so daytime AM stations should get a chance to "trade up" to LPFM.  Should a daytime AM station not "trade in" the existing license, the ownership of the daytime AM should not count as a media ownership demerit in a lottery.  There is some validity to the concern that LPFM stations remain in the hands of local owners.  Supports the use of filing windows.  The FCC should have no problem justifying the need for lotteries (instead of Congressionally mandated auctions), since the auction would lead to further media ownership concentration.  The adjacent channel and IF interference criteria should be removed.  "Letter perfect" processing should not be used.  Supports ownership limits.
• Susquehanna Radio Corp. - Petitions should be dismissed.  The Leggett petition states that microstations will serve "niche" markets, such as those interested in golfing, flying, archery, energy conservation, animal rights, etc.  It is illogical to expect a reasonable number of persons interested in archery or ecology to live within several blocks of this transmitter.  Persons interested in expressing social or political opinion would reach far more interested listeners by calling a full service radio talk show than on any number of one watt stations.  The TRA petition would have merit if  spectrum were available.  The present restrictions on adjacent channel operation are reasonable.  Further, changing these restrictions would seriously hamper any in band on channel digital broadcasting system.
• Robert B. Tanner - Supports proposals.  With corporate conglomerates buying out local transmitter facilities, listeners are losing the local element we used to take for granted.  There is no way a small business owner can own a radio station.  There is also a need to accommodate small markets of ethnic peoples without taking up large transmitters that cover a large area.  Gives example of Hmong population of Fresno.
• Tempest Inc. - Supports "Neighborhood Radio."  Proposal will bring new talent and business into the broadcast industry, create new jobs, and lead to innovations in programming and technology.
• Scott Todd - Approves a combination of the proposals of RM-9208, RM-9242 and the Community Radio Coalition.
• Michael C. Trahos - Supports the proposals with various modifications.  Suggests that an unlicensed low power service would fit in part 95 of the rules, along with the Family Radio Service and Citizen's Band Radio Service, instead of in part 73 (broadcast).  Suggests the FCC follow the frequency assignment procedure used in FRS, where frequencies were authorized for license-free FRS on a 12.5 KHz offset from GMRS channels (which are spaced 25 KHz).  Therefore, license-free low power AM would be on the existing AM band with a 5 KHz offset from existing channels, and FM would be on the existing band with a 100 KHz offset.  Transmitters should be FCC type-accepted.  Home-built transmitters would create too much potential for interference.  Supports a licensed low power FM service under part 73  Supports the ownership and operation proposals of the petitions, in general.  Suggests a provision for seasonal operation in seasonal markets.  Event broadcast service could be handled by the unlicensed service discussed above.
• Wanda Trent - Duplicates the coments of Wes and Jane Hare (above).
• Trumper Communications Inc. - Expresses concerns about interference.  Disagrees with first amendment free speech arguments.  Their stations present programming to meet the needs of the communities.  Docket 80-90 severely damaged the industry.  Consolidation allows recovery from that damage through economies of scale.  Consolidations permit greater diversity in programming, since a group owner can afford to program niche formats while an individual station owner must program popular formats.
• Unknown - Comments with no return address and unreadable signature duplicate those of Wes and Jane Hare (above).
• USA Digital Radio, L.P. - Suggests a freeze on new radio services using the existing broadcast bands, since the IBOC digital radio system being developed is based on existing interference standards.  Changing those interference standards would either require a redesign of the system or prevent its implementation at all.
• Dan Viles - Supports the addition of small stations to make entry into broadcasting easier and to make the "number of voices more multitudinous.  The more voices... the more democratic we are..."
• Wabbit Wecordings - Supports low power radio in some form.  "... low power stations are not only necessitated by commercial stations inability to serve the public interest of only a portion of their audiences, but they are in fact inevitable."  Low power stations could provide more exposure of new musicians than that currently provided by commercial stations.  Low power stations could provide a forum for the discussions of neighborhood issues that are not of interest to the larger community.  Stations should be owned by a local governing board rather than on a "first come" basis, possibly similar to public access cable television.
• Randy Wells - Supports petitions.  The high value and consequent debt service on existing stations is so tremendous that any sort of creativity or experimentation is foolhardy.  It is imperative that all profit potential from the trading of LPFM stations be prohibited.  If someone sells a station, he/she should only be entitled to recoup actual costs.  "I have a problem with 'multiple-ownership.'  We don't need any more 'corporations'; LPFM or otherwise.  If these allocations have no takers in a given town, don't award one until there is an interested party with no other facilities.  We're trying to make each station as individual and local as possible.  We don't need satellite-fed LPFMs."
• WGAD - Opposes the proposals.  The FCC flooded the cities and towns of America with radio stations in Docket 80-90.  They have admitted this was a serious mistake and now allow consolidation of ownership so stations can survive financially.  The FCC is considering another flood of stations from Pirate Radio.  This will make competition for advertisers impossible.  Further, none of the stations can afford to offer the services to communities that they have come to expect from broadcasters.
• WGCD/WLTC - Supports establishment of a low power FM service to open new opportunities for minorities, churches and community groups.  Requests that small AM station licensees be given the first opportunity for these stations as a means of helping these AM stations and protecting their investment.
• WHVN/WAVO/WNMX - Opposes proliferation of low-power stations.
• Dan Wilcox - Supports the concept of low power FM stations that are individually owned or nonprofit.
• WJLS - Opposes proposals.  Low power stations carry much further than most people realize.  Due to small budgets, these stations could create spurs or harmonics and interfere with the public's favorite station.  Commenter fears "that every Tom, Dick, and Mary will want to be the owner of their own station, with no regard to servicing the public interest..."  With the Commission having trouble regulating existing pirate stations, regulating hundreds of microstations seems difficult.  "With over 11,000 commercial radio stations currently license, virtually every community has at least one station, and virtually every local service is already being provided. Broadcasters donated over seven billion dollars in public service and public affairs time in 1997."  Comments that Commission should instead reverse flow of ownership consolidation.
• WLKI - Aside from the new expanded band, AM radio is already a chaos of interference.  In many areas, FM is similarly congested.  If pirate stations are allowed to proliferate, both AM and FM will soon resemble CB radio.  Will such stations present diverse viewpoints?  The commenter's station makes certain that many points of view are presented.  The station provides a variety of public service programming.  "It is true that Commercial stations are run for profit, but that is the very reason they are in a position to offer the kinds of activities mentioned above."
• WLMI - Opposes low power community stations.  Lists a variety of public service programs carried by commenter's station.  Commenter's station is not part of media consolidation.  Commenter's community "does not need a low-powered 'community' station operating out of someone's basement; it has a 24-hour professional station, that provides jobs for four full-time and four part-time employees."  Does not oppose "event" stations.
• WLZZ-FM - "Why are you allowing citizens who have no direction for their stations other than 'to broadcast' to have the opportunity to broadcast their agendas?"  This station provides excellent community service and the proposed low power stations will "never willingly honor such commitments."
• WMTA - Opposes proposals.  Agrees that the Telecom Act of 1996 has resulted in unacceptable station ownership consolidation, but believes the return of ownership limits is the cure, as opposed to creation of an LPFM service.  States that the amendment to petition filed by Skinner proposing amnesty for existing unlicensed stations would be "similar to inviting the bank robber back to the bank to work as a teller."  Proposes a list of all "known" unlicensed broadcasters be maintained by the FCC.  Those on the list would be denied future ownership of stations.  Discusses a petition submitted by the American Community Broadcasters Association, Inc., which proposes allowing AM stations to use FM translators.  Addition of LPFM stations will cause economic harm to existing independent stations, causing them to sell to conglomerates.  States that ownership limitations (both quantity of stations and residency requirements) may be unconstitutional.
• WNRI - Opposes proposals.  The proposal will further cut the already slim advertising pie.  Commenter's station already offers programming diversity.  No group is denied access.  No one in his community is asking for this service, since there is no need.  Introduction of more stations will decrease audiences for existing stations.  The commenter is one of the "little people" that the petitions are supposed to help in getting into broadcasting.  Prices for existing AM stations are affordable to almost anyone who is willing to sacrifice and work hard..
• Alan J. Wood - Supports RM-9208 and would be interested in applying for a construction permit for San Francisco.
• WPTL - Commenter's station will be placed in serious jeopardy should numerous low-power stations be permitted.  This will lead to further congestion of the bands, dilute the "media pool" and fractionalize the audience.  Commenter's experience with the proponents is that they wish to broadcast a narrow range of programming supporting their own causes.  Stations are affordable, it just takes work, patience, and credibility.  Adequate media diversity is available through cable access channels, public radio stations, other local stations, plus the internet.  Commenter's broadcast station is less valuable today than when purchased.  Would the proposed low power stations be able to survive?
• WQLV - Strongly object to proposals.  Station contributes about $5,000 per month of airtime to community service organizations, provides a "blizzard wizard" service.  "Does radio still provide community service?  It is more than alive and well at WQLV, and there is absolutely no need for more 'low-power' stations."
• WRDN - Opposes proposals.  Shut-ins rely upon local radio announcers for a friendly voice.  With low power stations causing interference, that voice may not be heard.
• WUFE/WBYZ - Don't create another 80/90 situation where there were applications for stations that were never built or later closed.  In this area, dozens of stations already serve their communities with entertainment and locally oriented programming.  "Signals are already being knocked back because of 80/90 low power stations that we approved."  Lists examples of local programming.
• Zillah School District #205 - The proposals clearly address an important public problem.  The FCC receives many letters annually from people who want to own an LPFM station as an outlet for self-expression.  None of the existing proposals consider section 47 USC 309(j)(1), which requires the use of competitive bidding to determine who shall be granted a license or permit when there are mutually exclusive applicants, except for noncommercial stations, where a random selection process could be used.  The commenter proposes the FCC re-establish the noncommercial class D service by deleting 47 CFR 73.512.