Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
Proposal for Creation of the Low Power FM
(LPFM) Broadcast Service

FCC RM-9242 and RM--9208

Comments of Stephen Burke
 

I would like to see the Adjacent Channel Spacing Requirements for LPFM Stations changed. Especially since any possible interference by doing so would be received by the LPFM service not by full power stations.

I do not want to see each town limited to 1 station.

I would like to see AM added to this proposed Low Power Service.

I would like to see a 1 watt service that does not require a license.

I would like LPFM broadcasters to be free to experiment with various antennas for best coverage, this promotes research & development.

I don't want to see a transmission radious limit imposed, this would do away with any incentive to develop better equipment, especially antennas.

I don't think antennas should be limited below 150' in height (HAAT) especially in mountain areas.
 
I believe large companies & corporations should be kept out of LPFM broadcasting, this should be a voice for the people NOT another money maker for the greedy. I do not consider multi Million dollar business to be small business.

I believe that 100 watts ERP would be an adequate power ceiling for the LPFM service.

I believe license fee's should be kept to a minimum & the requirements simple.

Licenses should be first come, first served, till all available frequencies are used.

I am opposed to auctions, they serve no purpose except to favor the rich.

If timesharing is used it should be a voluntary agreement between applicants before license approval. The first applicant should be able to decide if he wants to share a license with someone.

I DO NOT believe larger stations should be allowed to "Bump" the smaller stations or force them to upgrade, this would defeat the entire purpose of the LPFM service. If they want a Full Power station let them apply for one. The only exception should be, for example, I have a 50 watt LPFM station & I decided to use a frequency that was available for a full power station (not LPFM) and at some future date someone was granted a license on that frequency I could be required to move my LPFM service to a different frequency.

I would like to see 3 types of LPFM service, the first being a 1 watt or possibly even up to 4 or 5 watts, with very little regulation & easily obtainable license or no license required. No restrictions on equipment except that it cause no interference.

The second LPFM service being 10 or 20 watts, using type accepted equipment & License required. This would be needed in all but the smallest towns or communities to get adequate coverage.

The third LPFM service being 50 or 100 watts using type accepted equipment, License required. This service could be used in larger towns where 10 or 20 watts is inadequate or in mountain areas or farming communities where many of the listeners are not in town.

Due to Frequency Modulation many transmitters could be put on the same frequency in adjoining towns or communities with overlapping signals WITHOUT interfering with each other due to the fact that the Receiver will only pick up the strongest signal, when you left one community you would loose their station & pick up the station to the community you are entering.

Now let me tell you a little story about a common law & Constitutionally Lawful LPFM station known as K103.5FM which operated in Holdenville Okla. from July 4 1996 to Jan. 16 1998 on 103.5 and at an ERP of 88 watts for apx. 1 year, this station closed on Jan.16 1998 due to a visit from operatives from your Dallas, Tex. office. K103.5FM was put on the Air after our gospel station (KRAF 1370 AM) was closed by its owner. K103.5FM was the ONLY station here for over a year. This station had the support of the community. It was listened to at the Mayors office, Several local businesses and the Davis Correctional Facility. We did not HIDE what we were doing or the fact we had no license. We distributed surveys several times. We announced many times on the air that we had no license & why. We have a multitude of letters in support of K103.5FM & how well it was liked. We never had a single complaint of adjacent channel interference or interference to any broadcaster on 103.5, we had no complaints of TVI or radio interference. We did our best to see to it that we did not cause any problems of any kind for anyone. We checked the frequency carefully before using it. We had a frequency study done. When we put up our 115 foot tower we got FAA approval for it. We used type accepted equipment, with harmonic filter. We sold no air time or commercials. A local broadcaster thought we were stealing his listeners, we played Southern Gospel & Christian Country, he plays non-Christian Rock-n-Roll, (Lets get real here), So he turned us in after a year & a half. I see no compet-ition here! We were shut down due to 1 thing, no license. The point is the people would like to have their station back. It is my understanding that the FCC works for the people, if so I would like to request your help. One of your operatives told my Uncle that there is a way to get a license even tho your available frequency book & frequency study says there is not. I want to know what it is. I have shown above that it can be done without interference. I don't care what frequency or what power even if it's only 10 watts. Will you help us? We will do the work, we just need to know how. You will find information from the former station attached.
 

Stephen Burke
1227 E. Main
Holdenville, OKLA 74848
1-918-697-4017
1-405-379-5521 fax
 

[note - due to poor copy, the FAA Acknowledgement of notice of proposed construction or alteration filed with these comments is not reproduced here.  hh]
 



Corrections Corporation of America
Davis Correctional Facility
Route 4, Box 40
Holdenville, Oklahoma 74848-9295
Phone: (405) 379-6400
FAX: (405) 379-6496

June 20, 1997

K1O3.5
1227 East Main
Holdenvifle, OK 74848

To Whom It May Concern:

This letter is wntten to you as a request by the below listed inmates who are currently
incarcerated at CCA - Davis Correctional Facility.

These inmates are faithful listeners of your station and are very appreoiative of what you do.
They asked rne to convey to you their full support and prayers.
 
 
Randall Kyle, #137992 Leslie Colbert, #192465
Willy Nida, #253049 Harold Smotherman, #136191
Jimmy Clymer, #231783 Phillip Sumlin, #217463
Jimmie Arnold, #179214 Avery McClain, #93386
Larry D. Hines, #226380 Michael McGee, #162542
Jedidiah Chappelll, #240743 Darryl Scoggin, #139771
Monte Barton, #242210 Rodney Still, #241715
Mark W. Trout, #170490 Matt Mathews, #220075
Kevin Ray Haney, #224405 Mickey Langdell, #89355
Everett Evans, #205625 David Mills, #182927
Carmon Watts, #218727 Frankie Rollans, #145266
Michael Lee Mathis, #126743 David McCoy, #130870
Billy Upshaw, #146077 Gailon Smith, #87980
Ira Redding, #151369 Rex Tastad, #151077
Joe Fairchild, #122348 Jack Allen, #229740
 

If there is anything else that we may do to further support your station, please let us know. Laborers Together for Him,
 

Chaplain Bill Boyd

BB/km


K103.5 FM
Your Southern Gospel Connection for the Holdenville Area

1227 EAST MAIN
HOLDENVILLE, OK 74848
405-379-5521

Our goal at K103.5FM is to be a blessing to you and a service to the community. Please fill out the attached Survey, along with your comments, and let us know how we are doing. It is important that we have this information for our files. Thank.you for your time and help.

K103.5FM, does not sell air time or advertising, we will announce, free of charge Gospel Singings, Revivals or other Church functions.

K103.5 FM HISTORY
For several years we have recorded all the best songs from a wide variety of CD's. These tapes we would play all day, each day at work. Many of our customers really enjoyed the music. Often we wished everyone could enjoy the music with us. Then came a great idea, we could start a Radio Station. On the afternoon of July 4, 1996, we went on the air with apx 250 mw signal with the intent to experiment with various antennas, the second one worked so well we decided to use it. We continued to broadcast 24 hours a day beginmg July 4. Later the Lord provided a 10 watt stereo transmitter which we repaired and put on the air. Soon we changed locations and built a studio, we bought new studio equipment. The Lord provided a stereo audio processor. We continued broadcasting.

 Later on the Lord provided a better transmitter, we repaired it and with minor modifications's we now had 20 watts. We installed the new transmitter, then we changed the frequency to 103.5 to improve the signal. Other improvements have been and will continue to be made. As Paul Harvey says, "now you know the rest of the story." We trust K103.5 FM will be a blessing to you, as it has been to many others.

We are a 24-hour a day FM STEREO STATION, playing mostly Southern Gospel and Christian Country Music. We strive to pick the best and fastest music possible. We play songs with a good message and the anointing of God on them. Here at K103.5 FM, we enjoy the moving of God's Spirit and we believe, "If it's dead it needs buried." We are a different kind of Gospel Radio Station.

 K103.5FM may not be receivable in all areas. A directional rooftop antenna pointed at Holdenville and/or a high quality radio should help those with a poor signal.

 K103.5FM is kept on the AIR by your freewill offerings of any amount; we thank you for your support.
 

SURVEY
Circle Your Choice

1. Do you listen to K103.5FM    YES   NO
2. How well do you receive K103.SFM   Good Fair   Poor   No-signal
3. How long have you known about K103.5FM  Just found out,  Under 1 month,  Over 1 month,  Over 3 months,   Over 6 months
4. Compared to other Gospel Stadons, which Station do you prefer   K103.5FM
 OTHER STATION
5. What type of Gospel music do you like best
6. Do you like  SLOW  MEDIUM or FAST songs best.
7. Would you like K103.5FM to remain on the air. YES     NO
 
Name
Address
Phone
Signature
Date
 
 

Write
Your Comments On Back