Dear Chairman Kennard:
We write to comment on the low-power FM (LPFM) "micro radio" service proposed by the FCC.
We know that you take the Commission's spectrum management responsibilities seriously. We are concerned, however, that LPFM poses a grave threat to sound spectrum management.
The most immediate threat is that of interference with other services. It is clear that authorizing LPFM would require the Commission to dramatically weaken current interference standards. Such action would inevitably result in increased interference with existing FM broadcasters and other frequencies. Needless to say, this concerns us deeply.
We also are concerned that LPFM would jeopardize the conversion to digital radio. At a minimum, adding a large number of micro radio stations to the already congested FM radio band would make the transition more problematic.
We also are troubled by the potential impact on the excellent community services provided by existing broadcasters under today's system. Would LPFM broadcasters be required to meet the same public service obligations as existing broadcasters? Would new owners of LPFM licenses through sales be required to meet these obligations and operate locally?
Finally, we are concerned that the LPFM proposal legitimizes and encourages pirate radio operators. The suggestion by the Commission that former illegal broadcasters may be eligible for LPFM licenses sends the wrong message to these individuals, in our opinion.
For these reasons, we believe that the
Commission's low-power FM radio proposal is ill-advised at this time. We ask
that you carefully consider the implications of the proposal if adopted,
including the potential for interference problems and other conflicts, as well
as the FCC resources that will be required to regulate the service and manage
such conflicts.
Michael G. Oxley,
M.C.
Cliff Stearns, M.C.
Fourth Ohio
District
Sixth Florida District
cc: Commissioner Susan Ness
Commissioner Harold Furchtgott-Roth
Commissioner
Michael Powell
Commissioner
Gloria Tristani
