LPFM Report and Order Summary

MM Docket No. 99-25

Adopted: January 20, 2000

Released: January 27, 2000

Effective Date: Sixty (60) days after publication in the Federal Register

• A goal in creating the LPFM service is to create a class of radio stations designed to serve very localized communities or underrepresented groups within communities.
  • A maximum of 100 watts and 10 watts for the two levels of service will allow licensees to serve their local communities, and will permit a greater number of new stations to be authorized, fostering a diversity of new voices on the airwaves.
• A second goal is to specifically include the voices of the community-based schools, churches and civic organizations.
• The final goal is not to compromise the integrity of the FM spectrum.
  • The Commission recognizes that eliminating both 2^nd and 3^rd adjacent channel protections would create more opportunities for LPFM, but it noted that "given the ambiguity in the record on this issue and our commitment to ensure that the new LPFM service does not unacceptably interfere with existing radio services or impede a digital future for radio broadcasting, we must proceed cautiously."

Classes of Service

• The Commission will not authorize LP1000 stations, but will authorize LP100 and LP10 stations.

1. LP100 Service

• LP100 stations will be authorized to operate with maximum facilities equivalent to 100 watts ERP at 30 meters (100 feet) HAAT.
• Minimum facilities will be equivalent to 50 watts at 30 meters.
• This will produce a maximum 1 mV/m contour (60 dBu) with a radius of approximately 5.6 kilometers (3.5 miles), subject to the radio environment.
• Antenna heights greater than 30 meters HAAT would be permitted, but an appropriate downward adjustment in ERP would be made so that the 1mV/m F(50, 50) signal contour radius would not exceed 5.6 kilometers.

2. LP10 Service

• LP10 stations will operate at between one and 10 watts ERP and an antenna height of up to 30 meters (100 feet) HAAT.
• Such stations will produce a 60 dBu signal out of about 1.6 to 3.2 kilometers (1 to 2 miles) from the antenna site.

Nature of Service and Licensees

• LPFM stations will be noncommercial educational stations because the FCC believes a NCE service will fulfill its goal of providing voices and allow community groups to provide programming that is responsive to local community needs and interests.
• The Commission’s rules require an NCE station will use the station "for the advancement of an educational program" – specifically, an applicant must be (a) a government or public educational agency, board or institution, or (b) a private, nonprofit educational organization, or (c) a nonprofit entity with a demonstrated educational purpose.
• The programming does not necessarily have to be exclusively educational.

2. Public Safety and Transportation

• The public safety and transportation groups (such as the New York State Thruway Authority and the Texas Department of Transportation) will be eligible to apply for LPFM stations.
• However, all TIS licenses or other public safety or transportation licensees will be required to return their existing licenses "upon the initiation of LPFM service."

Eligibility and Ownership

• The Commission will prohibit common ownership of LPFM and any other broadcast station, including translators and low power television stations, as well as other media subject to the ownership rules.
• The Commission concludes that its interest "in providing for new voices to speak to the community, and providing a medium for new speakers to gain experience in the field, would be best served by barring cross-ownership between LPFM licensees and existing broadcast owners and other media entities."
• This restriction is "national and absolute in nature" – for example, a newspaper cannot have an attributable interest in any LPFM station, regardless of whether the newspaper and LPFM station are co-located.
• There also is a prohibition on operating agreements in any form, including time brokerage agreements, LMAs, and similar agreements between full-power broadcasters and LPFM licensees, or between two or more low power licensees.
• However, any existing licensee may apply for an LPFM station on the condition that it is otherwise qualified and it represents that it will divest its interest prior to commencement of LPFM operations.

2. Requirement That Applicant Be Community Based

• For the first two years after the initial filing window for LPFM service, all LPFM applicants must be based within 10 miles of the station they seek to operate.
  • The applicant must be able to certify that it or its local chapter or branch is physically headquartered, has a campus, or has 75 percent of its board members residing within 10 miles of the reference coordinates o the proposed transmitting antenna.
• Non-local applicants will be able to apply for LPFM licenses beginning two years after the first window for LPFM – the Commission believes that this approach will allow for more local entities to run LPFM stations, but will not let the spectrum go unused if no local entity comes forward.
• The Commission believes that the local licensee preference does not run afoul of the Bechtel decision – where the court overturned a comparative criterion that required station owners to work more than a specific number of hours per week at the station – because the preference in LPFM rests on its predictive judgment that local entities will be more attuned and responsive to the needs of the community, where have been underserved by commercial broadcasters, as opposed to the situation in Bechtel, where the integration preference elevated quantitative factors over qualitative factors.
• Further, the Commission believes that the local entity requirement is essential because the LPFM service is noncommercial – thus, it cannot rely on commercial market forces to ensure that LPFM licensees are responsive to local needs.

3. National Ownership Limits

• For the first two years of LPFM service, any one entity may own only one LPFM station.
• After the first two years, to bring into use whatever low power stations remain available but unapplied for, one entity may own up to five stations nationally.
• After the first three years of LPFM service, one entity may own up to 10 stations nationwide.

4. Local Ownership Limits

• One entity may own only one LPFM station in a "community." "Community" is defined differently than the traditional use of the term. In LPFM, it refers to the very small area and population group that will make up the potential service contours and prospective audiences.
• For the purposes of the LPFM local ownership limits, no entity may own or have an attributable interest in two or more LPFM stations located within 7 miles of each other.
• The seven-mile rule applies to both LP100 and LP10 stations.
• The Commission believes that the primary benefit of local multiple ownership, increased efficiency, is less compelling with respect to LP100 and LP10 noncommercial educational stations.

5. Attribution

• The Commission will apply the commercial attribution rules to the LPFM service – thus, the interests of the applicant, its parents, its subsidiaries, their officers and members of their governing boards will be attributed.
• Local Chapter Exception: if a local chapter of a national organization can demonstrate that it: (1) is separately incorporated, and (2) has a distinct local presence and mission, the local chapter can apply for a license in its own right and the national entity’s "ownership" will not be attributed to it. The local entity must be able to show a significant membership within the community, as well as a local purpose that can be distinguished from its national purpose.

6. General Character Qualifications and Unlicensed Broadcasters

• The Commission will apply the same character qualification requirements to LPFM licensees as apply to full power licensees.
• A LPFM applicant will be accepted, if it at some time broadcast illegally, certifies, under penalty of perjury that (1) it voluntarily ceased engaging in the unlicensed operation of any station no later than February 26, 1999, without specific direction to terminate by the FCC; or (2) it ceased engaging in the unlicensed operation of any facility within 24 hours of being advised by the Commission to do so.
• Submission of false or misleading certifications will subject the applicant to enforcement action including fines, revocation of license and criminal penalties.

Technical Rules

• The Commission will authorize low power stations throughout the FM band, where the station will fit, but not in the AM band.
• The same interference protection and other technical standards for LPFM operations will be applied to LPFM stations in the reserved and nonreserved bands.
• The FCC believes that most LPFM stations will not require studio-to-transmitter links (STL) because most will co-locate program origination and transmission facilities.
• However, LFPM operators may use the broadcast auxiliary frequencies used by full-service stations for STLs on a secondary basis.

2. LPFM Spectrum Rights and Responsibilities

• LPFM stations must protect radio reception within the service areas of existing full-service stations, as well as the existing service of FM translator and booster stations.
  • Applicants for new or modified LP100 or LP10 facilities will be required to meet minimum station separation distances to protect the service contours of authorized commercial and noncommercial FM stations of all classes, including Class D; FM translators and booster stations; and existing LP100 stations.
  • LPFM applicants must protect full-service FM, FM translator and LP100 facilities proposed in applications (for example, FM minor change applications) filed before a public notice announcing an LPFM filing window.
  • Full-service applicants will not be required to protect the facilities proposed in LPFM applications.
  • LPFM stations proposed to operate on channels 201-220 will be required to protect television stations operating on TV channel 6.
  • Applicants for LP100 stations will not be required to protect authorized LP10 stations or LP10 applications.
  • There is a 20-kilometer buffer added on to the separations for co-channel and 1^st adjacent channel between LPFM and full-power stations.
• LPFM stations should not prevent FM stations from modifying or upgrading their facilities, nor should they preclude opportunities for new full-service stations.
  • LPFM stations will not be protected against interference from subsequently authorized full-service facility modifications, upgrades, or new FM stations.
  • LFPM stations will not be required to meet minimum distance separation requirements to protect their service areas against interference received because they are not protected from future full-service facility modifications.
  • As a guide to LPFM applicants, the Commission has provided minimum station separation distances necessary to protect an LPFM station’s 60 dBu contour.
• LPFM applications will be required to protect vacant FM allotments.
• However, once an LPFM station is built and operating, the Commission wants to permit it to continue operating on its channel, wherever possible, as the radio environment changes around it.
  • LPFM stations will be permitted to continue operating even though they would cause interference within the protected service contours of a subsequent authorized FM service, including new stations and facilities modifications or upgrades of existing stations.
  • However, no LPFM station will be allowed to cause interference within a commercial or NCE FM station’s 3.16 mV/m (70 dB) contour – if the new full-power FM station or modification application would result in such interference, the affected LPFM station will be provided an opportunity to demonstrate that interference is unlikely to occur within this contour (e.g. due to terrain shielding). If the LPFM station fails to make such a showing, it will be directed to cease operations upon the commencement of program tests by the full-power station.
  • If an LPFM station makes a showing, but actual interference results, a complaint of interference must be served on the LPFM station and filed with the Commission. The LPFM station must suspend operations within 24 hours unless the interference has been eliminated by the application of suitable techniques and to the satisfaction of the complainant. The LPFM station may only resume operations at the direction of the FCC.

3. Minimum Distance Separation Requirements

• The Commission has adopted minimum separation requirements for LPFM stations as a means of protecting full service commercial and noncommercial educational stations, even though such methodology will preclude new LPFM stations in some areas.
• Spacing rules are also adopted to protect FM translator stations and other LPFM stations, Puerto Rico and the U.S. Virgin Islands, and the 20 "grandfathered superpowered" stations operating in the reserved band, as well as TV channel 6.
• There are no minimum spacing separations between LPFM stations operating two or three channels apart.
• LPFM stations are not protected against interference from full service stations, but are designed to prevent the LPFM station from causing interference to the protected service areas of full-power FM and other protected stations.
• FM translator rules are modified to protect existing LPFM stations from interference by subsequently filed FM translator stations.
• The 20 km buffer for co-channel and 1^st adjacent channel full-power stations will allow full-power stations to move and increase the likelihood that the LPFM station operation would not cause interference within a full-power station’s community of license.

4. Second and Third Adjacent Channel Protection

• The Commission finds "that the record in this proceeding thus far, including the technical data and other studies submitted, supports a conclusion that any risk of interference from LPFM stations of 100 watts or less is small and, on balance, is outweighed by the benefits of this new service."
• It concludes that 3^rd adjacent channel protections to or from such stations are not necessary and that 100 watt LPFM stations operation on 3^rd adjacent channels will not result in significant new interference to existing FM stations or to the development of IBOC DAB.
• The Commission found direct comparison of the technical studies difficult because of certain limitations – mainly because all of the studies used different measures to determine when interference occurs.
• The FCC did not find the audio S/N criteria suggested by both CEMA and NAB to be appropriate interference criteria for today’s FM radio service. The Commission also defended their use of distortion as an appropriate method to use.
• The Commission does not believe these measures are appropriate when most radios do not perform at this level without additional interference, and still provide satisfactory service to the public – thus a lower value or measure of acceptable performance would be more appropriate for interference purposes.
• The Commission also states that "another limitation of the studies was the relatively limited sample of FM receivers examined. The relatively small samples contained in each of the studies makes it difficult to draw statistical inferences with regard to the general population of FM receivers."
• The Commission admits that the studies do show that current FM radios exhibit a wide range of performance with regard to audio reception quality and interference rejection.
• The Commission notes that car radios and home stereos perform well in the presence of 3^rd adjacent channel interference – and while the lower cost clock, portable and personal radios do not perform as well – it believes that its "decisions with regard to LPFM service should not be constrained solely by the performance limitations of lower cost radios any more than we should use those radios to redefine existing FM radio service."
• Using NAB’s median receiver performance test results from the clock, personal and portable tests, the FCC finds that the interference areas would be generally 1 km or less generally, and that this estimate is conservative given NAB’s performance criteria and NAB’s sample had some of the poorer performing radios among the four studies.
• With regard to 2^nd adjacent channel protection requirements – the FCC finds the risk of interference may be somewhat higher, thus the 2^nd adjacent channel protection requirements are retained.

5. Other Technical Standards and Provisions

• Power/Height Restrictions: FCC will authorize equivalent height and power combinations to produce the 60 dBu contour generated by the maximum and minimum permitted facilities for the LP100 and LP10 stations. The staff will use a computer program to calculate the antenna HAAT based on the information provided by the LPFM applicant.
• Directional Antennas: The FCC will not authorize directional antennas for LPFM stations because it sees no need for stations to employ such antennas.
• Transmission standards: LPFM stations will abide by the same transmission standards presently in use for commercial and noncommercial stations. These standards, in most cases, will be met through the use of type certified equipment. LPFM stations will be required to adhere to the 200 kHz channel bandwidth, as well as the out-of-channel signal attenuation requirements, the center frequency drift limits and the limits on modulation. LPFM stations may engage in mono- or stereophonic operations. LPFM stations may also use subcarriers during those periods when the FM signal is on the air.
• Antenna Polarization: LP10 and LP100 stations throughout the FM band will be permitted to use horizontally polarized, vertically polarized, or circularly or elliptically polarized antennas, as desired by the applicant.
• Protection of AM radio radiation patterns: LPFM applicants should be aware that antenna structure construction within 3.2 km of a directional AM station or .8 km of a nondirectional AM station will subject the LPFM station to the requirement s of 47 C.F.R. § 73.1692. The AM station must make measurements before and after installation – at the cost to the LPFM station – to assure the AM station is not adversely impacted. The LPFM station would also be required to pay for corrective measures.
• Tower Height/FAA Coordination Requirements: Any proposal before the Commission that specific antenna supporting structure in excess of 61 meters above ground level is subject to the Commission’s requirements for antenna structure registration requirements.
• Blanketing Interference: For one year after the commencement of transmissions with new or modified facilities, all FM stations are required to take remedial action to resolve blanketing interference complaints occurring within the immediate vicinity of the antenna site. The blanketing contour for an LP100 station is approximately 125 meters from the transmitter site and a 10-watt LP10 station blanketing contour extends 39 meters. LPFM stations must solve blanketing complaints in the same manner as full-power stations.
• Potential Television Channel 6 Interference: A spacing table will be used to protect TV channel 6 to simplify processing and lessen the filing burden on applicants. LPFM applicants will not be required to coordinate their proposals with any potentially affected channel 6 television station.
• Radio Reading Services: The Commission does not set technical standards for receivers, thus it cannot consider the potential interference that might affect SCA reception. The FCC believes that the 20 km buffer to co- and 1^st adjacent channel protections should provide additional protection.
• Transmitter Certification: LPFM stations must use type-certified transmitters.
• Unattended Operation: LPFM stations may operate in unattended mode. LPFM stations must advise the FCC of unattended operations and provide the address and phone number of the responsible party during the unattended operation times. The responsible party must be able to shut off the transmitter within 3 hours of receiving notice from the FCC. FCC encourages the use of monitoring equipment. During the periods when the LPFM station is not transmitting programming on its regular channel, the transmitter must be turned off.
• Station Logs: Station logs for LPFM need contain only the following entries:

1. Daily observation of proper function of tower obstruction lighting;
2. Dates and a brief explanation regarding station outages due to equipment malfunctioning, servicing or replacement;
3. Any operation not in accordance with the station license;
4. Receipt of weekly EAS test;
5. Name of person making the entry.

• Logs must be retained for two years from the date of the last entry, and station logs must be made available to FCC personnel upon request.
• Environmental Requirements: LFPM applicant will have to certify compliance with the environmental requirements of Section 1.1307. The Commission will simplify the compliance worksheets in FCC Form 301 to account for the low operating power of LPFM stations.

Application Processing

• The Commission will not adopt a mandatory electronic filing system for LPFM application forms at this time.
• Assuming the availability of the forms, permissive electronic filing will be available for the first LPFM filing window.

2. Window Filing Process

• The Commission has adopted a window filing process because it allows the staff to control the filing and processing of broadcast applications.
• Applicants will be able to file at any time over a period of several days without losing filing rights. The window will be opened for five business days – applications filed before or after the dates specified in the public notice will not be accepted.
• The MMB will release a public notice announcing the national filing window for LP100 applications after the Order becomes effective (60 days after publication in the Federal Register).
• The public notice will be released at least thirty days in advance of the filing window (window is expected to be open in May).
• Full power applications filed on or after the date of release of the public notice announcing the opening of an LPFM window will not preclude the filing of conflicting LPFM applications filed during that window.
• Where the conflict ultimately is determined to relate to service inside the city contour of a full power station, the LPFM application will be dismissed.
• The staff initially will screen applications for the purpose of identifying those that are mutually exclusive and those that fail to protect existing stations will be dismissed without the applicant being afforded an opportunity to amend.
• Technically acceptable non-mutually exclusive applications will be further reviewed for acceptability and processed by the staff.
• Groups of mutually exclusive applications will be identified and subject to the selection procedures.
• After selection of one application from a mutually exclusive group, it will be reviewed and announced that it has been tentatively selected and is acceptable for filing.
• Petitions to deny the application will be due within 30 days of the release of the public notice of its acceptability for filing. Petitions and informal objections will not be considered unless and until the application has been tentatively selected for processing and found acceptable for filing.
• The Commission will develop software to assist in determining whether specific frequencies may be available – the software will merely assist, but cannot determine conclusively whether a frequency will be available.

3. Selection Among Mutually Exclusive Applications

• The Commission adopts a point system for resolving mutual exclusivity among LPFM applicants.
• There are three selection criteria:

1. Established community presence;
2. Proposed operating hours; and
3. Local program origination.

• The system will employ voluntary time-sharing as a tiebreaker – tied applicants will have the opportunity to aggregate points by submitting time-share proposals.
• As a last resort (where time-sharing or settlement cannot be reached), successive equal license terms totaling eight years, without renewal expectancy for any of the licensees, will be awarded.
• Established Community Presence: Applicants that have established community presence of at least two years’ duration will be awarded one point. The applicant must be able to certify that it has been physically headquartered, has had a campus, or has had 75 percent of its board members residing within 10 miles of the reference coordinates of the proposed transmitting antenna.
• Proposed Operating Hours: One point will be assigned for applicants that pledge to operate at least 12 hours per day. The minimum operating hours for LPFM stations are five hours per day.
• Local Program Origination: One point will be assigned for applicants that pledge to originate locally at least eight hours of programming per day. Local origination is defined as the production of programming within 10 miles of the reference coordinates of the proposed transmitting antenna.
• Applicants will have to certify they meet the qualifying conditions when claiming points for operating hours and program origination – and they must adhere to their pledges.
• Random audits will be used to verify the accuracy of the certifications and the Commission will entertain written complaints regarding actual performance.
• The Commission has deferred consideration of a selection criterion that provides points for minority applicants until such preferences can be justified by the on-going Commission fact-finding studies.
• Tiebreaker – Voluntary Time-Sharing: If the point system results in two or more mutually exclusive applicants, they will have 30 days to amend their applications incorporating voluntary time-sharing proposals. Each time-share proponent must propose to operate at least 10 hours per week.

• If all tied applicants agree, the Commission will review and process all of the tied applications.
• Some of the tied applicants can agree to share and aggregate their points.

• Final Tiebreaker – Successive License Terms: If no settlement or time-share agreement, the staff will review the tied applications for acceptability – those that are grantable will be eligible for equal, successive license terms of no less than one year each, spanning a total of eight years. If there are more than eight entities, the Commission will dismiss all but the eight with the longest established community presence. If there are still more than eight, the entire group will be deemed ungrantable and dismissed if a final opportunity to settle is not reached within 30 days. There will be no renewal expectancy for any of these licensees.
• Settlements: Applicants may propose a full settlement at any time during the selection process after the release of the public notice announcing the mutually exclusive group. Settlements must be universal – they must involve all of the mutually exclusive applicants within a group. The Commission’s rules for settlements must be followed. Settlements may incorporate voluntary time-share proposals.
• Delegated Authority: The Commission is seeking authority from Congress to delegate the responsibility for applying the point system to the staff. Until authority is received, the staff will refer point system proceedings to the Commission for disposition.
• Minor Modification of Authorized LPFM Stations: The Commission will permit the filing at any time of certain "minor change" applications. For LP100 stations, a minor change may involve a transmitter site relocation of less than two kilometers. For LP10 stations, a minor change may involve a transmitter relocation of less than one kilometer. Minor change also includes any change in frequency to avoid interference. All other changes are major and subject to window filing procedures.

4. License Terms and Renewals

• LP100 and LP10 stations will have the same license terms and renewal expectancy as full-power FM radio stations (except in a successive license situation under the tiebreaker procedure). Thus only if incumbent LPFM licensees fail to meet their obligations will other applicants be eligible to apply for the same license.
• The licenses will follow the same schedule for full-power stations – all initial LPFM licenses will be for a period of less than eight years to fit into the synchronized schedule.

5. Transferability

• LPFM licenses and construction permits cannot be transferred to avoid license speculation.
• Unused permits and licenses are returned to the Commission.

Programming and Service Rules

• The Commission concludes that certain obligations imposed on full-power radio licensees would be unnecessary if applied to LPFM licensees.
• The Commission believes that the local nature of the service, coupled with the eligibility and selection criteria will ensure that LPFM licensees will meet the needs and interests of their communities.
• LPFM licensees will not be required to provide programming responsive to community issues or to maintain a list of issues addressed or specific programs aired.
• LPFM stations must follow the indecent and obscene broadcasting rules; comply with the sponsorship ID and political programming rules; rules regarding taped, filmed or recorded material, personal attacks, and periodic call sign announcements.

2. Locally Originated Programming

• The Commission is encouraging the provision of locally originated programming by means of a licensing preference, but does not impose specific local originated programming rules on LPFM licensees.
• LPFM stations cannot be used for retransmitting the programming of full-power stations.

3. Political Programming Rules

• The Commission concludes that it is required by statute to apply the same political rules to LPFM stations as applied to full-power stations.
• LPFM stations must provide reasonable access to federal candidates on a free basis due to their noncommercial status.
• Equal opportunity provisions also apply.
• LPFM stations may not support or oppose any candidate for political office, or charge candidates for the time used on their stations, or discriminate among candidates.
• LPFM stations must maintain a political file to record the requisite particulars.

4. Station Identification

• Low power radio stations will positively identify themselves with a four letter call sign with the suffix "-LP."
• Such identification will inform the public the station is a low power station.
• A call sign cannot exactly duplicate the call sign of any other broadcast station and cannot contain the same first four letters as another station without written consent.

5. Operating Hours

• The Commission will impose the same minimum operating hour requirements on LP100 and LP10 stations that currently apply to full-power NCE FM stations.
• LPFM stations will be required to operate at least 36 hours per week, consisting of at least 5 hours of operation per day on at least 6 days of the week; however, stations licensed to educational institutions are not required to operate on Saturday or Sunday.
• To accommodate situations in which the demand for airtime does not exceed the spectrum availability, a station will not automatically be deleted if it is operating at less than the minimum hours – when another applicant comes forward to use the channel, that applicant can notify the Commission of the incumbent’s failure to meet minimum hours and demand that the incumbent return its license or agree to a time-sharing arrangement that will accommodate both parties.

6. Main Studio Rule, Public File Rule and Ownership Reporting Requirements

• The Commission will not impose main studio, public file or ownership reporting requirements on LPFM stations.
• It believes that these requirements will place an undue burden on such small NCE stations.
• The Commission concludes that all LPFM licensees must comply with the Commission’s long-standing prohibition against employment discrimination, but other EEO recruiting requirements will not be imposed because the Commission anticipates the vast majority of LPFM stations will not employ over 5 full-time employees.

7. Construction Permits

• LP100 and LP10 permittees will have 18 months to construct their stations.
• The Commission recognizes that zoning and permitting processes may, in some cases, delay construction, but it does not intend to grant extensions to the construction permits.
• LPFM stations will have the same eligibility for tolling of the construction period as other full-power stations.

8. Emergency Alert System

• LPFM stations will be required to participate in the EAS structure, but in a modified way.
• LPFM licensees will be required to install and operate Commission-certified decoding equipment, which will alert station personnel to emergency alerts.
• LPFM stations must pass any national emergency audio messages on to listeners.
• Participation at the state and local levels will be on a voluntary basis.
• LPFM stations are exempt from installing and operating encoders.
• EAS waivers will be granted on a case-by-case basis in appropriate circumstances upon a sufficient showing of need.

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© Copyright 2000. National Association of Broadcasters, Washington, D.C. All Rights Reserved.

L-0001  Updated: 2/2000