Reply comments on a digital radio power increase 7/17/2009

Media Access Project submits these reply comments on behalf of Prometheus Radio Project (“Prometheus”) in response to the initial comments filed pursuant to the Commission’s Public Notice seeking further comment on the Joint Parties’ request for power increase. See Comment Sought on Specific Issues Regarding Joint Parties’ Request for FM Digital Power Increase and Associated Technical Studies (May 22, 2009). Based on the initial comments filed, the Commission should reject any blanket increase of the digital operating power using the in-band, on channel system (“IBOC”). The Commission must ensure that analog signals are protected, especially since a power increase will threaten the public interest due to interference to full-power analog channels and existing low power FM (“LPFM”) stations. Thus, the Commission should defer any increase in power until, at a minimum, the National Public Radio (“NPR”) study has been presented.

See the attached PDF for the full reply comments.