Comments on digital radio power increase 7/6/2009

COMMENTS OF PROMETHEUS RADIO PROJECT

Media Access Project submits these comments on behalf of Prometheus Radio Project in response to the Commission’s Public Notice seeking further comment on the Joint Parties’ request for power increase and the subsequent studies filed by National Public Radio (“NPR”). See Public Notice, Comment Sought on Specific Issues Regarding Joint Parties’ Request for FM Digital Power Increase and Associated Technical Studies, 24 FCCRcd 5818 (2009) (“Public Notice”). In these Comments, Prometheus Radio Project reiterates its objection to a blanket increase of the digital operating power using the in-band, on channel system (“IBOC”) from one percent to ten percent of a station’s authorized analog power. First, the Commission should not consider a power increase until it has adopted public interest obligations. Additionally, proponents of the increase have not yet addressed concerns regarding the impact a power increase will have on low power stations and the impact of self-interference. Moreover, analog service, which includes the low power service, must be protected from interference since analog service continues to be relied on by the vast majority of radio listeners.

Read the attached PDF for the complete comments.