FCC filing in response to the Mitre study on third adjacency - 10/14/2003

In October of 2003, Prometheus Radio and other concerned organizations filed this comment to the FCC in response to the Mitre study, and independent study on the interference caused by LPFM on third-adjacent channels to other broadcasts.  The testing concluded that the effects were neglible; both in how much interference they induced and in how close one must be to a LPFM broadcaster to register interference.
The response also highlighted how stringent the Mitre study's testing was.  In truth, its standards were set far higher than those of the FCC.  Finally, it discusses the problems with the current translator regulations and offers recommendations to promote localism with LPFM.

Download the entire filing at FCC filing in response to the Mitre study on third adjacency.

Please read the FCC's own report to Congress on low power FM radio, as a result of the MITRE study, here: http://prometheusradio.org/images/mitre_lpfm_fcc_summary.pdf

 
SUMMARY

The Comments first highlight the success of low power radio, showing the vibrant sparks on the dial now available in hundreds of communities across the country, including in Opelousas, LA, Temperance, MI, Oroville, CA, and Ocean City, MD. The Comments show how the third adjacent channel restriction prevented the Center for Hmong Arts and Talent, in Minneapolis, Minnesota from getting on the air.

The Comments applaud the independent testing of LPFM, which has already wasted significant tax-payer dollars proving what we already know: that LFPM stations on third adjacent channels will not harm current broadcasts. The Mitre report finds no significant LPFMrelated degradation to a full power station at more than 333 meters from an LPFM transmitter, and the vast majority of what little degradation was discovered only occurred at distances less than a hundred meters from the transmitter site. Mitre also concluded there was no conceivable scenario in which more than 0.13% of the area within the protected contour of a full power station could be disturbed. No further testing is needed.

The Comments below show that Mitre’s analysis was conservative, and that it attributes all interference in the study to third adjacent interference when much of it is likely to have been caused by blanketing interference. The FCC already has rules in place for LPFM and full power broadcasters to protect against blanketing interference.

The Comments also show that the Mitre testing criteria far exceed criteria used by the FCC and the NRSC to evaluate IBOC. In particular, both receiver selection and noise interference were evaluated and were found sufficient to approve IBOC using much less stringent tests that those employed by Mitre. Although the LPFM Advocates represented here fully expect that LPFM’s historic opponents will critique the study, the fact remains that those who lobbied Congress against LPFM are responsible for the study’s design.

Finally, LPFM Advocates offer suggestions for the Commission both in the Low Power Radio docket and in the new Localism Task Force docket to promote localism through improving the operation and implementation of LPFM. In particular, LPFM Advocates explain how non-local translators are eviscerating any chance for adding LPFM stations, even under the present, overly-restrictive, interference limits. .....

Please read the entire filing at FCC filing in response to the Mitre study on third adjacency.