Magalie Roman Salas, Esq.
Secretary
 Federal Communications Commission
 1919 M Street, N.W.
 Washington, D.C. 20554
 

Re: RM-9242 and RM-9208

 Dear Ms. Salas:

Submitted herewith for filing, on behalf of InterNet Associates, are an original and four (4) copies of its Comments in connection with the above-rulemaking petitions.

Respectfully submitted,

KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, LLP

By:
Irving Gastfreund

Enclosures

TO: The Commission

INTERNET ASSOCIATES ("INA"), by its attorneys, pursuant to Sections 1.4, 1.45 and
l.405 of the Commission's Rules, and pursuant to the Commission's Public Notices of March 12, 1998 and February 5, 1998,¹ hereby submits its instant Comments with respect to the above-
referenced two rulemaking petitions, which request that the Commission amend its rules to create
a new "microstation" radio broadcasting service.² In support whereof, it is shown as follows:

The two above-referenced rulemaking petitions seek the establishment of a new AM-FM "micro-broadcast' service for stations which is essentially a low power FM ("LPFM") broadcast service not unlike the existing low power television service. The proposals could service the purposes envisioned by the proponents  i.e., to foster of freedom of expression of information for non-mainstream programming on radio.

INA is also interested in establishment of a type of "micro-broadcast' service in the FM band; however, INA is concerned with an avoidance of potentially destructive interference to existing stations.

In this regard, INA proposes a "micro-broadcast" service based on the reality that the existing Commission operating requirements for second adjacent channels, as set forth in the Commission's FM Rules, are no longer required, in light of the realities of microelectronics in FM radio stations and FM radio receivers today.

In this regard, older radios, prior to the Comrnission's adoption of the existing Table of FM Allotments in the early 1 960s, generally operated with the older technology of tubes. Based on this technology, it became necessary to contemplate repairs to radios rather than simple replacement of radio receivers. and it was not uncommon for a multitude of radio repair shops to exist.

However, today transistors and microchips have made tubes for radios virtually obsolete. Indeed, Intel has indicated that it is now possible to place several million transistor equivalents on a single chip. Microelectronics has thus changed the world. However. the advantages of microelectronics have not yet been brought to the domain of the Commission's second adjacent channel spacing requirements.

Real world experience with more stable transistor and microchip technology indicates that the second adjacent channel spacing requirements in the Commission's FM technical rules, adopted in the early 1960s, may no longer be necessary to protect existing stations from harmful interference. Accordingly, INA proposes a new "micro-broadcast" service for the FM radio band on such second adjacent channel stations (assuming that no harmful interference is caused to any existing broadcast stations), with each such station operating with an effective radiated power of under 100 Watts. This proposal would essentially be a type of "low power FM" service.

Advantages of such a service, of course, would include increased opportunities for targeting programming catering to specific "niches" for non-mainstream broadcasting. INA respectfully submits that the Commission's existing second adjacent channel mileage separations are unnecessarily restrictive in today's microelectronic climate and are not necessary to protect second adjacent channel stations from harmful interference. Real world experience will support this conclusion.

In sum, INA respectfully submits that the paramount public interest. convenience and necessity would best be served by expeditious adoption by the Commission of INA's aforementioned proposal for a new low power FM service, in lieu of adoption of either of the above-referenced "micro-broadcast" rulemaking petitions.

Respectfully submitted,

INTERNET ASSOCIATES

By:
Irving Gastfreund

Kaye, Scholer, Fierman, Hays & Handler, LLP
901 15th Street, N.W., Suite 1100
Washington, D.C. 20005
(202)682-3526
Its Attorneys

April 27, 1998

¹ Report No.2262 (Erratum released March 12 1998); Report No.2254 (Mimeo No.
 81672 released February 5, 1998).

² The Commission has extended the filing date for the of Comments and Reply Comments in this proceeding to April 27, 1998, and May 26, 1998, respectively.
 

 I, Mary Odder, a secretary in the law firm of Kaye, Scholer, Fierman. Hays & Handler, LLP, do hereby certify that on this 27th day of April, 1998, a copy of the foregoing Comments of InterNet Associates on Petitions for Rulemaking was sent via U.S. Mail, postage prepaid, to the following:
 

 J. Rodger Skinner
 President
 TRA Communications Consultants, Inc.
 6431 Northwest 65th Terrace
 Pompano Beach, Florida 33067-1546

 Nickolaus E. Leggett and
 Judith F. Leggett
 1432 Northgate Square No. 2A
 Reston, Virginia 20l90-3748

 Donald J. Scheliharcit, Esq.
 45 Presswood Road
 Waterbury, Connecticut 06706