345 North 24th Street
Lebanon, PA 17046

April 13, 1998

Office of the Secretary (1800)
Room 222
Federal Communications Commission
1919 M Street, NW
Washington, DC 20554

Dear Sir:

This letter addresses comments to proposed rule-making, involving Low Power Broadcasting, items RM9242 and 9208.

As a commercial radio broadcaster for the past 25 years, I have seen the air waves disintegrate from what has been "operating in the public domain" to a free-spirited system, not serving the public and concerned mainly with how large a portfolio of stations can be obtained and how great a bank account can be achieved.

With FCC deregulation several years ago, the ownership issue has become one of David verses Goliath. I have no problem with industries, such a banking, gobbling up smaller financial institutions and creating mega-banks. However, radio broadcasting is different, as the AM and FM airwaves are "owned" by the general public. As a result only those with huge dollars to invest may start or buy a new broadcast station and the little guy, well, his or her hopes of ownership and truly serving the public are dashed.

As a result, I support low power microbroadcasting in the strongest words. I see this type of (regulated) broadcasting as a method to return at least radio back to the public in terms of ownership and to begin again, to serve the public as a public trustee. Many microbroadcasters currently on the air (admittedly some are illegal) do indeed offer religious, minority and otherwise programming that other licensed, mega-companies do not and will not offer because such programming many not be a large enough revenue producer.

I believe low power broadcasting should contain the following regulations:
 

  1. AM frequencies be limited to the expanded AM band of 1610 to 1710 khz.
  2. Between one and three non-interfering frequencies assigned to each community regardless of any frequency assignment in that area.
  3. Power would be limited to one (1) watt or less.
  4. All transmission equipment must be FCC type accepted/approved.
  5. All low power stations apply for such frequencies paying a small processing-registration fee. Approval will be based on a first come first served basis and non-interference with any existing station.
  6. All low power stations must register each year with the FCC to advise if they are on the air and of their current mailing address.
  7. Low power stations should not subjected to EAS and other monitoring equipment regulations, due to the high cost of such equipment.
I applaud the Commissions actions in at least finally considering getting low power broadcasting out of the so called "gray area" and possibly into a viable, legal, service to the true local community member of the media.

I will be watching the progression of this rule making and hope for its speedy adoption. Please contact me if you have any questions and desire further input.

Sincerely,

Douglas J. Neatrour