In the Matter of
Petition for a Microstation Radio Broadcasting Service

Comments on RM-9208

To: Federal Communications Commission

I feel it is necessary to file these comments in opposition to the majority of ideas put forth in RM-9208. After studying this petition, it is my opinion, as a technical consultant and broadcaster with 35 years experience, that the petition is in general ill-conceived, lacking technical merit and if enacted would doom the Low Power FM service to failure.

The RM-9208 petitioners, by their own admission, have no experience in the field of broadcasting and thus lack perspective, in this commenters opinion. The petition consists of general comments and opinions of how a so called micro-broadcasting service should be created, without giving any details on crucial issues, such as preventing interference, that could affect any such service. It touches somewhat on the needs for such a service only in general terms. It seems to have been spawned partly in response to watching a movie called "Pump Up The Volume" about a pirate radio broadcaster. Indeed, one of the petitioners told me that they sent a copy of this movie to each Commissioner. The other reason for filing the petition, again according to the petitioners, was in response to reading an article in a newspaper about the Stephen Dunnifer / Free Radio Berkeley "pirate radio" proceeding. So, it would appear, that their only background in this matter comes from a movie and a newspaper article. The petitioners have also told me that none of them intend to apply for or operate a low power radio station, if such a service is created. This seems strange to me, as would a chef who refused to eat his own meals. I understand that there are no qualifications required to file a petition for rulemaking at the Commission. I also understand that this petition languished at the Commission for over seven months before being assigned a rulemaking number. Apparently, according to reports in the broadcast trade press, Chairman Kennard, interested in exploring creation of a low power radio service, asked the Commission's Mass Media Bureau to look into the matter. They then assigned a rulemaking number to this petition to establish a public comment period on the matter in the hopes of receiving comments from the public that would help them form such a service. Indeed, that happened, particularly with the filing of a comprehensive petition assigned rulemaking number RM-9242, of which this commenter is the author. Although I believe the petitioners had good intentions, I believe they played right into the hands of critics of a low power radio service that would like to see such a service crippled by providing extremely low power levels (coverage areas) that are too small to be effective. Indeed, if the National Association of Broadcasters NAB) were told they had to create a low power radio service, I would suspect it would resemble this petition as regards to power levels (coverage areas). This petition poses absolutely no threat of competition to existing stations. The NAB appears to oppose anything that could pose even the slightest competition to their member stations. Although this may be good for NAB, it is not in the best interest of America, in my opinion.

According to the curves used to predict FM propagation, FCC rules Section 73.333 Figure-1 F(50,50) chart, the 1-watt maximum power limit in this petition with its corresponding maximum antenna height of 50-feet would provide a 1 mV/m  (60 dBu) signal contour out to only six-tenths of one mile. Their comparison to cells in a cellular telephone system is flawed in that a cellular telephone system covers a large area by switching from one cell to another as a customer (listener) drives through an area thus offering coverage over a large area. Their minuscule 1-watt signal would be lost entirely and not picked up by another such cell upon driving out of range, in just a few blocks. I understand that the petitioners may have amended this petition to include a range of up to five miles. Although this range may suit some small markets, it certainly is too low to be considered a "maximum" range for all stations in all size markets. For example, a similar service, the existing Low Power Television service allows for power levels providing coverage out to 15 miles or more. This type of coverage should also be available to a low power FM radio service, as proposed in RM-9242. Even FM translators, under current rules, are allowed up to 250 watts, which at 100 meters HAAT, provides a 60 dBu signal out to 8 miles. That is why RM-9242 provides for flexible power usage of 50-watts to 3-KW for its LPFM-l class stations, thus allowing coverage of small, medium and large markets. After all, those interested in operating a Low Power FM radio station live in all three sized markets and each should be provided for in any planned service.

 Besides the inadequate power levels proposed in RM-9208, I have a serious problem with their plan for allowing any applicant to construct his/her own transmitter. They say "The licensees should be allowed to establish, build and maintain their own transmitters". This plan is simply foolish and would result in equipment likely to cause serious interference problems to other radio stations as well as other services, due to harmonics and spurious emissions. My plan calls for use only of FCC type-accepted equipment to prevent such interference. Use of sub-standard equipment that does not meet FCC specifications has already created problems of interference to several airports and this cannot be condoned.

Another ill-conceived provision calls for a station who loses his license for lack of activity to be allowed to apply for the license again. If losing the license a second time, should be allowed to apply for the license again and even a third time. This is utter nonsense and shows a lack of respect for conserving precious Commission resources, at the very least! The petition does not even state what time period would trigger such a loss of license other than a vague statement saying "There should be a requirement that the station should broadcast at least a minimum number of hours per year for the license to continue in effect".

In conclusion, there is more wrong with this petition than is right. I could continue to find glaring faults in this so-called plan for a micro-broadcasting service, but I will conclude by saying that the Commission should not give this ill-conceived petition more than a cursory glance, for all the reasons stated above. I am not the type of person who finds fault with a plan without presenting a better plan. I have presented a much better plan for creation of a Low Power FM radio broadcast service nationwide. I refer you to my petition bearing FCC rulemaking number RM-9242.

Respectfully submitted,

L Rodger Skinner, Jr.

April 24, 1998

J. Rodger Skinner, Jr.
6431 NW 65th Terrace
Pompano Beach, FL 33067
(954) 340-3110

I, J. Rodger Skinner, Jr., do hereby certify that a true and correct copy of the foregoing "Comments on RM-9208" was sent via First Class U.S. mail this 25th day of April, 1998 to the following parties:
 

Nickolaus E. Leggett
Judith F. Leggett
1432 Northgate Square, #2A
Reston, VA 20190-3748

Donald J. Schellhardt, Esq.
45 Bracewood Road
Waterbury, CT 06706
 

VIA FEDERAL EXPRESS / OVERNIGHT DELIVERY
(An original and nine copies)
Office of the Secretary
Room 222
Federal Communications Commission
1919 M Street, NW
Washington, DC 20554