Under 1 month now to produce a professional submission supporting 5 watt
LPFM base power in both guardbands. This means up to 88.7 outside of
Auckland, and 106.7 to 107.7.

I've been informed that one of the large commercial networks have
already filed their submission and are strongly against a 5 watt base
power system. I'm not sure what their stance on 5 watt eirp is, but I
suspect they don't care so much about that.

Their argument is that 5 watt base power can be turned into 50 watts in
one direction using a high gain directional antenna system, which could
provide similar coverage to their commercial frequencies which they paid
a lot of money for.

We need to attempt to overpower these arguments with some good ones of
our own, such as:

1. Testing by RSM field officers that a station is complying with
regulations
will be much easier with a 5 watt base power limitation. Some operators
are currently using directional antennas at low power levels, and with
an e.i.r.p. limitation, the field officer will either require knowledge
of the antenna gain and feeder loss to the transmitter, or will be
required to take RF field strength measurements which can be time
consuming to obtain accurate figures in all directions, particularly
where the antenna is in an elevated situation.

2. 5 watt base power will tend to attract more directional antenna
systems which will provide more localized suburban coverage areas and
generally much less interference with operators in other areas. This
will provide a better service to the community, which is what LPFM is
all about. Listeners in the targeted area will be able to receive the
station on home stereos without interference from other operators, and
without the expense of purchasing outdoor aerials as is often the case
currently.

3. There has been some pressure on RSM to provide inexpensive licenced
medium power FM spectrum for localized areas. A directional 5 watt
system will provide primary coverage of alternative programming in a
small area and will ease some of this pressure.

The writer also suggests that all the current available guardband
frequencies be permitted to use 5 watts base power. The current
suggestion that only 88.1 to 88.4 to be increased to 5 watts is not a
necessary restriction, and will cause many more problems than it solves.

Using the same power level across all LPFM frequencies will make for
easier compliance and policing.

All operators will want to use 5 watts as apposed to 0.5 watts which
will lead to massive over-crowding within this small 400khz area.

The concern that 5 watts on the other LPFM frequencies may cause
interference is unfounded. The discussion paper fails to mention the
use of 88.5 to 88.7 outside the 120km limit of the Auckland Sky Tower.
There should be no reason to prevent the rest of the country to use up
to 88.7 at 5 watts. This may have been unintentionally omitted.

There is also no reason for concern regarding the 106.7 to 107.7Mhz band
at 5 watts. NZ uses the same standard aviation band from 108 to 117 MHz
as used in most other countries, and in most of these countries, many
high-powered FM transmissions exist on 107.9 and 108Mhz. This includes
Australia, the US and the UK. There is nothing different in NZ that
would require a larger separation, particularly at the low power of 5
watts.

What appears to have been overlooked is t hat the aviation band has a
self imposed guardband from 108 to 109Mhz. No services use any
frequencies between 108 and 109Mhz. This is designed for the protection
from high-power transmissions on the FMBC band, and therefore there is
no need to provide a guardband to a guardband.

I have employed a broadcast engineer to establish if a broadcast at
108Mhz could affect aviation services. He established it was not
possible with any antenna system at 5 watts base power to cause any
interference. With directional antennas, less radiation is directed
skyward, so this is of even less concern.

The engineer established that an aviation receiver within 1km of a
several kilowatt 108Mhz broadcast would not cause any issues. The
selectability of an aviation receiver is several times higher than a
high quality FMBC receiver, and the self imposed guardband is more than
ample protection.

At 5 watts LPFM, an aviation receiver could be within just a few metres
of the transmission without any effect, so there is no reason to
restrict the upper LPFM band to 0.5 watts.

The current LPFM guardband up to 107.7 could in fact be used for
high-power broadcasting, but to be overly cautious, I recommend leaving
this space reserved for a 5 watt LPFM guardband.

I'm sure there will be the usual negative feedback from the commercial
networks in an attempt to prevent any possible indentation to their
listenership and advertising revenue. I and many others believe that
LPFM is not going to impact very much at all on the revenue of these
companies. Most LPFM operators are not operating for profit, but as a
service to the community. Many are offering alternative styles of music
that many listeners desire, but will not provide massive profits to
shareholders in Canada, for example, so is not currently available on
the radio.

In summary, I and many others believe it is the benefit to the community
that should be considered above all else. The current commercial
networks provide a very limited range of music, and little or no
community presence. LPFM operators are providing an essential service
with alternative programming, servicing localized suburban areas with
formats that are often niche and not commercial viable.

LPFM can make a real difference to what is available on the radio. The
commercial networks have taken over the airwaves to the detriment of the
New Zealand public. The Government needs to stand up to these money
hungry networks and provide New Zealand with some alternative
programming and spectrum. The 5 watt base power system will go a long
way towards that ideal, and with very little cost to all concerned.


You may use these as ideas in your own submissions if you like but
please do not
copy anything word for word. They are just draft ideas at this stage.

The Engineer I mentioned is Bay Business Equipment in Tauranga who does
radio engineering and implements STL links and broadcasting equipment.

Ross.