Well spoken, Ross!

I'm sure that any advertising revenue that is made by LPFM operators is
usually sold to organisations that wouldn't otherwise be advertising on
radio at all anyway due to the cost of advertising on large commercial
stations. LPFM stations charge out at a rate that means that not only are we
providing niche programming but we are providing a niche advertising service
in a way. Giving an opportunity for businesses who couldn't otherwise afford
to, to get their message on-air. That certainly is not going to dent anyone
elses profits, and even if it did, its going to be negligable compared to
large stations with clients spending around $4000 a month.

End of my 2c.

Dean
Groove 107.7FM
Wellington

----- Original Message -----
From: "Ross Levis" <ross@...>
To: <LPFM_Radio@...>
Sent: Thursday, November 03, 2005 3:59 PM
Subject: [LPFM] LPFM discussion paper deadline 1-Dec-2005


> 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.
>
>
>
> ---------------------------------------------------------
> LPFM Website: http://au.groups.yahoo.com/group/LPFM_Radio
> Yahoo! Groups Links
>
>
>
>
>
>
>
>
>
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