It is becoming apparent that more and more commercial operators are
"double dipping" and utilising guardband frequencies in addition to
their licenced frequencies - often to get their program into regions
where no commercial frequencies are available.
This is TOTALLY unacceptable.
Guardband frequencies were not designed for this - nor is it ethical
for an operator who is already on the air to take over a frequency
that should be available for LPFM operators and those who are unable
to purchase a commercial frequency.
This is not an issue that requires policing as such - it simply
requires a policy change (addition of ONE clause in the regulations)
for it to be effective. If it was then found that a commercial
operator was using a guardband frequency it would be a simple matter
of a phonecall by RSM to the offending operator advising them to cease
the use of the frequency.

Given the fact that commercial operators (read "paying clients") are
pandered to by RSM because of the almighty dollar, it seems in some
respects that they have tacit approval to use these frequencies. This
has to stop.

I urge all LPFM operators to lobby the RSM to stop the use of
guardband frequencies by any operator who currently uses a commercial,
high-power or community frequency.