Amendment of Section 73.207, 73.210, 73.211, 73.215, and 73.3573 of the Commissions Rules related to the Minimum Distance Separation Between Stations, Station Classes, Power and Antenna Height Requirements, Contour Protection for Short Space FM Assignments, and Processing FM Broadcast Station Applications ) ) ) ) ) ) ) ) )
RM-11727
To The Commission:
COMMENTS OF THE MINORITY MEDIA AND TELECOMMUNICATIONS COUNCIL
The Minority Media and Telecommunications Council (MMTC) submits these comments in response to the Public Notice released July 18, 2014, 1 to continue to express its support of the SSR Communications, Inc. proposal to create a new FM C4 category of stations. 2
MMTC urges the Commission to continue to improve its broadcast rules to increase spectrum efficiency, quality of service, and competition. MMTC has long advocated for greater participation by small and minority-and-women owned business enterprises (MWBEs) throughout the regulated industries. 3 The Commissions Advisory Committee on Diversity
1 See Consumer & Governmental Affairs Bureau Reference Information Center Petition for Rulemaking Filed, Public Notice (July 18, 2014) (Public Notice). 2 See Letter from David Honig, President, MMTC to Hon. Julius Genachowski, Chairman, FCC re SSR Communication Inc.s Petition for Rulemaking No PRM13MB (Feb. 19, 2013). 3 MMTCs mission is dedicated to promoting and preserving equal opportunity and civil rights in the mass media, telecommunications, and broadband industries. MMTC is the leading 2
submitted a recommendation to create a class of medium power FM stations, 4 a proposition supported by the Diversity and Competition Supporters in the 2010 Quadrennial Review proceeding. 5 In its petition, SSR advances its goals as a logical extension of this Diversity Committees recommendation to increase spectrum efficiency and benefit Class A stations, including those owned by minority broadcasters. 6 Increasing opportunities for these stations to expand their coverage areas to connect with a broader audience could help small and minority- owned stations gain access to capital and strengthen their foothold in the broadcasting arena. In alignment with our mission to preserve and expand minority ownership, MMTC continues to urge the Commission to adopt this proposal to improve spectrum efficiency while providing greater opportunities for small and minority entrepreneurs in broadcasting.
advocate for minority participation in the communications industries. We seek to preserve and expand minority ownership and equal employment opportunity in these industries and to close the digital divide. 4 Recommendation on Diversifying Ownership in the Commercial FM Radio Band, Emerging Technologies Subcommittee, Advisory Committee on Diversity for Communications in the Digital Age (Oct. 4, 2004), available at http://transition.fcc.gov/DiversityFAC/adopted- recommendations/AdoptedFMRadioRules.pdf (last visited Aug. 13, 2014). 5 Supplemental Comments of the Diversity and Competition Supporters in Response to The Notice of Proposed Rulemaking, 2010 Quadrennial Regulatory Review - Review Commissions Broadcast Ownership Rules and Other Rules Adopted Pursuant to Section 202 of the Telecommunications Act of 1996, MB Docket No. 09-182 et. al. (April 3, 2012) at p. 44, available at http://mmtconline.org/wp-content/uploads/2012/04/Supplemental-Media- Ownership-Comments-040312.pdf (last visited Aug. 13, 2014). 6 See SSR Communications Inc., Petition for Rulemaking (Jan. 29, 2013) at p. 3, available at http://apps.fcc.gov/ecfs/comment/view?id=6017160905 (last visited Aug. 13, 2014). 3
Respectfully Submitted,
David Honig, Esq. President Jacqueline Clary, Esq. Senior Counsel Minority Media and Telecommunications Council 3636 16th Street NW, Suite B-366 Washington, D.C. 20010 (202) 332-0500 dhonig@mmtconline.org