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Before the

FEDERAL COMMUNICATIONS COMMISSION


Washington, D.C. 20554

In the Matter of

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
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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,
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to continue to express its
support of the SSR Communications, Inc. proposal to create a new FM C4 category of
stations.
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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.
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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).
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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
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submitted a recommendation to create a class of medium power FM stations,
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a proposition
supported by the Diversity and Competition Supporters in the 2010 Quadrennial Review
proceeding.
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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.
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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.
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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).
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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

August 15, 2014

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