REC has proposed that the minimum power allowed for an LP-250 station is 101 watts ERP. If an LPFM that has a HAAT above 30 meters (and is not able to get a full 100 watts) is only short-spaced to an intermediate frequency channel (+/- 53 or 54 channels, 10.6 or 10.8 MHz) but meets all other distance separation requirements, the "upgrade" should be allowed however, the station would be limited to no more than 100 watts ERP.
For example: If an LPFM station is at 37 meters HAAT and they are currently authorized 66 watts ERP, they are only short-spaced by an IF channel. Normally, an LP-250 at that HAAT would be authorized 172 watts (7.1 km service contour), however because of the IF restriction, they would be limited to 100 watts ERP (6.2 kilometer service contour).
Another example: If an LPFM station is at 62 meters HAAT and they are currently authorized 22 watts ERP (5.6 kilometer service contour), as an LP-250 station, they would normally be 60 watts (7.1 km service contour), because that ERP is less than 101 watts, the full upgrade (at 60 watts ERP) would be allowed.
Therefore, if the HAAT of the LPFM station is 49 meters or higher, then the IF spacing requirement can be completely disregarded because the upgraded LP-250 ERP would be 100 watts or less.
REC proposed to add the IF spacing requirement for all stations at 101 wats ERP or greater to maintain a level of consistency between LPFM, FM Translators and lower powered Class A full-service stations.
