1. LPFM must allow for "commercial" (commercially supported) as well as "non-commercial" stations.

2. Both the 2nd and 3rd adjacent channel restrictions must be dropped for LPFM stations.

3. LPFM must not be subjected to a narrower bandwith than full-power FM stations since audio quality could suffer. We do support dropping sub-carriers other than stereo however to prevent interference.

4. The 60 meter (197 feet) limitation on Class LP-1000 stations in the FCC NPRM should be increased to 100 meters (328 feet), which is the same as for Class-A full-power FM stations. This would provide for an additional 2-3/4 miles of coverage without requiring any additional power. Distance to 60 dBu contour would increase from 8.8 miles to 11.76 miles, which could help LPFM stations reach significantly more people and thus enhance their opportunity to survive.

5. Mileage separation tables must be provided for other powers in addition to the 1,000 watt and 100 watt stations. For example, have a table for each 100 watts down from 1,000 (900,800,700 ect.) so that if a channel won't hold 1,000 watts, it may be able to hold 700 watts or 600 watts, etc.

6. Some form of ownership restrictions must be in place to keep this service for "local owners" so as to not be snapped up by the large corporate broadcasters. The "50-mile rule", proposed in RM-9242, that requires an owner to live within 50-miles of his/her proposed antenna site would work nicely and would be easy to enforce by requiring applicants to list the coordinates (latitude & longitude) of their residence as well as their antenna site on the LPFM application along with a certification that they meet this requirement.

7. The FCC should try some form of "first-come first-served" application process with five-day filing windows. If this system proves unworkable, then and only then should the FCC consider using auctions to select between mutually exclusive (MX) applicants. If auctions are considered, there must be some form of "bidding credits" available to small business applicants that would allow them to compete with applicants with larger financial resources at there disposal. This is imperative since we are trying to lower the barrier to entry for new applicants of lesser financial status.

Discussion of comment points above:
We are very concerned about the possibility of the FCC creating a non-commercial only service. This would be a travesty and a great blow to the public interest, if this were to happen. We must flood the FCC with comments and reply-comments supporting commercially supported LPFM stations, in the strongest possible means. Radio stations have used commercials to support themselves for over 75 years and there is no reason at all to preclude LPFM stations from supporting themselves with commercials. In addition to being a fine mechanism for a LPFM station to receive financial support, it also provides a great benefit to the small local mom and pop businesses who heretofore could not afford to use radio advertising. We must be able to sell commercials to support our LPFM stations. It's a matter of their economic survival. This is a critical issue and must be addressed with massive comments to the FCC in favor of commercially-supported stations.