Summary of Testimony of Dr. Theodore S. Rappaport, P. E., before the Subcommittee on Telecommunications, Trade, and Consumer Protection, House of Representatives, United States Congress, February 17, 2000

 I performed extensive engineering analysis on behalf of a coalition of churches, non-profit foundations, and other public-interest groups, led by the United Church of Christ and their lawyers at Media Access Project.

To determine the technical feasibility of low power radio, my staff and I did two things. First, we performed extensive analysis and computer simulation using the FCC's own interference protection rules and licensing procedures for existing FM radio stations. This analysis allowed us to determine how the addition of LPFM stations would impact existing FM stations, as well as emerging digital radio services. Second, we conducted a rigorous review of some of the technical data and public comments that had already been submitted to the FCC in response to the NPRM for LPFM.

Our analysis shows that between 64 and 680 times as many citizens will be able to receive LPFM programming over small distances (i.e. within neighborhoods) as compared with those who may rarely experience some level of interference or degraded service. Our analysis, based on FCC FM license guidelines, shows that in the absolute worst case, only 1.6% of the listeners within LPFM listening range might experience some sort of interference or degradation of service, and that the vast majority of those affected listeners actually will not experience any interference, whatsoever. The few who do experience some type of interference will likely be able to improve reception by simply repositioning or readjusting their FM receiver by a few feet.

After reviewing the technical studies submitted by the opponents of LPFM, I concluded that most of them would not meet the objective standards necessary for peer review or publication acceptance in the engineering community. For example, the NAB adopted unrealistic performance standards for radio receivers. More than half of the FM receivers tested by the NAB could not even meet the NAB's performance standards in a perfect, interference-free environment in the test laboratory. To "prove" that LPFM would harm current broadcasts, the NAB needed to "prove" that most radios do not work today. This clearly defies common sense. In addition, I explain by analogy how the overly cautious FCC FM licensing rules leave ample room for new low power radio stations.

As an engineering professional who makes a living by studying and creating new technologies in the wireless communications field, I am confident that the FCC's low power FM system, as recently adopted, will have no detrimental impact on existing and future FM radio stations or their listeners, and will benefit millions of Americans who desire to communicate within their own neighborhoods and communities.

The full version of this testimony and summary are available for download in pdf format (34KB) here.

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