Betsy Cortis

COMMENTS IN SUPPORT OF LP-250

	I am the co-chair on the Board of directors for Valley Free Radio LLC, the license holder of WXOJ-LP in Northampton, Massachusetts. I urge the commission to consider the LP-250 proposal brought forth in MB Docket No. 19-193. As both height and wattage affect signal contour, but wattage alone affects signal permanence through objects and buildings, an increase in the wattage of WXOJ-LP would help us better serve the public in our listening area. 
	Currently, the downtown of the city we are licensed in has many tall buildings made of brick and concrete. As Cities develop, taller buildings and particularly new parking structures, which are made with thick walls and beams to support load, block or interfere with low power signal to all but the uppermost floors of a building. This includes the many listeners who tune in while commuting on the streets and sidewalks of the city.
	Since the radio spectrum is owned and regulated primarily by the federal government, and the government is in place to serve the people, I would argue by transitive property, the radio spectrum is a public commodity first and a potential business last. Signal concerns of NCE stations should be a priority concern for the FCC. Educating the local community in both free media production training though use of our system and noncommercial educational content aired to Northampton, MA has a larger benefit to our society than using airtime to inform the public where they should spend their money to best benefit and ensure continuation of each commercial radio station.
	While some full power commercial station will boast the ability to raise large amounts of money for charitable causes, the only reason an LPFM cannot raise money on that scale is because their signal is not on that scale. LPFMs, by nature, educate their communities about non-profit charitable causes and organizations frequently. Improving signal quality by updating to LP-250, would also help the public organize volunteers and donations for 501(c)(3) organizations.
	At WXOJ-LP, we strive to educate our hosts on having the best sound quality for our listening area. This includes free training on how to set and read levels for microphones, music sources, sound clips, instrumental beds, etc. We hire professionals to regularly tune our equipment and ensure our signal is the best it can be. The bottleneck in our quality goals then lies with interference directly related to the power of our signal being too low for this hill-filled region. As each proposal for an LPFM to move to 250 would be handled individually, the worries of interference are managed on a case by case basis, and should not be a factor in changing this limit at the policy level.