Before the
					Federal Communications Commission
						Washington, D.C. 20554



In the Matter of				   )
						   )
Amendments of Parts 73 and 74			   )
To Improve Low Power FM Technical		   )
Rules						   )


MB Docket 19-193
Reply Comment from WHMV-LP Mohawk, New York

WHMV-LP is located in Southern Herkimer County in Central New York State in the western Mohawk Valley.  As with many parts of the northeastern United States, we are located in an area of very hilly terrain, between the foothills of the Adirondack and Catskill mountains.  This terrain makes it difficult for our line-of-sight FM signal to travel very far at 100 watts.  To help rectify the situation, we just moved our transmission facilities to a higher location, on the side of a southern hill. This has helped our coverage a bit, but has not solved all of the reception problems we hear about from listeners, a problem all too common with too many LPFM stations nationwide.  It has allowed our listenable signal to travel from a range of about 3 miles from our transmitter in each direction to about 5 miles, east to west along the Mohawk River valley. The area north and south is blocked by large hills.  

Our broadcast area is also known as "the valley" by everyone in this part of New York State. It includes the villages of Frankfort, Ilion, Mohawk, Herkimer, East Herkimer and the only city in our entire county, Little Falls, NY - an area of about 10 miles total of municipalities lined up along the Mohawk River. Although we are technically part of the Utica-Rome metro area, people in this region consider themselves residents of "the valley" and everyday life revolves around this. Since we commenced broadcasting in 2016, people in Frankfort had complained that they could not receive the station - even though they were only 4 miles away. Our move has allowed us to bring the entire village of Frankfort into our broadcast area. Others in the hilly areas, especially south and southwest of our station have also complained about the weak or non-existent coverage.  Others also informed us that although they could receive us in their cars, they could not do so in their homes.  While the move helped, it did not solve these problems everywhere. This would all but be eliminated by allowing LPFM stations to broadcast at 250 watts as the FCC has been considering doing for several years now. 

The seat of county government is in Herkimer, N.Y. as are our county offices. The government and several service agencies located there routinely send information and announcements to be read over the air to us.  With our new location, we are being received in about 1/3 of the city of Little Falls but the signal at 100 watts is very weak as it is outside our 60 dBu signal area. They are about 8 miles away. An increase to 250 watts would allow us full coverage in the city, giving all of the residents there the ability to receive our signal and be able to hear these announcements from county government and the many agencies located there.   One side note, we are the only broadcast station in southern Herkimer County, other than the local community college station that has studios there.  All of the other 5 licensed to the valley are commercial stations and have moved their studios to Utica, NY some 15 - 20 miles away. And although they still cover the valley area in their operations, it is not their primary concern - they cover the entire Utica-Rome area at large - regional coverage, not local. LPFM represents local radio - it's our bread and butter and the signal strength of LPFM stations like WHMV-LP needs to be brought up to the level of translators to keep it a viable service for the citizens of this country. Many listeners tell us the reason they listen is because we concentrate on the local area - "the valley." LPFM equals local and it always should be. It's the one last radio service that is carrying out the true power and intent of radio - a local medium to keep the citizens informed and that local governments can rely on in times of emergency.

The FCC understands the importance of LPFM as a service to the nation. It allowed a second filing window to expand the service.  LPFM stations now need the ability to be considered real broadcast stations with regulations that are in line with all other broadcast facilities and with the ability to penetrate buildings so people can tune in the stations in their homes, businesses and government offices - not just in cars.  Otherwise, with limited listernership, the stations will find it difficult to attract enough listerners or raise enough funds to remain viable. Please allow LPFM stations that qualify to move to 250 watts as soon as possible.  Many of their survivals will depend on it.




Respectfully,

Alan W. Smith,  
President and General Manager
WHMV-LP, Mohawk, N.Y.