Let's review this point-by-point, now that I've come off that "expanding the FM band" high.
I will keep that in mind. Since the FCC requests comment, how do I respectfully reach them?
From what I have seen, the new tests have been highly successful. Several stations, including WTBS, KXDP, WRME, and KBKF (all LD) have noted that their NextGen signal does not interfere with the 87.7 frequency, and vice versa. In addition, the signals achieve the same distance (which is to be expected, because of the HEVC codec in ATSC3 that wasn't available in ATSC1.
So, most of today's Franken FM's such as KXDP and WNYZ, serve a Spanish-speaking audience, so I think it is in the interest of minority groups to continue these operations to run. It is expensive to afford a radio-station, get the licensing out and everything, and these Channel 6 FM's have afforded these minorities an opportunity to broadcast their culture. This is what LPFM's were supposed to solve, but IMO the LPFM's have become a landing spot for churches, which half the time doesn't provide things a "community" would expect from a "community" station, such as a calendar, locally inspired music/talk, and lost/found support services. That is not to say that all religious LPFM's are bad, because some, like KWYG-LP in Wyoming, do a very good job of adding that local element while carrying what is truly a regional if not national format. It should be in the public interest to provide a small section of the band dedicated to helping local interests and Ethnicities get on radio, who might otherwise not have a voice, or resort to piracy. Not all pirates are jerks, they just can't afford to broadcast anywhere else. Hopefully, the FCC will consider small groups when deciding either to keep Franken FM's, or expand the FM band. Without such groups, actually, the Franken FM's are otherwise a repeat of what you can find elsewhere on the band. It might also be in the public interest to give LPFM's their own chunk of the band, in a similar fashion to Franken FM's, but without the hassle of being on Channel 6.
One thing in favor of Franken FM's is that you get a TV signal and an FM signal packed into one, which may serve doubly. When one tunes into WRME-LD (at least before they switched to Jewelry TV), there was a constantly updating weather map. Useful! On WDCN-LP, local ads ran on the screen. Useful! However, not all Franken-FM's do this. There was one in Florida that just put a blank screen on channel 6. Not useful! The one in Georgia, WTBS-LP, stopped broadcasting the audio-carrier altogether, I kid you not. However the advent of the ATSC 3.0 signal has uniquely given these stations to broadcast as many video streams as they wish, while having the 87.7 audio broadcasting something else. There is mixed implications here, and as I mentioned earlier, WRME-LD Chicago now runs Jewelry TV on virtual channel 33, while still having "Me-TV audio" on 87.7.
As I have mentioned before, the current tests have ran very well. Because FM6's are practically FM from the perspective of a reugular listener, they should be held to similar standards regarding Legal ID's, advertisements, and what not, however we do need to give them financial leniency, otherwise it's just another part of the FM band, and these LP's probably will go away if that were to happen, with maybe one of them finding a forever home after going off channel 6.
Talk about maintaining the status quo here, are possibly putting those FM6's on life-support here.
This option excites me, because the FM band is getting overcrowded as it is, and we eventually need to welcome AM move in's. Being forced on to translators is rather unfair to AM's used to covering several markets at once, and if we are going to make the move to FM permanent, we have to do it right the first time. Also, I counted, and NPR's statement is correct. You will receive 30 new FM channels, assuming that they get rid of Channel 6. Of those 30, I would say the first 5 (82.1-82.9) goes to a new breed of LPFM's that are up to 150 watts, and they have reduced qualifications for application, which would help the FrankenFM's and other LPFM's find a permanent home. The next 23 channels (83.1-87.5) would be home to Non-Commercial applications, which would shift the current NCEFM band (88.1-91.9) over to, the aforementioned 83.1-87.5 area, and there would be three extra channels in this new bandplan. The Next 22 channels (87.7 through 91.9) would be home to AM move in's, prioritizing first-service, at perhaps a Class A or Class C2 level, as to help reduce interference on the new band, but allowing entire metros to be within the 50-60+ dbu coverage. This should mainly prioritize the large cities first. Rural AM's should be allowed to move onto the regular FM band at full power, if spacing allows for it. Stations like KOA, KLZ, KHOW, and KDFD should go to the designated 88 Mhz band, whilst stations like KFBC should be allowed to expand their power on their current frequency if they wish.
Continued in Part 2...