KBRU-LP at 92.5 FM

On December 8, 2023, Stewards of the Black Rock Desert, permittee of station call sign KBRU-LP (this call sign has since then been rewarded), 92.5 FM in Gerlach, NV, filed an application with the Federal Communications Commission for a new Non-commercial Low Power FM license. Members of the public wishing to view this application or obtain information about how to file comments and petitions on the application can visit https://enterpriseefiling.fcc.gov/dataentry/views/public/fmDraftCopy?displayType=html&appKey=25076ff38bd01f3c018bd94267eb04d3&id=25076ff38bd01f3c018bd94267eb04d3&goBack=N

Stewards of the Black Rock Desert
LPFM Educational Program Statement

Mission Statement: Stewards of the Black Rock Desert (Stewards of BRD) is a 501(c)3 nonprofit organization which provides outreach and education to encourage responsible recreation and promotes protection and enhancement of resources in the Black Rock Desert region.

Introduction:
The Stewards of BRD Low Power FM (LPFM) broadcast facility will be a powerful tool to promote responsible practices, increase appreciation of resources, and communicate vital information to visitors to the Black Rock Desert – High Rock Canyon Emigrant Trails National Conservation Area (Black Rock NCA) and surrounding region. We will produce and provide programming that educates the visiting public and local community in three major areas: historical interpretation, resource protection, and public safety. We will also provide programming to inform about current events, weather, and regional public interests. Programming will be flexible to remain relevant whether the audience consists of a low number of dispersed visitors or a large number of event participants.

Stewards of BRD was established on Earth Day 2022 to promote responsible use of the Black Rock NCA and surrounding region. Congress established the Black Rock NCA in 2000 to conserve, protect, and enhance resources associated with the California National Historic Trail and surrounding areas including 10 designated wilderness areas. Administered by the Bureau of Land Management (BLM), the Black Rock NCA contains fascinating cultural, archaeological, and paleontological traces of the past, including the longest intact segments (totaling 175 miles) of the historic Emigrant Trails to California and Oregon. The region also offers a more rugged brand of recreation activities including several organized events on the 200-square-mile Black Rock Desert playa (dry lakebed), most notably the annual Burning Man event with about 80,000 participants. In 2021, an impromptu gathering variously labeled as Plan B or the Renegade Burn attracted approximately 15,000 people. The world land speed record (760 mph) was set on the Black Rock playa by ThrustSSC team member Andy Green in 1997. The playa is also the setting for other permitted events including amateur rocketry events, Black Rock Rendezvous, Perseids Meteor Shower, and Constellation City. Thousands of people visit the area to enjoy a variety of activities including hunting, wildlife viewing, rockhounding, land sailing, dispersed camping, off-highway vehicle recreation, and more.
As dispersed camping, off-highway vehicle use, and wilderness engagement continue to increase, demands on management of the playa and surrounding region will also increase. Since the Black Rock NCA is a remote area, nearly all the visitation requires the use of motor vehicles which can have an adverse impact on the pristine, undeveloped setting. Stewards of BRD along with other partners will help to provide the information and infrastructure necessary to steer visitors and recreational users away from dangerous and destructive behaviors and towards a shared responsibility for the sustained health of public lands. Other adjacent public lands in the region may be developed for industrial and recreational uses in the future, and the public would be well-served by programming that informs about these developments as well.

Historical Interpretation:
Educating the public about the history of the Black Rock Desert, surrounding communities, the State of Nevada, 19th century Western emigration, and related topics will help visitors connect to their public lands and inculcate a sense of shared responsibility to preserve and protect natural resources. While not strictly historical, coverage of current events is included in this category. Programs covering these topics will be in a longer format, from 15 to 55 minutes, as necessary to address the details of each subject adequately and thoroughly while allowing for station breaks and public service announcements.

Pre-Modern Topics: Lake Lahontan, Paiute and Shoshone History, Black Rock geology, et al.
Emigrant Era topics: John C Fremont and Kit Carson, Applegate-Lassen Trail, Nobles Trail, Peter Lassen, Joseph Goldsborough Bruff, Soldier Meadows, Hardin City and the Comstock Lode, Louis Gerlach, Paiute War and other First Peoples interactions, Granite Creek Station, Black Rock Tom, Roop County War, Basque emigration, et al.

Modern topics: WW2 strafing range, Winning of Barbara Worth/Far From Home cinema, Helen Thrasher, Josie Pearl, Bullfrog Farm, Western Pacific and Union Pacific Railroads, Empire gypsum mining, Leadville mine, Fly Geyser, Hycroft gold and silver mining, DeWayne Williams and Guru Road, “Snowbound” Stulpa family, Paiute/Shoshone activities, World Land Speed Record, Burning Man, et al.
Current Events: Ormat geothermal development, lithium mining development, Gerlach General Improvement District/Gerlach Empire Citizen Advisory Board topics, Washoe County and Nevada topics, et al.

Resource Protection:
It will be important to make explicit the expected behaviors for visitors to the Black Rock NCA. The improper use of vehicles, irresponsible camping practices, and other inappropriate activities can have long ranging consequences for the health of delicate ecosystems and severely diminish the experience of other visitors. We will produce public service announcements, ranging from under a minute to several minutes as necessary, covering an array of topics to educate the public about these potential harms.
Subjects in this category may include: requirement to stay on designated trails, respect wilderness areas, special closures such as High Rock Canyon closure during nesting season, tips to preserve primitive experience, do not stack rocks, respect private property, Leave No Trace/Tread Lightly, respect other campers, avoid excess noise, use caution at hot springs, respect Paiute culture, leave artifacts like arrowheads in place, rules regarding rock collection limits, cryptobiotic crust and special soils in off-limits areas support wildlife and ecosystems, fires must be raised off the playa, contained, and removed completely, do not bury human waste in holes, pack it in pack it out, et al.

Public Safety:
The remote location and harsh environment of the Black Rock Desert presents many risks to visitors’ health and well-being. We will produce public service announcements, ranging from under a minute to several minutes as necessary, covering an array of topics to educate the public about these potential risks.
Subjects in this category may include: Remote locations, significant distance from emergency services, no cell phone reception to aid navigation, inform others about travel plans, avoid wet areas, ensure well-maintained vehicles, bring relevant maps, bring sufficient food and water, what to do in case of emergency, some routes require 4WD high clearance vehicles, check spare tire, jack, and lug wrench, reduce speed to diminish risk of flat tires on gravel roads and risk of flipping vehicles on playa, protection from sun and other personal protection equipment, weather updates, risk of carbon monoxide asphyxiation from heaters, generators, or vehicles, fuel safety, ham radio frequencies available, responsible use of firearms, et al.

Event-Specific Programming:
Special events provide an equally special opportunity to educate visitors about the unique character of the Black Rock NCA. In order to adequately communicate to these populations, a complementary remote broadcast facility will be necessary to ensure that programming can be received. There will also be an opportunity to produce programming specific to each special event. Stewards of BRD will be able to promote our local partners, provide information about the camps and events of partners, and communicate event-specific safety precautions and announcements to complement our basic mission.

Partnerships:
Here is a partial list of current and potential partnerships we will employ to support the project:
Bureau of Land Management, Conservation Lands Foundation, Burning Man, Gerlach High School, Everywhen, Friends of Black Rock High Rock, OHV groups, AeroPac, Nevada Historical Society, Desert Research Institute, Oregon-California Trails Association/Trails West, National Trail Service, KUNR-FM at University of Nevada – Reno, other LPFM stations, Union Pacific, Empire Mining, et al.

REQUEST FOR EXEMPTION TO ALLOW TEMPORARY TRANSMISSIONS FROM A SECOND LOCATION

As discussed in the Educational Program Statement, the population (and resulting audience) in the Gerlach area varies dramatically during the year, principally due to events permitted by the BLM. We request an exemption authorizing transmissions from a second temporary LPFM broadcast facility up to 30 days in each calendar year, at a power level between 20-50 watts, at an antenna height of 25-35 feet, limited to locations and time periods authorized under an applicable Special Recreation Permit (SRP) issued by the BLM. The programming content of the permanent and temporary stations would be simulcast via available wireless internet technology.

Currently there are three events regularly authorized by SRPs—Burning Man, Everywhen, and amateur rocketry launches. Those SRPs specify both a time period and location boundary for the events. Activities outside those time periods and boundaries are limited to informal “dispersed camping.” Most importantly, BLM’s dispersed camping rules preclude the construction of structures such as towers. For that reason, the primary station location proposed by this application is on non-Federal lands in the community of Gerlach, rather than in the event areas with large temporary visitor populations.

The location proposed for the regular broadcast facility in Gerlach is 40.65 N, 119.358 W. The location of each of the three SRPs can vary from year to year, but usually not by more than 300 to 500 feet. The center point for the Burning Man event in 2023 was at approximately 40.786 N, 119.204 W, which is approximately 12.4 miles from the proposed primary LPFM broadcast facility antenna location. The center point of the Everywhen event in 2023 was approximately 40.819 N, 119.193 W, which is approximately 14.5 miles from the primary location. With a 50-foot tower, which is the highest feasible at the proposed location given surrounding uses, line of sight propagation is limited to around 8 to 10 miles, and the expected range of a 100 watt transmitter is even less. As a result, in order to reach these large temporary populations, a temporary second station would be needed.

The Burning Man event is open to all ticket-holders during a 9-day period beginning the second Sunday before Labor Day and ending on Labor Day. Staff and ticket holders with special passes can arrive earlier and leave later in order to build and tear down the event structures. The Everywhen event also spans a similar period surrounding Independence Day, although the precise dates still vary since the event has only been permitted for the past two years (BLM is currently in the process of issuing a three-year permit for that event). The amateur rocketry launches occur at varying times but are similarly limited to specific dates in their SRP. Construction of a temporary transmission tower would be limited to the time periods and locations specified in these SRPs, which in turn limits the practicability of a tall tower. Since there is no utility power at these locations, the temporary LPFM facility would need to be powered by solar panels, batteries, and/or a generator, which in turn limits the practicability of higher transmission powers.

Given the limited boundaries of the SRPs, which confine the event population, a temporary station within the parameters mentioned would fully cover the necessary area. Because event participants and other visitors generally transit the community of Gerlach on the way to and from these events, and to maintain local broadcast expectations, we request that this exemption authorize a second temporary transmitter, rather than a change in transmitter location that would involve turning off the primary transmitter in Gerlach during that period. It should be noted that the temporary broadcast facility locations are even further away from other licensed stations than the proposed principal location, so no potential interference concerns are presented by the exemption request.

Most recreational use of the playa is accessed via Nevada State Route 34 at two entrances 8 and 12 miles distant from Gerlach. There is a closer entrance at three miles, but that portion of the playa is often too wet to be passable. There are entrances further away, but those entrances require a high clearance vehicle and are not suitable for passenger cars and RVs. As a result, the significant recreational use is almost all in a band between 8 and 16 miles from Gerlach. Accordingly, the remote temporary transmitter antenna will never be further than 20 miles away from the primary location in Gerlach and will therefore always be “local” as defined in the LPFM regulations. When the two transmitters simulcast, there may be a zone of uncertainty where FM capture will not be reliable, but this would be limited to a few miles on Highway 34 and portions of the playa that are not significantly populated. The on-playa satellite transmitter will be fed by a computer or laptop connected via StarLink to a computer or laptop at the base station in Gerlach hooked to the output side of the emergency alert system (EAS), most likely via a daily Zoom session (Zoom sessions can now be up to 30 hours long at studio quality). Therefore, both transmitters will be connected to the EAS.