What constitutes a "foothill station" in RM-11749, and what is the rationale behind proposal to impose extra limitations on them?

In RM-11749, a “foothill station” refers to an LPFM (Low Power FM) station that has a very large service contour lobe in one or more directions. These stations have signal patterns that extend far beyond their primary coverage area, often into surrounding valleys or lower-lying areas. This extensive coverage can potentially create interference issues with other nearby stations, including full-power FM broadcasters and other LPFM stations.

It is proposing additional restrictions on foothill stations to address the potential interference problems caused by their extended signal patterns. By imposing restrictions on these stations, The goal is to ensure that LPFM stations can coexist with other broadcasters without causing undue interference, thereby maintaining the overall integrity of the FM broadcasting spectrum. These restrictions help strike a balance between LPFM stations’ desire to expand their service and the need to protect the quality of service for existing stations.