Whether the 'best reading' of the Low Power Protection Act mandates nationwide Low Power Protection denial despite potential standing and statutory interpretation issues

No question identified. : QUESTION PR ESENTED Whether the “best reading” of the Low Power Protecti on Act (“LPPA”) mandates nationwide Low Power Protection denial, as i f the LPPA had not been enacted, where: 1. The lower court assumed that a trade association had standing and redressed its speculative third-party injury claim, FCC 23-112 ¶ 38, Pet. App. 77a-78a, asserted on behal f of unknown Full Power broadcasters the LPPA seeks to constrain, even though that injury claim is plainly barred by Article III associ ational standi ng rules; 2. The lower court ignored this Court’s unani mousl y rendered interpretive rule that statutory definitions are “virtual ly concl usive,” altered statutory definitions to nullify the LPPA’s and 47 U.S.C. § 307(b)’s nationwi de protection and licensing mandates, and produced an LPPA readi ng with no substanti al effect upon interstate commerce; and 3. The lower court rejected First Amendment and mustcarry issues based upon RCC’s purported LPPA ineligibility, but inexplicably and inconsi stentl y used the LPPAineligible trade association’s speculative third-party injury claim to di squal ify RCC from LPPA protecti on. (I) PAR TIES TO THE PR OCEEDINGS BELOW All parties are disclosed in the case caption above. RULE 29.6 DISCLOSUR E STATEMENT Petitioner, Radio Communi cations Corporati on, is a nonpubl ic, closely held company with no publicly owned subsidiaries or owners, and is organized and located in Connecticut. RCC’s sole owner is a citizen of the United States resi ding in Connecti cut. RELATED CASES The D.C. Circuit’s Opinion is reported at 141 F.4th 243 (CADC 2025). Pet. App. 1a. (II)