It is REC's ultimate desire that LPFM be a service where the only difference between a NCE translator and an LPFM is that it can originate programming, remain non-commercial and be subject to the LPFM localism and ownership rules. There is no technical reason why LPFM stations can not use contour overlap.
What does come into question though is the hyperlocal nature of the LPFM service. In 2012, the NAB did question whether LP-250 would be able to maintain the hyperlocal nature of LP-100. Many of these questions were raised because LP-250 was being promoted as a rural expansion service. REC's strategy is to promote LP-250 as enhancing the quality of service within the three-mile-zone while providing some additional fringe coverage. We had looked at extending the service contour west of the Mississippi (except for California) out to 13.3 km similar to the translator rules and ruled that out as that would seriously jeopardize the local nature of LPFM also taking into consideration that many NCE class A stations operate with service contours around 13.3 km.
The main reason why full contour overlap rules were not introduced was because of Section 3(a) of the Local Community Radio Act that prohibits any LPFM from being spaced closer than the values shown in §73.807(a) in respect to full-service FM stations.
To allow Contour Overlap between LPFM and regular domestic FM stations, it will require an act of Congress to amend the LCRA. This can not be done through FCC rulemaking.