LPFM Advocacy Group (LPFM-AG)

b-turner said:

Plainly put, he doesn't get that running Amy Goodman in a mostly conservative community goes unheard by the very people he hopes would listen.
And he does not get that he is viewed as not a part of the community at large.
If he centered on community non-political subjects, avoiding the controversial material (in his community's eyes) he stands a chance at being a station embraced by the community.
He even admits selling underwriting is a challenge because of how he is perceived.

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I would endeavor to maintain a mainstream reach but without trying to compete with full power stations.
Classical and jazz are probably the two most successful non-commercial music formats where there are no full power stations of such.
Unfortunately. neither format is conducive to heavy processing, which severely limits the station's already-miniscule coverage.
Minority language formats in large metros also seem doable to me.
BTW...if you have ever heard how many of these screaming loud underwriting messages sound,
you would not be overly concerned about the proscription on commercial advertising.

Actually the guy has a really good format in place that really fits the feel of the town. He just tosses in so many programs from non-mainstream sources every couple of hours, I really think he defeats his purpose. Quite frankly, the local input from the community is minimal, I think, because of the 'stigma' attached to his station. He is in a small town without a bunch of other radio signals, so there are several 'format holes' left unfilled. I would contend classical or jazz would reach so few on his station that he'd never have the support needed. He only reaches 15,000 people. I figure if you can't get 10% of the radio listeners in your 60 dbu with the LPFM, you'll never have a self-sustaining station.

b-turner said:

I do see your point and rationale. I disagree on only one point: to not consider the stations that managed to get on the air, holding them accountable for those that did not, seems unfair.

There is no denial many LPFM formats serve tiny audiences and overall lack the knowledge of most all broadcasters. In fact, my following of LPFM's track record, approximately a third of stations that get on the air wind up turning in their license.

It would be interesting to know the percentage of CPs in general that go unbuilt. I'm talking from LPFM through class A, AM stations, TV and LPTV. It would be interesting to know how many bid for stations at auction and never build. I do not know those percentages.

I know one commercial broadcaster facing many of the challenges LPFM stations faced. He already has had two CPs expire after trying to unload them for a fraction of the cash he had invested. Primarily it is a tower issue and the costs demanded versus the potential from the sparsely populated service area and existing radio services. In each case, promises were not kept by those entities that agreed to allow him on their tower. To build his own after buying land would add too much debt considering the billing potential. The reality is a tower might be available when you apply, but the tower owner gets new customers in the meantime, locking the applicant out on the given tower by the time they're granted and ready to build. In some rural areas that tower is the only option.

I'm merely guessing, but I think it would be fair to say the average LPFM takes in under $5,000 a year. One station I know never brought in a cent. After several years a full power FM moved, knocking the LPFM off the air. There was no frequency they could move to in the immediate area. One station does $480 a year doing Christian programming about 50% of the time. An eclectic FM in a community of 15,000 manages to attract about 250 listeners and about $200 a month, enough to break even. An oldies LPFM in a small town did $20,000 their first year and about $30,000 their second. Another community-involved classic hits station had approximately 22 Underwriters at $500 a month (one of the best stations I've heard in small market radio). Naturally the last two were run by radio people who understand radio. Most LPFMs lose a little money each year primarily because they do radio the way their board wants things versus the community at large.

In fact I had a discussion with a LPFM operator about his programming. He was perplexed because the community did not embrace him. His mission was to share views not found in mainstream radio to offer a platform for people to expand their knowledge on various subjects. I told him that because much of that was political in content, he was viewed as far left by the community, not his intent. He could not see that moving away from that, in time, would bring the core of the community to him if he embraced only subjects that the community at large was affected by. He didn't get that his desire to expand knowledge had backfired. Plainly put, he doesn't get that running Amy Goodman in a mostly conservative community goes unheard by the very people he hopes would listen. And he does not get that he is viewed as not a part of the community at large. If he centered on community non-political subjects, avoiding the controversial material (in his community's eyes) he stands a chance at being a station embraced by the community. He even admits selling underwriting is a challenge because of how he is perceived.

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It is not a matter of "holding them accountable for those who did not". It is a matter of looking at LPFM as a whole and determining its overall condition and rate of success. When you are 3 years past the closing of the last window and 40% of the issued permits are not on air there are major issues. Those issues can easily be attributed to lack of experience and funding. What if the FCC had charged $2500 for a LPFM permit - or just required that a refundable $2500 bond be posted? Put aside any legalities due to the way the original LPFM rules were written - they could have been written differently, or even been changed when the first window showed pretty much the same issues as we see in the second window. There have been many discussions about how you can't build a LPFM for less than $5000, but it is glaringly obvious that many applicants didn't even have $2500 when they applied. A little skin in the deal - but far less than it takes for any commercial station AM or FM - would have thinned the herd significantly and eliminated many of multiple app situations that arose. Free permits get you hundreds of applicants who had no business even applying.

As far as how many commercial permits that were obtained at auction that were never built, the number is undoubtedly very low. Once again, those people have a significant investment and were far more likely to be experienced broadcasters who did proper due diligence before bidding. They are also far less likely to have "board issues" like many of the LPFMs experienced and are still experiencing as common sense takes the place of emotion when large sums of your own money are involved.

I know a few will claim it is hard to raise funds before going on air, and this is actually an argument that proves my point. If you need to raise funds from outside sources you are not in control of the situation from the start as you are reliant on funding that may or may not even exist. If you don't have $2500 of your own money to post on day one your chance of failure is very high. Did a few make that happen? Sure - my friend Allan McCall in Tallahassee is one example. But for every Alan, there are ten that didn't make it happen - 40% not on the air proves that clearly.

I agree there are problems with LPFM but how much of a problem is it to the FCC? It might be a problem for those that want to apply for a frequency change or move. Why punish 60% for 40% not getting on the air. I've never felt it right to be punished for what I didn't do. It would seem a filing fee would just take precious dollars away from getting the LPFM on the air, making it harder on those that follow through.

I know Alan too. Alan does it right.

I gather your feeling is it is too easy to apply for a LPFM when a window opens. As a matter of fact, it's that way with a full power non-commercial signal. I get that. I'm gathering 'lack of radio experience' is a problem. It is. But LPFM is specifically for first timers. I think we have to ask ourselves if we;d rather keep it like it is or make things more difficult. Would you have applied if there was a $2,500 filing fee? Maybe a solution is for the FCC to have an online course the applicant must pass to apply. If we can remove some ignorance would that help or is it more of an ego issue? I sort of think it is both.

Why does the commission impose filing windows?
Why have limited times in which a CP must be applied?

Filing windows are a way for the FCC to organize itself. It is not strange for a filing window only coming up every 10 to 15 years. There are so many filing as well as MX applications it can take that long to work through everything. An MX situation, for example, is where maybe 8 groups apply for the same frequency at the same spot. With LPFM, they used a point system. For example if one applicant could qualify for 4 points but the next applicant could qualify for 5 points, then the 4 point group would be dismissed. The problem is when, say 2 or more groups are equally qualified, who gets it. The FCC likes for all the groups to work that out but only when invited by the FCC to do so and under their rules. In LPFM if you can't resolve things, you share the frequency by mutually agreeing a split of the frequency (ie: one might take 5am to noon and another take noon to 7 while, perhaps a third group takes 7pm to 5am. If the groups can't work it out, the FCC will assign hours. The FCC auctions commercial frequencies to the highest bidders. Non-commercial, translators and LPFM are not auctioned.

The FCC limits CPs to 3 years and for some reason 18 months for LPFM stations. They figure if you can't build a station in that time, unless you can prove matters are unique, then you will likely never build and just prevent a frequency from being assigned to a group that will get the station going.

b-turner said:

I agree there are problems with LPFM but how much of a problem is it to the FCC? It might be a problem for those that want to apply for a frequency change or move. Why punish 60% for 40% not getting on the air. I've never felt it right to be punished for what I didn't do. It would seem a filing fee would just take precious dollars away from getting the LPFM on the air, making it harder on those that follow through.

I know Alan too. Alan does it right.

I gather your feeling is it is too easy to apply for a LPFM when a window opens. As a matter of fact, it's that way with a full power non-commercial signal. I get that. I'm gathering 'lack of radio experience' is a problem. It is. But LPFM is specifically for first timers. I think we have to ask ourselves if we;d rather keep it like it is or make things more difficult. Would you have applied if there was a $2,500 filing fee? Maybe a solution is for the FCC to have an online course the applicant must pass to apply. If we can remove some ignorance would that help or is it more of an ego issue? I sort of think it is both.

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I didn't have enough funding in place so I didn't apply. I understood how much money it would take so I felt it best to not waste time. Looking back, I probably should have taken a chance - there are about 1000 who did that and didn't make it happen, which just delayed the ones who were actually financially qualified by creating MX situations that took upwards of a year to settle. How would you feel if you lost a MX battle to someone who had no money and then never built the station? There is no doubt that happened many times - the one who could actually make it happen was left on the sideline and had to watch the permit wither and expire as the other party had no money and likely no experience.

This is not a matter of penalizing anyone - why would you give more to a group who has performed so poorly without fixing the reason for the poor performance? Any proposal to the FCC for expanded LPFM regulations would be met with significant resistance by commercial broadcasters who can just point at the absurdly high number of unbuilt permits as a reason to deny all changes. Further, would it make any sense at all to ever open another window when the performance was so poor in the first two?

It seems to me you are saying the current way is flawed and broken but not worthy of being fixed.

I worked with a group. They didn't get on. In short, they received permission to go on a city water tower. In other words they consented but with the condition all the requirements from the city, state and Ferderal regulations were met. Meetings to determine all of that were had and approved. A year later, the city council gave the okay. There was one more hurdle: a structure of some kind needed to be set outside the water tower fencing. They needed the Parks and Recreation Department approval since the water tower was in a park. They voted it down. 14 months has passed.

Negotiations on a tower a few hundred feet away was sought. Space was 'assured via letter'. A few months later when the group was ready to sign a contract at $750 a month, an amount not originally budgeted for, the group learned that during that time a new client had been placed on the tower and that the place the antenna could go would be 60 feet (18 meters) below the height assigned on the construction permit as a result. A call to the broadcast engineer determined the lower HAAT meant the station would not reach the targeted areas at that height. A search for a new tower site was had. Two other tower owners were contacted and only one had space but at a lower height than the FCC designated on the CP. A third option was to try to lease space in a pasture and erect their own tower. They contacted a 'friend' in the tower business and getting pricing, the board felt even though each would agree to take on personal debt to erect a tower, they could likely pick up a client on the tower to 'pay back' the investment.

At this point the first 18 months was almost up. The board had the engineering study done for the new location. A change was applied for and an extension to the CP for another 18 months. After getting FCC approval, the rains hit. The record rains: 30 inches in a month at some spots. It delayed any erection of a tower. The ground needed to dry up a bit. It took about 4 months.

Unfortunately that tower was never constructed. Relatives of the owner of the pasture (the very ones that would receive the land upon the current owner's death) didn't like the idea, so to 'keep the family peace', he backed out. At this point the only option was a 60 foot tower that would cover only a small portion of the original proposed coverage area. Considering the extra unexpected dollars required, it was decided reaching maybe a thousand or two people versus 20,000 was just not worth it. Maybe they could move closer to one of the two population hubs they were to originally serve.

The best option of towns put the station too close to another station. Other frequencies were not available. The engineer got paid for that work. The alternate town would work and before a formal study was done by the engineer, the board sought a tower to lease. None of the few towers in the area had space at the height the broadcast engineer stated would be required. Back now to the idea of maxing out credit cards and building a tower. They needed a willing landowner. Those parcels that had the height had huge homes on the hill overlooking the area and they sure were not open to a tower going up.

The options: build a tower over 200 feet if the land could be found to lease and deal with painting and lighting or buy land at the going rate and erect a tower own their own land to cover fewer people or opt for that original 60 foot stick serving few, or try a 50 foot stick in that town, if they could get the city to okay it. Now totally frustrated and with far more cash spent than expected, the board looked at the options and said it just didn't make sense.

The board, feeling the frequency should not go unused, knew of another group that had been wanting to reach the area. They proposed leasing tower space from that tower company with the tower nearest the water tower, where their saga began. They'd put up the money and pay all the bills until they could eventually transfer the station to that group wanting a station in that area if the group would pay their actual expenses when that time came. Unfortunately, that group felt they might not have the budget to do so and was uneasy about making a gentleman's agreement.

The group finally shopped the frequency around to other local non-profits to see if anyone had any interest. The group was intent on abiding by FCC rules, but didn't want to see their CP just expire with nothing happening. There was no interest.

Granted, that's just one station. I've talked to many and the situation is similar in many other situations. I don't know how you fix that. I would not say a lack of experience is the case. Almost the same thing happened to a commercial broadcaster I know. His CP expired unbuilt as a result after trying to price it at pennies on the dollar to recoup some of his investment. In the scenario above, the construction costs would have been so high it would have reached the low end for the construction of a full power NCE (granted a lower powered end station like say a 3kw). The group I described had $40,000 on hand. They expected $25,000 might be reasonable for getting on the air. I think they had a reasonable sum of cash.

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b-turner said:

The group finally shopped the frequency around to other local non-profits to see if anyone had any interest. The group was intent on abiding by FCC rules, but didn't want to see their CP just expire with nothing happening. There was no interest.

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That happens quite a bit actually.. LPFM CP-holders can't build their facility in time or have some other issues, broker out their time to a local church or religious network. Depending on the market size and population served by a LPFM, even some religious operations don't want to bother.

b-turner said:

Granted, that's just one station. I've talked to many and the situation is similar in many other situations. I don't know how you fix that. I would not say a lack of experience is the case. Almost the same thing happened to a commercial broadcaster I know. His CP expired unbuilt as a result after trying to price it at pennies on the dollar to recoup some of his investment.

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Anyone serious about building a Construction Permit, should have everything ready to go by the time their CP letter via E-mail, or the actual CP hits their mailbox. At a minimum, they should have the physical property and support structures secured by the time that CP arrives. Really, that could also mean equipment purchased, tower site secured, tower up and antenna on tower. There is no restriction on purchasing broadcast equipment whenever, provided you don't power things on until you receive the authority and can start testing.

The lunacy of looking for funding to purchase gear, erect a tower, or any type of building facilities after you received the CP is another recipe for failure. Eighteen months can go by in a flash. That holds true for full power (3 years-CP), or LPFM facilities.

Never said it shouldn't be fixed. I actually offered a solution to the issue. What shouldn't be done is granting more power and responsibility to a service that has performed poorly without first correcting the obvious faults. More power or worse yet height would just tighten an already crowded band even further and the real issues - experience and funding - would not be fixed. Using your trucking analogy from earlier in this thread - why give everyone in a group a license to drive a large truck when many have shown they shouldn't have a drivers license at all?

We're sure on the same page. It seems the issues are not so much technical but everything else. The groups I've spoken with have hired engineers and sometimes firms to handle all their FCC filings. That does not mean they know a thing about broadcast engineering but at least they have somebody to call and some instructions on when it's time to call. What it seems is needed is at minimum a basic knowledge of radio station operation. Sure money is a factor in many instances.

I was rummaging through the Pirate Jim LPFM directory last night. A classic example was a website that explained the station hadn't a single business as an underwriter even though they had been on the air for many months. Now they were having equipment problems. I'm simply guessing but I think I know the problem: either they think because they offer underwriting packages on the website people that own businesses will beat down their door to buy or their programming is so off-base very, very few listen. Likely they purchased equipment based on lowest price and didn't heed the advice of their engineer or other LPFM operators. Simply put, they likely have no concept of how radio works. I see that scenario a bunch. I'm not saying you have to buy the most expensive equipment but you should realize the least expensive is priced that way for a reason. There is no free lunch.

While you are centering on getting to square one, I think I'm centering more on square two. Those that get on the air too frequently do not last because they haven't a clue how radio works, not even the basics. And it happens to some that have been in radio but their experience has been confined to just one aspect such as engineering or programming. For some odd reason, those that had sales experience tend to have a clue about everything else possibly because they realize it is the product they are selling. Even then, they might know what the end result should be, just not the steps to reach that end result.

I'm sure no radio guru but I sure have been lucky my path went the way it did. I'd rather say I have been lucky enough to continue to get a paycheck from radio than to rate my level of knowledge on a scale. I was on air and in programming for about a decade, then forced to go in sales. Finally I had an owner who had been in banking and was a CPA that groomed me to manage from that perspective. Quite frankly, I knew the end result stuff, just not the path to how to achieve the end result when he started grooming me to take the management chair. When the first question is: "explain how that makes me money" you really start to think. Sure LPFM is non-profit but non-profit does not mean you don't have a path to the revenue you need to operate.

Another issue many face is overpricing the inventory. The price should be based on audience size and many LPFMs have little audience due to poor programming and/or no promotion. They then overprice the inventory but still get a few sponsors but not for long. The sponsors eventually drop off as the response doesn't match the cost, and they are then gone forever as they now know first hand it doesn't work. When you cover a small area like a LPFM does, you will eventually run out of businesses to solicit. Don't forget those businesses talk to each other so many will be told to avoid you as it isn't worth the money. Nothing you can say at that point will change their mind and you are now on a death spiral.

I run a LPFM that covers about 10000 people. I give four 20-30 second mention every day for only $60 per month or about 50 cents a spot. We have around 30 local sponsors and more than 20 of them have been on for over two years. Station is on private land and has fixed expenses of less than $250 per month. Extra money for HS football and seasonal sponsors and the station bottom lines almost $25k per year but more importantly it will keep doing that from now on.

Even without sales experience that package could be sold by anyone. The sponsors never question response as they are spending such a small amount each month no justification is needed. However if the price was doubled the whole game changes for many of them.

Bottom line - be realistic. A station covering a small population will never make much money but being realistic insures it turns a profit and that it will survive for years to come.

Some will attempt to ridicule my business plan. However my profit level is just that -a profit. How many commercial stations are losing money, especially AMs? Hundreds or even thousands, and my little LPFM is beating them all. How many LPFMs never even recover the cost of the build out, much less monthly operating expenses like electricity, royalties, and internet costs? Obviously hundreds considering the number of cancelled permis and licenses. Be realistic and you will live to see another profitable year.

It sounds like a fine plan to me. I find lots of people under-pricing. I'm talking 3 a day for $10 to $15 a month. Your pricing is wise because it offers enough exposure at a price a small business can afford and more apt to spend (I've always been told a small business can handle about $50-$75 a month). You can eventually go up a tiny bit. A guy I worked with added $1 or $2 a month for an increase. It worked well for him because it was so insignificant, everybody stayed on.

That is a good point. At $25,000 a year, you can operate and cover any emergency with ease. Best yet you can always make improvements in what you do along the way without having to go on a big financial quest. There is a level of 'safety in numbers' that applies. With about 30 clients, a potential new client hearing all the others on the station has a positive opinion of the station.

Some have insane underwriting plans. I urge people to keep it real simple. I saw one station where pricing went this way: Can't figure out what it is: Airtime is charged at 46 cents a minute for daily but 92.1 cents for weekly. Then it says: 10=$9.21, 20=$18.42, 30=$36.84. Is that number of spots, length or what? Is that per spot?

Another had pricing: under 10 seconds $10; under 20 seconds $20 and up to $60 for 51 to 60 seconds. Come to find out details, the station makes the client provide the produced spot. They refuse to write or read copy and the fee is for the spot to air during every show on the station for a full month (meaning every volunteer that does a show on the station must play the spot on their show). They have no takers. They have about 35 shows, so $10 gets you about 150 ten second units a month but it's so difficult to get on nobody buys.

Never let the customer write the spot. Easy way to air an actual commercial and violate the rules. We feel any spot over 30 seconds likely does not meet FCC rules either. All spots are written the same way - Bobs Tackle Store is located at 123 Main Street in Mayberry, right across from the high school. Bobs Tackle Store is open everyday from 6 AM until 6 PM and they carry fishing equipment and bait. They may be reached at 555-1212 and their website is Bobs Tackle Store dot com. Bobs Tackle Store - 555-1212.

All spots are lead with a separate announcement - The following programming segment is brought to you by a generous donation from the following local business. This is an attempt to identify all money paid as a donation.

This is all legal as there are no calls to action, promotion, quantifying, or price information. There is also no issue with too much detail as the message is what is on a business card which is basic identification only. They are also under 30 seconds. We run one spot every ten minutes and right back to the music so the breaks are all less than a minute including a jingle and donation announcement. This plan has worked very well.

That's right, I'd never let the client write the spot. We are going with short spots, one played at a time, averaging 8 to 10 seconds, called audio business cards. We'll mention one item (ie: support comes from X Pest Control offering once a year fire ant control. Information at XXX-555-1212; support comes from The Sand Trap, custom design name brand golf clubs and accessories, 123 Main Street, Anytown; support comes from Partytime, party and event solutions at partytime dot com). Each break is a local voice liner, spot and jingle back to music, generally under 15 seconds. Online business directory included with schedule of over the air announcements. We call it trade area marketing where you only pay to reach those that live in your immediate area...targeting the mom and pop business that can't buy a meaningful campaign on other local media options. We run promos saying information on our supporters is found at the station website in the business directory.