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Request for Silent STA

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Actually niche might be an adjective for serving the community in their 60 dbu. That does not mean they have to be very mainstream but that sure helps. In a city it might mean a segment of the population not currently served by radio. As for 'professional', I feel the FCC has an expectation of professionalism in operating properly utilizing professional standards but not necessarily 'polished' as major market station might sound. From my interpretation of not being professional I would extend that to every not for profit station in the context it was presented. I don't consider NPR non-professional, for example. I contend, you might not be earning a living doing radio but that is no excuse to to strive for a professional sound.

I contend the FCC does intend LPFMs to generate income. There are operational expenses and obligations not unlike any other broadcast facility. Granted, the investment in a 100,000 watt FM is not that of a 100 watt LPFM, the fixed expenses are for the most part the same. For example, renting a studio is not less expensive for a 100 watt FM versus a 3,000 watt FM. Certainly the same as that 100 watt NCE FM versus that 100 watt LPFM.

I see no issue if a radio professional chooses to form a non-profit to gain a LPFM to serve it's community. I suspect the FCC does not choose to discriminate either. Certainly they'd be doing so not for the money but rather the satisfaction of serving their tiny coverage area. Certainly professionalism is an option and any organization seeking to operate an LPFM should strive for it if for no other reason to offer a quality of programming listeners will choose to listen to versus not choosing. I say that because I have heard plenty of really bad radio, unfocused hosts, long periods of silence and such that made me switch the dial. I have also heard grassroots radio programming that was well executed and informative and/or entertaining.

The FCC does not have any expectations for programming. As long as there is a Legal ID, working EAS system, and the station conforms to community standards (profanity for example) you can play the bongo drums 24 hours a day if you want to. There is a difference between generating funds for operating expenses vs revenue. LPFMs for the most part are 501c3 for that reason. The board members can choose to allocate funds for salaries or other issues. Most of the successful LPFM's I have encountered have been a niche format and are successful because they can reach that base for donations.
 
This is probably the part of building an LPFM that trips most would-be operators up. Pretty much all LPFMs are built on a shoestring budget and I'd bet pretty much all of them have one or fewer "knowledgeable radio people" available for consultation. That leads to people acquiring inadequate, non-type accepted transmitters or exciters, or getting donated equipment like an EAS box that is not compatible with current standards. Or worse, putting a station on air that's at serious variance with the licensed parameters.

If you're not a person with experience in the technical side of broadcasting, and you have one person who says "this is the proper equipment and it costs $X thousand to do it right at a bare minimum" and you have another person who is saying "if you look hard you can source this, this and this for next to nothing", someone who doesn't know better is going to go for the "next to nothing" advice even if it's going to get you the wrong equipment.

It's understandable to some degree that someone could get snookered by bad advice while looking to save a buck. What's less understandable to me is why people who are considered "knowledgeable radio people" would be giving the bad advice in the first place. I mean, I am FAR from an expert on FCC rules and regulations, but even I have had a passing knowledge of CAP-enabled EAS equipment. (What I didn't know until today, to be fair, was that CAP messages come over the internet, which means your transmitter location needs to have reliable internet access!) Because "I don't know what I don't know" I would never consider myself to be a viable source of knowledge on building an LPFM.

Experience is the key. You can build a very modest station and still be able to keep up with the Jones. Note: Your transmitter and Exciter has to be FCC TYPE accepted.

You also need to know where to shop for equipment. I have only worked at one FM station in 30 years that has had all new equipment. The owner insisted. He was happy because I came in under 20k of his budget (this was back in 1991). He was told he needed a dozen cart machines, a 12k processor, 18 channel board etc. NOT!

Many of the stations I worked for are still using that "old" equipment with no issues. It is what you buy, and a engineering background helps.

The reality: most small market stations don't have the funds to buy new, or top of the line equipment.

I just helped someone build a EAS system: An TFT EAS 911 system (new old stock and a later model with updated software), with a 943 interrupt, and G/R CAP system. for around $800. It is compliant, and it works just fine. I actually like it better than my EAS systems.
 
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This is probably the part of building an LPFM that trips most would-be operators up. Pretty much all LPFMs are built on a shoestring budget and I'd bet pretty much all of them have one or fewer "knowledgeable radio people" available for consultation. That leads to people acquiring inadequate, non-type accepted transmitters or exciters, or getting donated equipment like an EAS box that is not compatible with current standards. Or worse, putting a station on air that's at serious variance with the licensed parameters.

If you're not a person with experience in the technical side of broadcasting, and you have one person who says "this is the proper equipment and it costs $X thousand to do it right at a bare minimum" and you have another person who is saying "if you look hard you can source this, this and this for next to nothing", someone who doesn't know better is going to go for the "next to nothing" advice even if it's going to get you the wrong equipment.

It's understandable to some degree that someone could get snookered by bad advice while looking to save a buck. What's less understandable to me is why people who are considered "knowledgeable radio people" would be giving the bad advice in the first place. I mean, I am FAR from an expert on FCC rules and regulations, but even I have had a passing knowledge of CAP-enabled EAS equipment. (What I didn't know until today, to be fair, was that CAP messages come over the internet, which means your transmitter location needs to have reliable internet access!) Because "I don't know what I don't know" I would never consider myself to be a viable source of knowledge on building an LPFM.

YOU ARE SO RIGHT! You would probably also be amazed at how much of that "bad advice" comes from these very message boards. (If I were an inspector for the FCC, I'd lurk on here looking for people giving out that bad advice and then visit them. Why? If they're so quick to hand out advice on how to "almost squeak by", I'd be willing to bet that's just what they're doing, too!) I keep getting these emails (every time there's an LPFM filing window that begin with "You CAN build your own completely legal FM radio station for under $5,000.00!!!" With a legal (type certified) transmitter costing $3k or more, a legal (CAP enabled) EAS system costing more than $2k (including receivers and other accessories), there's $5k and we haven't even mentioned an antenna, a tower, transmission line or even the beginnings of a studio! Yes, you can "cheap-out" on it by following bad online advice from others who did the same and were lucky enough to not get caught (yet) but, that's living very dangerously! Some people seem to love doing that and, when it catches up with them, they want to point the finger and scream, "It's my engineer's fault!" I've seen this again and again and again. It never works. The FCC always holds that it is the ultimate responsibility of the license and, if that licensee is too ignorant to realize they are noncompliant, that is an unfit licensee. (I wonder how many reading this are now seriously wondering how much longer they can avoid updating some seriously outdated equipment just about now.)
 
Note: Your transmitter and Exciter has to be FCC TYPE accepted.

With LPFM, it is "TYPE CERTIFIED" which is a whole different animal. You have no idea how many times I have to set people straight on this, too. They get advice (and donated equipment) from other broadcasters and the troubles begin. The "homebrew" excited that is perfectly legal on your 100kw class-C with the 2,000 foot antenna and 62 miles of city-grade coverage is NOT legal for a 100 watt LPFM with a 100 foot antenna and 32.5kw miles of city-grade coverage. This is a hard fact.
 
I just helped someone build a EAS system: An TFT EAS 911 system (new old stock and a later model with updated software), with a 943 interrupt, and G/R CAP system. for around $800. It is compliant, and it works just fine. I actually like it better than my EAS systems.

How will this owner feel when that CAP adapter is outlawed? You are aware that the original plan (back in 2012) was to only allow "converters" for two years and it was later extended because of too many licensees whining about having to upgrade? Eventually, the luck will play out and all of those people who just wasted between $1k and $2k on outdated systems with "converters" will be very angry for having to purchase new so soon after buying old. On the other hand, art least the new systems will come with a guarantee of not being outdated for a number of years and will even have a warranty!
 
How will this owner feel when that CAP adapter is outlawed? You are aware that the original plan (back in 2012) was to only allow "converters" for two years and it was later extended because of too many licensees whining about having to upgrade? Eventually, the luck will play out and all of those people who just wasted between $1k and $2k on outdated systems with "converters" will be very angry for having to purchase new so soon after buying old. On the other hand, art least the new systems will come with a guarantee of not being outdated for a number of years and will even have a warranty!

The G/R CAP system will not disappear anytime soon. In fact, G/R can be modified with a simple software update. Worst case situation: I will install a EAS-1 for them (I have several) with a firmware update... back in business.

and yes I was one to whine about the upgrade. I don't see any changes anytime soon. It would still have to be voted on. Go to public comment, and then a report and order. Plus the transition period/ Estimated time: 3 to 5 years. By that time internet will overtake FM radio :)
 
Estimated time: 3 to 5 years. By that time internet will overtake FM radio :)

That last line reminds me of filling in at a local station during April of 2011 right after the tornado outbreak. I was desperately trying to get information on food and water drops for people with no homes to go home to. I finally managed to get a FEMA representative on the phone and explained that I worked with the local radio station and was gathering information to broadcast to the local people. (One of the nearby towns, less than five miles away was leveled. Not just hones or a few businesses. The entire town was literally leveled.) The FEMA representative kept insisting that I needed to "just tell them to go to this website for assistance". I finally gave up. She couldn't seem to grasp that, after several days with no power, no gas, no food or water and very little of anything else, these were people with very few items of clothing and going to websites was one of the last things on their minds. I'm all as excited as you are about internet radio and the digital age but,i seriously doubt it will be a real player in the aftermath of a hurricane.ca major earthquake or anything else that takes out a major portion of the communications grid. Give me an old-fashioned tower, an analog transmitter and a generator! Internet is wonderful when it works but, when major (and sometimes minor) disasters occur, what is usually the first thing to go away? I'll even add this. I'm posting this via an iPad connected through a cell system. Why? I am at a radio studio. Still, the AT&T DSL connection went down about an hour ago and the cable system went down at about the same time. This was because of a rain band from a minor tropical storm. Now, imagine what we would have with internet service had this been a category 4 or 5 hurricane. I'm seeing hanging thousands of lives on that. Better yet, how would this sound on your local (internet dependent) station: "The staff and management of this station recommend that you turn to Noaa Weather Radio during this time of emergency. Noaa Weather Radio is comprised of a nationwide series of hardened transmitter sites similar to those that were once common at each and every radio station. However, with modernization, broadcasters have opted to 'cheap-out' and this makes our facilities so unreliable that our legal department advises us to broadcast this announcement advising you to turn elsewhere for urgent need and information."
 
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Noaa Weather Radio is comprised of a nationwide series of hardened transmitter sites similar to those that were once common at each and every radio station. However, with modernization, broadcasters have opted to 'cheap-out' and this makes our facilities so unreliable that our legal department advises us to broadcast this announcement advising you to turn elsewhere for urgent need and information."

First, even in major markets most stations were not "hardened" to the degree you envision.

Example: Smaller "major market" (Tallahassee, FL) only one station, WTNT, hardened in the pre-consolidation decade (1986-1995), and that was courtesy of Federal funding of an underground studio and a generator in a bunker.

Example: Top 20 market (San Juan, PR) in the pre-consolidation era. Not one station hardened, and every one was vulnerable to hurricanes or flooding. Generally, a hurricane would take some stations out and leave others on, but never the same stations.

Today, getting building permits, environmental permits and other licenses to put a hardened transmitter site together are several times more complex and make such projects very expensive. With declining revenues for the industry, and a lack of government understanding of the fact that cellphones and the Internet are not viable in disaster situation, there is no way to build "hard" facilities any more.
 


First, even in major markets most stations were not "hardened" to the degree you envision.

The degree I'm envisioning is simply not total (or even mostly) internet dependent. Is this too much to ask in a world of extremely unreliable internet services?
 
At least I know our CAP system will be totally reliable in a hurricane, tornado, or natural diaster. I want to ask a FEMA director what fails first. Good example of government procedure on paper that is not reliable in a actual scenario.
 
At least I know our CAP system will be totally reliable in a hurricane, tornado, or natural diaster.

Indeed it will! You may not relay a single emergency message designed to help anyone by saving life and/or property because of an upstream issue with a router (or downed lines) somewhere else but, you'd have a fully functional CAP system at three local level. I guess it all depends on whether your goal is "to be compliant" or "to be compliant while also serving the listeners in the best ways possible and in the interests of public safety". I tend to always go for the latter. For some odd reason, most others do not. I guess, to each his own. I just know that I like the idea of local audiences knowing they can count on my client stations for emergency news and information. For some reason, they seem to be much more willing to support local stations they can rely on in a time of crisis.
 
Indeed it will! You may not relay a single emergency message designed to help anyone by saving life and/or property because of an upstream issue with a router (or downed lines) somewhere else but, you'd have a fully functional CAP system at three local level. I guess it all depends on whether your goal is "to be compliant" or "to be compliant while also serving the listeners in the best ways possible and in the interests of public safety". I tend to always go for the latter. For some odd reason, most others do not. I guess, to each his own. I just know that I like the idea of local audiences knowing they can count on my client stations for emergency news and information. For some reason, they seem to be much more willing to support local stations they can rely on in a time of crisis.

I was being sarcastic. Internet will fail first. I was in both Ivan and Katrina (pre CAP) and the internet was out for two weeks. At our current station. We had severe storms this week, and internet was out for periods of time. Thank heavens for 950Mhz STL or most of us would of been throwing a carrier. But hey..... we are CAP "compliant" :)

Redneck EAS system: Our City Administrator walked up the stairs and on a post it note asks us to remind local residents to remove cattle and farm equipment from low lying areas because of potential flooding. It worked flawless.
 
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Indeed it will! You may not relay a single emergency message designed to help anyone by saving life and/or property because of an upstream issue with a router (or downed lines) somewhere else but, you'd have a fully functional CAP system at three local level. I guess it all depends on whether your goal is "to be compliant" or "to be compliant while also serving the listeners in the best ways possible and in the interests of public safety". I tend to always go for the latter. For some odd reason, most others do not. I guess, to each his own. I just know that I like the idea of local audiences knowing they can count on my client stations for emergency news and information. For some reason, they seem to be much more willing to support local stations they can rely on in a time of crisis.

I've sawed on this topic before, but I'll mention it again: our local radio stations were as useless as teats on boars during the Royal Gorge Fire of 2013. During the height of the fire, about 6:30 in the evening, as the west side of town was receiving pre-evacuation orders, and while we could see DC-10 jets dumping orange sprays of retardant over the mountains some three miles west, our local stations were stuck on automation. Simply inexcusable. It was THE ONLY reason I applied for an LPFM for this town in the window later that fall.

Thankfully, my LPFM never got past the planning stages, and I returned the CP back to the FCC. "In Statu Quo", not "E Pluribus Unum" or some other high-sounding yet meaningless Latin phrase, is the unofficial motto of local residents and their government. I could have railed against our local stations' failings, but chose to keep it positive. And unlike a lot of areas, the terrain-challenged valley actually had a lack of listenable FM stations.

I could rail on about other current scandals in this relatively small county, but I won't. Put the clues together and Google or Bing them for yourself. It's the main reason I'm thankful I'm not running an LPFM here today.
 
Either way, I think that we can all agree things can get seriously out of hand when licensees decide to "cheap-out" and, as a result, abdicate their responsibilities to the local community. It gets really bad, really fast. This is what's happened in Selma and we'll just have to sit back and watch the results as they unfold. All I know is that I've (in private messages" given Dan good advice on how to be legal, his engineer advised his on how to be legal, too. Then, I've also seen others on this forum give him not so good advice on how to "maybe be almost legal while saving money" and, as I understand it, he opted for the latter and it is now costing him. I almost wish that he was able to share those expenses with those who advised him on how to be "almost legal" while "saving money". Maybe, if they also shared the responsibilities and the expenses, they wouldn't be so fast to offer up money saving advice again, later? It doesn't cost them anything to give it out. It only costs the poor folks who are uninformed enough to follow it.
 
Either way, I think that we can all agree things can get seriously out of hand when licensees decide to "cheap-out" and, as a result, abdicate their responsibilities to the local community. I

The real issue is that radio overall has declining revenues, more and more stations dividing the revenue pie, and many alternatives for listeners.

Stations do not "cheap out". They adjust to new realities.

The company I was with had stations in Lake City, FL in the late 80's. There was enough revenue to do good community service, carry HS sports, do fund raisers and to be live with information blocks three times a day. Then Docket 80-90 essentially tripled the stations in the market with no growth in revenue. We had to cut back much of the community programming, the high school decided to ask for rights fees, and the new stations sold ads for a buck each. We eventually sold for about a third of what was paid.

You can't ask commercial stations to lose money. And you can't ask someone who has invested their savings and, maybe, their life, in a station to just sign it off. This is not an easy subject if we want to say what is right and what is wrong.
 
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