If I Were The Super FCC Commissioner...

1) Place an immediate freeze on any new licenses on the AM band. Renewal applications currently pending and existing stations would be exempted. As technology continues to improve while AM listenership continues to drop with stations going dead on a regular basis, we need to seriously look at the future of commercial radio on this band. Obviously, there will always be some need for AM radio. This is especially true in rural areas which are either underserved (if at all) by other radio signals in the region, as well as in major markets with a need to serve suburban areas or provide unique programming opportunities for segments of the population.

2) Require all applicants for broadcast licenses to provide proof that they would have the financing availabile to operate for a minimum of three years. In today's economy, I realize that is a tough requirment. However, this requirement would help better the chance that a station would have a fair chance to survive before pulling the plug...or having it pulled for them by lenders.

3) Reinstate...sortof...the ownership limitations of pre-deregulation. We've seen what companies such as Clear Channel have done to the business in an effort to become the "biggest and baddest"...and as I type this they are on the edge of possible bankruptcy. What their actions have done to local radio nationwide has been no less than a disgrace. I would limit a broadcaster to a maximum of two AM and two FM stations in a market, with a maximum total of ten AM and ten FM stations nationwide. Slightly more liberal than the old rules permitted (one AM, one FM, seven of each nationally), but it would lessen the chance of a company to overextend itself while concentrating on serving it's local markets.

4) In seeking to change a station's City of License, a broadcaster would have to submit documentation to show how such a change would provide significant and original service to the area it is seeking to cover, as well as how it would continue to serve it's current COL. The reason for this idea is because many of us have seen this happen simply for a station owner to achieve access --- and, hopefully, increased profit --- to a nearby larger market Here, the owner would have to show that it would be providing something different to the area besides another soundalike signal.

5) Broadcasters would be required to commit to a mimumum of 75 percent locally originated programming weekdays, 50 percent weekends and holidays. Live coverage of special news events and broadcasts of sports events (pre/postgame and PBP broadcasts) would be exempted from this requirment. This would, hopefully, truly make radio LOCAL again. In many places, this seems to have become a thing of the past. I say this should be ended NOW! We are here to provide a service to the communities that we are licensed to serve. That is a privilege.

The time has come for policy makers in DC to say boldly that while we agree that it is important for a broadcaster to make a profit, it should be done in such a way that the community/area is placed first...and that you should either do it or get out of the way!

Nice sentimental list of features that give a warm and fuzzy feeling to people who view broadcasting much the same way many people review a religious dogma.

If you want to start a movement that might accomplish some of the things you value, start by creating a list of policies that will make radio valuable to the listener.... and from that would come regulator features that might be put in place in a combined effort by Congress and the administration via the FCC.

I own two FM stations, a B, and an A The one station, the B, is licensed to a town of 2,000 in a county of 8,400. We reach a rated market, where we compete with 15 other commercial AM and FM stations for a 12+ audience of 120,000. The Class A station is licensed to a city of 5,000, in a county of 27,000--with two FM and an AM station as competitors.

In that later city there were four full-line car dealers just 5 years ago. Now there is just one--a Ford dealer.
We just lost a major advertiser--and $2700 in unpaid advertising--when a "Major National Bank" pulled the floor plan on a major RV dealer in our main market.

In 1969, when I had my first commercial radio job in this market, there was no Wall Mart. Sears and Penney were major advertisers for their downtown stores. We had one McDonald's, fast food near the radio station I worked at was a BBF--a regional hamburger chain run by a couple of fellows including a guy named Dave Thomas. There was no mall--it wasn't built until the mid 70's. Everyone shopped in small, locally owned stores, which all advertised on the radio. We had two downtown areas, both thriving.

And there were just five AM stations,(and three FM's that no-one listened to).

So, now you want me to drop the satellite feed and go all live on both stations?

Choose a specific format ... say News/Talk and analyze the typical broadcast day of such a station, WIBC/Indianapolis

MID-5:30a: Coast to Coast AM
5:30a-10a: Local morning show
10a-11:30a: Local talk show
11:30-12n: Local & State News program
12n-3p: Rush Limbaugh
3p-7p: Steve Simpson (local news & talk)
7p-MID: Clark Howard

They're on the bird for 14 hours of the day.

And a typical sports talker, WFNI/Indianapolis:
MID-10a: ESPN Radio feed
10a-1p: Dan Dakich show (local - unless this one got canceled)
1p-4p: ESPN Radio feed
4p-7p: Kravitz & Eddie (local - hoping this one gets canceled)
7p-MID: ESPN Radio feed

WFNI is on the bird for 18 hours a day, 24 on weekends.

Or, drop from Market 41 (Indy) to Market 207 (Terre Haute, IN) where the news and sports talkers are both birdfed 24/7 unless there is play by play on the air.

The problem with these formats is difficulty of being compelling when 100% local. Indianapolis has several professional franchises and two Big Ten schools nearby, but the local shows still run out of stuff to talk about. Its not that ESPN Radio doesn't run out of stuff to talk about, but they have vast resources to talk with lots of different people about the same thing. When Colin Cowherd talks about something, it sounds different than when Doug Gottlieb talks about it.

Your list doesn't include any actual responsibilities for the FCC, as in policing the broadcast bands for pirates and controlling interference. The FCC has NOT kept up its end of the bargain for a long time.

Your list also doesn't include increasing minority ownership, which is the only stated priority for the new FCC.

The third part is how the FCC will pay for all these new regulations. Their staffing has been cut, they don't have the personnel to enforce or police their rules, and those who are left appear to be pencil pushers.

The reality is that the FCC itself has allowed the airwaves to deteriorate to this level by their own inaction, and their own agenda on things that don't matter. I have no reason to believe that will change any time soon.

OK, once again, take a music station and tell me how much of the hour must have a DJ talking and what they are required to say (unless you really believe these hours should consist of music by local bar bands). What does local really mean? I'd rather listen to Rush than somebody talking about the Dayton (OH) City Commission for three hours. In this case our affiliate does a great job with news.

Some of you want the eight station cluster to be broken up and have eight different owners, althewhile mandated to spend thousands of dollars on local staffing. And here in town, you can only talk about the University of Dayton flyers for so long. It's only radio people who believe "local always good, syndication always bad".

TheBigA said:

Your list doesn't include any actual responsibilities for the FCC, as in policing the broadcast bands for pirates and controlling interference. The FCC has NOT kept up its end of the bargain for a long time.

Your list also doesn't include increasing minority ownership, which is the only stated priority for the new FCC.

The third part is how the FCC will pay for all these new regulations. Their staffing has been cut, they don't have the personnel to enforce or police their rules, and those who are left appear to be pencil pushers.

The reality is that the FCC itself has allowed the airwaves to deteriorate to this level by their own inaction, and their own agenda on things that don't matter. I have no reason to believe that will change any time soon.

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Thank You, Big A, for neatly packaging my views. I would also add further engineering oversight to the FCC, and perhaps even split off
a branch dedicated to the (more or less) functions generally specified for the original FRC and early FCC, when attention was paid to true
management of the broadcast spectrum.

The FCC is spread too wide and shallow, and can no longer properly regulate radio from such "disinterested" or "distracted" position.
Partly due to financing, but also due to inattention and failure to respect the wisdom of the 'old-old' regulations regarding management of AM BC.

Besides the fact that it is a dumping ground for recycled puc commissioners. Look at the last two commissioners nominated--one is the daughter of a congressman, the other the daughter-in-law of a career politician.

Tom Wells said:

I would also add further engineering oversight to the FCC

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In my view, the ONLY role the FCC should have is technical oversight. Period. The rest, including ownership limits and anything else, would be set by the marketplace. Unfortunately, technical oversight isn't very glamorous. Thus, their interest in matters outside their purview.

Tom Wells said:

Partly due to financing, but also due to inattention and failure to respect the wisdom of the 'old-old' regulations regarding management of AM BC.

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Well there's more than broadcasting under their oversight, and broadcasting is the least interesting, based on the background of the current commissioners.

TheBigA said:

Well there's more than broadcasting under their oversight, and broadcasting is the least interesting, based on the background of the current commissioners.

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Which begs the question, should there be a separate agency to handle broadcasting?

In many countries, responsibility is split. There is one agency that handles technical aspects of all radio services (broadcasting, wireless phone, commercial two-way, etc.) and a separate agency that handles non-technical aspects of the broadcasting service.

w9wi said:

Which begs the question, should there be a separate agency to handle broadcasting?

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Perhaps. When you say "many countries," do you mean England, where they have a broadcasting tax to officiate?

My view is the main reason the FCC was created was for technical matters. All the other stuff is less important. Preserving the integrity of the airwaves is a federal role. The airwaves have been degraded over the last 40 years by bad policies and lack of enforcement. I find it laughable that Commissioners like Copps make demands of broadcasters when his agency has failed in its primary objective. He's a fireman who is worrrying too much about the cake, and meanwhile the kitchen has burned down.

Interstate4Jammer said:

I would limit a broadcaster to a maximum of two AM and two FM stations in a market, with a maximum total of ten AM and ten FM stations nationwide.

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That kind of rule only made sense when there was something known as "scarcity." Not really a problem any more. What destroyed that concept came in the 80s when the FCC overlicensed the spectrum. Too many stations, not enough qualified applicants, and not enough money in a community to support all the stations. If you study the history of the 96 Act, prior to it, the healthiest companies, the ones doing the best job were companies like Clear Channel, Shamrock, Nationwide, and the three networks (ABC, NBC, and CBS). Also, in the 96 Act, the reason they allowed companies to own more stations was to save AM. They required all companies who bought more FMs to also buy AMs. That was a mistake.

With regards to localism, you need to define your terms. In my opinion, a local DJ playing music recorded in LA or some other place is NOT local programming. It's local presentation of national programming. It's cheap and lazy, and doesn't serve the community. To me, local programming is 100% local, and I don't think it's fair to place those kinds of requirements on radio, and not on other media, such as television.

w9wi said:

In many countries, responsibility is split. There is one agency that handles technical aspects of all radio services (broadcasting, wireless phone, commercial two-way, etc.) and a separate agency that handles non-technical aspects of the broadcasting service.

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I only know of two countries where this dual or divided system is in place... Canada, and as Big A notes, England. I know of a hundred or so countries where this is not the rule.

Of course, in a totalitarian system, the "president" can regulate the media by fiat. This week, Hugo Chávez of Venezuela intervened by setting into motion the takeover of aobut 200 private AM and FM stations based on who the owners are and the fact that a number of owners have multiple stations.

In most places, the content is only regulated to the extent of preventing indecency, fraud, and other practices most would agree on in broad terms while technical aspects are regulated via rules and regulations.

I don't know about the situation now, but in my shortwave days i remember going through the World Radio and TV handbook and seeing countries where the broadcasters were regulated or even ownedf by the "Department of Posts(post office) and Telegraph"

gr8oldies said:

I don't know about the situation now, but in my shortwave days i remember going through the World Radio and TV handbook and seeing countries where the broadcasters were regulated or even ownedf by the "Department of Posts(post office) and Telegraph"

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That's interesting. The American system grew out of the Department of Commerce, mainly interstate commerce. The fact that these airwaves were passing over state lines.

gr8oldies said:

I don't know about the situation now, but in my shortwave days i remember going through the World Radio and TV handbook and seeing countries where the broadcasters were regulated or even ownedf by the "Department of Posts(post office) and Telegraph"

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In the areas that were part of the British Empire in particular the telegraph became part of the postal service. And then the telephone. And then radio. So in many places, the postal authority also became the authority for phones and radio and TV.

In most places, electronic communications have become so important that the regulatory body was long ago split from the postal service.

The British outposts in the Caribbean certainly had lots of departments of posts and telegraph systems. In the case of smaller countries, it made sense to have one body over all forms of communication.

TomT said:

Besides the fact that it is a dumping ground for recycled puc commissioners.

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In my opinion, those kinds of career regulators seem to understand the job better than political hacks like Powell, Copps, and Adelstein, who had political agendas, and wanted to legislate rather than regulate.

I was impressed with Deborah Tate, who had a lot of experience as a state public utilities regulator. She described the FCC as a public-private partnership, which is similar to what puc commissioners do with electric, gas, water, and oil resources. The airwaves aren't much different. She seemed fair and didn't attempt to make policy. Some people overthink this regulatory stuff. She didn't.

Work with Canada and Mexico to eliminate channels 4, 5, and 6 from the TV band, and convert those to FM radio channels.

As part of the reallocation process, all AM stations would reallocated to the former channels 4 and 5 (70.1 to 81.9 on the FM dial). The former TV channel 6 would be reallocated in the following manner:

1) Any licensee with two or more stations in the same metro area broadcasting identical programming could consolidate on to one channel in the new portion of the band that covers at least 95% of both stations' original service areas, but would surrender both original licenses. The new station would be required to be licensed to one of the original stations' COL. The original licenses go back up for auction.

2) Any FM station using translators would have the opportunity to consolidate both the parent station and the translators on one allocation between 82.1 and 87.9 MHz. The new allocation must serve the original station's COL.

3) All LPFM stations less than 100 watts would have the opportunity to change channels to any part of the band (preferably to a channel vacated in the previous steps) to achieve a maximum of 100 watts. No future LPFMs would be licensed with an ERP of less than 75 watts, and the maximum would be eventually be raised to 250 watts.

4) Any time-share LPFMs would be given the opportunity to split off into separate frequencies (Tuscaloosa, Alabama, this means you!).

Your plan requires everyone to purchase new radios to receive the new frequencies. This comes at a time when the public has made it clear it's not interested in buying new radios, and the electronics manufacturers aren't interested in making or marketing them. No one wants to be moved to frequencies no one can receive.

If no one's buying HD despite the constant bombardement of advertising, no one is going to buy radios that tune down to channel 4.