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Low Power FM Stations - Pros & Cons

Some of my previous comments have been misunderstood, so perhaps I did a lousy job of clearly expressing the opinion. I have no argument with Low Power FM radio stations. The problem is that many of the compliant stations are clobbered by the non-compliant blasters . . .

The "Low Power FM Service" (full definition below) has been instrumental in providing thousands of tiny signals to serve churches, minorities, schools, and social groups all across the country. It has blossomed like no other creation in the radio world. That is a noble and valuable aspect of LPFM, giving the Little Guy & Gal a new neighborhood voice.

The lack of effective FCC regulation has signaled a Green Light for many stations to transmit considerably above their licensed output power and/or antenna height limits thereby crowding out many of the honest operators that do comply with their licensed limits. This has caused interference to the point that listeners can hear multiple stations battling each other on car radios while driving down a local street. That calamity is not helpful to anyone and is most damaging to the stations that operate correctly. Examples of that problem have been stated on this site for years.

At the core of the issue, the real problem is not the FCC – the real problem is Congress because it has failed to provide funding levels that are necessary for the FCC to do its job. Many observers have pointed out that the FCC is woefully understaffed to meet the needs of regulating LPFM stations in a fair and comprehensive manner. For now, there’s not enough money to effectively regulate the thousands of Low Power FM radio stations.

Over the years, Congress is famous for creating government programs but not providing the support dollars to go with them. In the past, that type of law was called an “unfunded mandate.” Similarly, Congress has created an unfunded mandate for the FCC requiring it to do what it cannot do with current budget levels.

This funding shortage has provided the ultimate incentive for certain LPFMs to violate power output limits to steal more listeners from the compliant stations. If there’s no one to stop the violators, the Green Light (representing “go” and “the color of money”) provides too much incentive for them to boost output power well beyond licensed levels.

Illegal broadcast operations are only part of the problem. Another issue goes to the LPFM legal and regulatory structure. The FCC clearly states,
> “LPFM stations are not protected from interference that may be received from other classes of FM stations.”
This means that LPFMs suffer from double-trouble: They get no protection from other FM classes and get no protection from other illegally-powered LPFMs.

Congress created LPFM to be a new unique radio reach for smaller communities. Congress also dropped the ball on enforcement funding so that compliant players are drowned out by the non-compliant players. Realistically, the budget requirements to properly control the LPFM space are probably unattainable.

The concept of LPFM service is excellent, but the reality has been a mess. LPFM service is subject to excessive reception interference; some originates from illegal operators, and some from unfunded enforcement protections to rid the space of those illegal operators.

[“The Low Power FM (LPFM) radio service was created by the Commission in January 2000. LPFM stations are authorized for noncommercial educational broadcasting only (no commercial operation) and operate with an effective radiated power (ERP) of 100 watts (0.1 kilowatts) or less” with maximum antenna height of 30 meters (100 feet) above average terrain (HAAT). “The approximate service range of a 100 watt LPFM station is 5.6 kilometers (3.5 miles radius).”]
--- https://www.fcc.gov/media/radio/lpfm
 
Over the years, Congress is famous for creating government programs but not providing the support dollars to go with them. In the past, that type of law was called an “unfunded mandate.” Similarly, Congress has created an unfunded mandate for the FCC requiring it to do what it cannot do with current budget levels.

However, they gave the FCC the ability to fund itself through the sales of spectrum space and license fees. A bigger problem is for the stations themselves to find the local funding to keep them operating. At one time, educational institutions owned a lot of broadcasting. During the last five years we've seen many of those educational institutions selling their broadcast licenses, citing lack of interest and high cost. So those licenses have gone primarily to religious organizations.
 
The problem is most LPS in the Houston market are owned by "ghost company's/churches" that only take space and really not doing anything for the community.
 
Prometheus is not a LPFM license holder. They advocated for LPFM and continue to be listened to by the FCC as if they are the NAB. Actually Prometheus is an advocate of one type of LPFM station. I wish they were not locked in to only community radio as they see it.

Michelle Bradley, RecNet does some engineering work and is the face of LPFM as a whole. Michelle does not hold an FCC license but yet Michelle is able to bend the FCC's ear. Michelle has advanced LPFM to this point even more so than Prometheus but like Prometheus, has her opinion of what LPFM must be. True to herself, if it is not matching her opinion, she won't advocate for it.

I find it unusual that LPFM station have two advocates that are not inclusive of all LPFM stations and neither organization actually holds a license. I would say a state radio group is directed by actual licensees or those running stations at a minimum. LPFM lacks an all inclusive voice but at least Michelle Bradley is pretty close to being that as an individual.

LPFM stations are mostly religious and some are other formats including community radio, which itself is not a true statement but rather 'selective' community radio. Not everyone can get airtime as community radio is a 'format'.
 
Prometheus was the first organized roup advocating for LPFM. Without them, LPFM may not have happened. They help like-minded LPFMs and advocate for only this type of LPFM. They tend to not be fans of stations that operate as ministries or function much in the way of that small town radio station serving their local area with a LPFM. They'd prefer LPFM be public access and a voice for those without a voice...great for big cities but not every instance.

Michelle Bradley has done the most for all types of LPFM stations. She mostly keeps her opinions out of it, but where she feels strongly she has a narrow interpretation that does not work in all cases. In my opinion she does not understand radio sales. She doesn't seem to like that I contend a business buying underwriting is doing so because of the benefit they get from it. She would seem to prefer underwriting be presented as a request for a donation. Given I deal with business owners selling advertising every day, I can tell you the mindset of the business owner is 'how does this help my business'. Even any donations are structured to benefit the business.

Michelle provides some engineering assistance and is very good at what she does. She knows how to bend the ear of the FCC and just how to word things to get their attention.

My opinion is LPFM needs an advocacy group that includes everyone but quite frankly there is so much animosity among some groups, I doubt everybody will ever get on the same page.
 
There are more than a few LPs around that are really commercial stations masquerading as non-profits with "ads" for bars, night clubs, concerts, car dealers, etc that just tag each "spot" with "we thanks them for their generous support."
 
Are we talking about translators, or LPFM here?

I know there are loads of translators in Houston, some with half-decent signals. And they are commercial for the most part.

But non-commercial LPFMs are different. Are there any that are making any kind of impact or "noise" in Houston?
 
There are more than a few LPs around that are really commercial stations masquerading as non-profits with "ads" for bars, night clubs, concerts, car dealers, etc that just tag each "spot" with "we thanks them for their generous support."

Of course there is more to that than just a final statement, including prohibitions for price/item ads, advertising sales and specials, comparative ads and quite a few other restrictions. If an LPFM is doing "normal" ads with a tag on them, that ain't legal.
 
Again I agree with David. Many of these "LPS" "none profit " "translator " are 100% profit! I notice a huge war between fm translator owners and "lp owners" over contours and signal interference. They want the same respec the big boys (full powers have) . Having the right engineer firm working before you apply on the same dial of a full power or another translator would be good before you start crying to the fcc about "interference".
 
Again I agree with David. Many of these "LPS" "none profit " "translator " are 100% profit! I notice a huge war between fm translator owners and "lp owners" over contours and signal interference. They want the same respec the big boys (full powers have) . Having the right engineer firm working before you apply on the same dial of a full power or another translator would be good before you start crying to the fcc about "interference".

Yikes!!

Most of us LPFMers are just doing our thing as good neighbors on the dial. Many of us are SBE members and maintain a good relationship with our "full-power" colleagues. Yes, we do respect the "big boys" and even depend on their generous guidence. I haven't met a bad broadcaster yet, but I've met a lot of good upstanding folks who just want to give the best they have to offer, and that's why radio still works after over 100 years.

Bad apples in radio?!? There may be some out there, but always look for the good folks trying to do the right thing!! You'll feel better about radio! :)
 
At one time, Prometheus Radio Project was a very well-funded organization with physical offices and staff. This lasted until after the enactment of the LCRA and the funding for LPFM dried up. The offices were closed, staff left.. Prometheus is now two different identities per se. The Prometheus name lives on in coordination with the Georgetown Law Center who is working to push for media ownership reforms. The "original" Prometheus is now mainly Paul Bame and Will Floyd, who has taken on the LPFM roles. I believe that both Paul and Will are currently involved with LPFM stations.

I have spent many years following the media industry from a regulatory perspective. I became involved with LPFM in the late 90s when Don Schellhardt and the late Nick Leggett were working on a petition for rulemaking that eventually became known as RM-9208. REC did sign on with some of the early decisions of the Amherst Alliance, their organization.

In those days, please understand that the concept of LPFM was being advocated from different angles. Prometheus was aligned with community and media justice organizations trying to push a local voice for local people. Independent of that, there were more technically inclined people like Amherst and REC working on a technical proposal. Early in the proceedings, REC did take more of a backseat approach. Also, independent of all of us, Rodger Skinner, an LPTV speculator was also working on his own LPFM technical proposal (have LPFM mirror LPTV as a commercial service). This petition became RM-9242.

Under pressure to address the pirate radio issue in the wake of the enactment of the Telecommunications Act, then-FCC Chairman William Kennard pushed for the LPFM service. The RM-9208 and RM-9242 proceedings were combined in MM Docket 99-25 and the rest is history.

My current "indirect" involvement in LPFM stations allows me to better focus on the industry as a whole and how it will impact the various issues that I am involved with. I am in a position where in am "segment neutral" where it comes to LPFM stations. This means, I work with faith-based stations, the grassroots community stations as well as the microstations (those stations with corporations established for the sole purpose of running the station and has no real community service organization backing..). Also, REC should not be branded as an "LPFM organization" per se. It's more about "citizen's access to the airwaves". This can include full-service NCE.. and in some cases, this can involve diverse ownership in commercial stations.

REC is about accessibility... both in ownership/operation and in areas available (especially many underserved rural areas). REC's reach does extend past broadcasting and includes other FCC issues including other wireless radio services (such as amateur radio) and telecommunications issues.

Where it comes to LPFM and NCE, I do have the ear of the FCC because I am the only one who is proactively reaching out to staff. I am the only one traveling to DC to attend meetings and giving ex parte presentations. Those who go beyond filing comments are the ones who will get heard. The record will show that there was a lot of work that went into the FCC bringing 19-3 and 19-193 forward last year. While it was the petition and comment filings in Media Modernization that sparked the flame, it was the many phone calls, letters and visits to the Portals that kept the issues alive and prevented mistakes based on misunderstandings by the FCC to happen. NAB sends attorneys to meet with staff on many things. Somebody needs to be speaking from a non-NAB perspective.

I don't dance the same dance as other LPFMers, but my dance is pretty close and we are in step most of the time. I take more of a diplomatic approach. I don't consider myself an "activist". I want the Commission to see that there is the way that the NAB wants something, the way the activist LPFM movement wants it and the opinion of REC, which sides mainly with the LPFMers but from a different perspective. I am just a concerned citizen who wants to see LPFM improved for everyone, faith-based and secular. As suggested, I do have some very strong political opinions, but I consider LPFM bipartisan and I leave those opinions at the door.
 
I don't dance the same dance as other LPFMers, but my dance is pretty close and we are in step most of the time. I take more of a diplomatic approach. I don't consider myself an "activist". I want the Commission to see that there is the way that the NAB wants something, the way the activist LPFM movement wants it and the opinion of REC, which sides mainly with the LPFMers but from a different perspective. I am just a concerned citizen who wants to see LPFM improved for everyone, faith-based and secular. As suggested, I do have some very strong political opinions, but I consider LPFM bipartisan and I leave those opinions at the door.
See what I mean about the good broadcasters? Michi, you're an example of why radio works!
 
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