LPFM's to be regulated by states, not the FCC?

[Chuck]

As for selling commercials, I think that harms the integrity of what LPFM is supposed to do. Having worked in both non-commercial and commercial radio, I can tell you there's a different mind-set in each of the systems.

Speaking as someone who ran a LPFM station for a little over 8 years, I can tell you that it would be very helpful to have some kind of limited commercialism. It is very hard selling underwriting to most small businesses. Perhaps restricting advertisers on these stations to those who are located within 25 miles of the station's transmitting site would be appropriate. That way they would be an actual part of the community, not carpetbaggers from afar. Maybe easier still would be a further relaxing of the enhanced underwriting rules. That could make life a bit easier these stations.

That said, it occurs to me that if LPFM's were to become commercial, they would come under the FCC rules that require new allocations to be auctioned, not granted. The price of admission might keep a lot of players out of the game. Of course, those existing rules could be changed, but that possibility opens up a whole new can of worms. Be careful what you ask for, you may get it.

 

[TheBigA]

Speaking as someone who ran a LPFM station for a little over 8 years, I can tell you that it would be very helpful to have some kind of limited commercialism.

As someone who was in non-commercial radio for ten years, I believe that is the best approach for real community radio. It forces you to keep your costs down, remain engaged with the community instead of advertisers, and provide programming that serves the public instead of the ratings. The minute you get a taste of the evils of commercialization, it's a drug you can't give up. Take it from me.

 

[WCWalker]

Speaking as someone who ran a LPFM station for a little over 8 years, I can tell you that it would be very helpful to have some kind of limited commercialism.

As someone who was in non-commercial radio for ten years, I believe that is the best approach for real community radio. It forces you to keep your costs down, remain engaged with the community instead of advertisers, and provide programming that serves the public instead of the ratings. The minute you get a taste of the evils of commercialization, it's a drug you can't give up. Take it from me.

This is the perfect recipe for playing right into the hands of the corporate broadcasters. Take away the opportunity for small business to stay in business by not giving them an affordable means of advertising. This allows the big boys to get bigger while Mom and Pop go under.

Non commercial operation is hardly resilient to the economic doldrums that we face. Note the following story about a station in Bennington, VT that is experiencing trouble. I am willing to bet there are hundreds of stations just like this (non commercial) facing these same issues right now.

http://www.rutlandherald.com/article/20100204/NEWS02/2040354/1003/NEWS02

 

[TheBigA]

This is the perfect recipe for playing right into the hands of the corporate broadcasters. Take away the opportunity for small business to stay in business by not giving them an affordable means of advertising. This allows the big boys to get bigger while Mom and Pop go under.

Really? Tell that to the folks at Citadel. The fact is that radio advertising has dropped almost 30% in the last year. You want a piece of that? Advertising is not the panacea you seem to think it is. And in the process, it takes these small community stations and throws them into the lion's den.

The biggest mistake these stations make is waste time worrying about the "big boys." My local LPFM spends all its time ranting about Clear Channel. What's the point? That's not community service. When you waste time and effort attacking an enemy, it takes away resources from achieving the primary goal. Focus on the positive. There are a lot of advantages to being non-commercial, and you have to emphasize what they are. Otherwise you simply become the same kind of operation as the one you're competing against. Viva la difference!

 

[WCWalker]

Citing Citadel's fiscal woes is a perfect illustration of why we need commercial Mom and Pop radio.

Citadel is an overextended, bloated corporation that cannot really service its local markets effectively with syndicated programming. Like all corporate entities they charge exorbitant rates for advertising in an effort to try to cover their bloated budgets. Small start up companies or proprietors are not likely to have a budget to advertise on these stations. And print media may not effectively reach their target market.

I have a friend that owns a family owned restaurant that he took over from his parents a decade ago. At one time he spent thousands of dollars advertising on a couple of Hartford market corporate stations in an effort to grow business. After spending all that money for a couple of months he realized he was not seeing enough of a return on his investment. The reason why? 85% of his primary market lives within a three to five mile radius of his business. Now what % of metro station audience might be tuned into the one or two stations that he happens to run his ad's on if his primary market only represents perhaps 10% of the coverage area of a major FM or AM in a metro market?

A What If: Now, a small station with a small reach located in town would more effectively reach his target market and a much larger % of potential customers will likely be listening to the local station with a small reach than the large station that competes with many other large stations for the same audience. That Mom and Pop AM or FM with its niche format that services that community where his business is would not only charge less money for advertising but also more effectively reach the people that will use his restaurant. People living 25 miles away on the other side of the metro area are not going to drive to a restaurant serving Greek and Italian food because there are others that are closer to where they live. Thus, he wasted thousands of dollars on advertising to people that cannot be considered potential patrons of his business or others like it. Clearly a small LPAM, LPFM etc. can more effectively service a community in this regard.

 

[Carmine5]

This is the perfect recipe for playing right into the hands of the corporate broadcasters. Take away the opportunity for small business to stay in business by not giving them an affordable means of advertising. This allows the big boys to get bigger while Mom and Pop go under.

Really? Tell that to the folks at Citadel. The fact is that radio advertising has dropped almost 30% in the last year. You want a piece of that? Advertising is not the panacea you seem to think it is. And in the process, it takes these small community stations and throws them into the lion's den.

I don't agree here. There are many communities that have thriving small businesses that would never consider advertising on a neighboring large city radio station, where the Citadels of the industry exist. A case in point is where I live. We have many successful small businesses that don't and would never consider buying time on a Los Angeles station--not only because of the expense but also because the reach is too broad. However, these same small businesses have no problem buying ad space in our local newspaper (which is not cheap).

Would a community station offering inexpensive local advertising be used by these small businesses? Yes. If they'll buy local newspaper, they'll buy local radio. What an LPFM or LPAM doesn't have that Citadel has is high overhead, starting with Suleman's multimillion dollar salary.

c5

 

[TheBigA]

Would a community station offering inexpensive local advertising be used by these small businesses? Yes. If they'll buy local newspaper, they'll buy local radio.

They buy local newspaper because they get something tactile that they can't get from radio, namely a physical coupon that can be used to measure ROI.

Support for community non-profits is different from advertising. It's support for the local high school band, or the girl scouts, or a church group. Local businesses do that all the time, and they would get more from it if their good work is publicized by radio. That's the sales pitch. But it pre-supposes that the radio station is really operating as a community station, and not simply another commercial station with less power, or if that community station is pushing some kind of political or social agenda that a business doesn't want to be associated with. That's often a problem with a lot of these non-religious LPFMs.

I've gone to businesses asking for funding for community radio, and I know it isn't an easy job. But the funding rules have loosened up, and you can give a lot of information about the funder that was prohibited in the past, plus there's the tax deduction. They're getting more than simply a name at the start and end of a show.

There's a completely different state of mind in community radio. It has more in common with other charities and less in common with advertising, ROI, and ratings. You open that door, and in a few years, the community station will have many of the same problems that you say has befallen commercial radio.

 

[WCWalker]

The world of radio can use both non commercial and commercial stations. Each has its own niche and serves a purpose. It still takes money to keep a non commercial afloat. Some businesses are willing to buy sponsorships if they are able to help such a station. You can't always rely upon donations to keep a station like this afloat though and you will still have to rely upon commercial interests to keep the station going.

 

[Carmine5]

Would a community station offering inexpensive local advertising be used by these small businesses? Yes. If they'll buy local newspaper, they'll buy local radio.

They buy local newspaper because they get something tactile that they can't get from radio, namely a physical coupon that can be used to measure ROI.

Support for community non-profits is different from advertising. It's support for the local high school band, or the girl scouts, or a church group. Local businesses do that all the time, and they would get more from it if their good work is publicized by radio. That's the sales pitch. But it pre-supposes that the radio station is really operating as a community station, and not simply another commercial station with less power, or if that community station is pushing some kind of political or social agenda that a business doesn't want to be associated with. That's often a problem with a lot of these non-religious LPFMs.

I've gone to businesses asking for funding for community radio, and I know it isn't an easy job. But the funding rules have loosened up, and you can give a lot of information about the funder that was prohibited in the past, plus there's the tax deduction. They're getting more than simply a name at the start and end of a show.

There's a completely different state of mind in community radio. It has more in common with other charities and less in common with advertising, ROI, and ratings. You open that door, and in a few years, the community station will have many of the same problems that you say has befallen commercial radio.

Businesses can just as easily put coupons on a station's website or do a click through to the business's site. Many radio station websites already offer this.

As for the rest of what you're saying, I don't see how the two, a local station airing community programming with commercials, need be mutually exclusive. Such a station should, and I think would, realize that its advantage over the "big boys" is its community involvement and localized programming, such as high school sports, etc. The community simply would not be getting this kind of programming from a major market station nor would it be feasible for a major market station to even offer it. The question of commercials is really immaterial.

c5

 

[TheBigA]

The community simply would not be getting this kind of programming from a major market station nor would it be feasible for a major market station to even offer it. The question of commercials is really immaterial.

If the question of commercials is immaterial, then they should learn how to program without them. And since the law has already been passed, and isn't going to change, the subject of commercials on LPFM is immaterial.

If there were advertisers who wanted to pay for high school sports, it would air on the commercial stations. There is no shortage of low power commercial AM stations in every town for this kind of programming. They don't need to add even more stations to the mix competing for the same limited local dollars. Use non-commercial as an advantage, not as a limitation.

 

[Goat Rodeo Cowboy]

I don't play bridge.

I don't read novels.

One of my mental stimulations is to outline possible radio stations. I have a small "fleet" of communities of various sizes and "cultures". I contemplate: What would my station "look like" if I had a commercial station in this community? How would it be different if it were NCE or LPFM? What traits/programming/style would I install in either a commercial or non-commercial setting? Does this community have any "killer traits" that would make it hard or impossible to do non-commercial? Impossible to have a financially healthy commercial operation? (A small rural town with no significant amount of retailing is a KILLER!!!)

Are there traits that I would install in either kind of station, no matter the size and complexion of the community?

I had unusual appointments today so lunch was impromptu and late. My wife suggested that on my way home I stop by Quiznos and pick up a sub. Our favorite and convenient Quiznos closed last year and reopened under new ownership.

We just finished a robust and inventive conversation that covered the following: Could we operate one of those? Where would you want it to be? We discussed the traits of various communities we are familiar with. We discussed locations in the heart of the business district versus locations more suitable for drive up access.

For some people all Quznos locations are just alike. They are what they are. We concluded that though the product line is quite rigid, the location and personality varies widely.

As I read discussion here (and participate here) I notice that in the mind of some people, all radio stations are really just alike. More troubling to me is the assumption by some that all LPFMs are just alike. For that to be a valid assumption, all communities would have to be alike. I encourage all of you to think with great variety so that when you compose messages here, we all can expand our visions of radio, commercial and non-commercial. It is painful when one of the most common descriptions used today in discussing radio is: COOKIE CUTTER.

 

[Carmine5]

The community simply would not be getting this kind of programming from a major market station nor would it be feasible for a major market station to even offer it. The question of commercials is really immaterial.

If the question of commercials is immaterial, then they should learn how to program without them. And since the law has already been passed, and isn't going to change, the subject of commercials on LPFM is immaterial.

If there were advertisers who wanted to pay for high school sports, it would air on the commercial stations. There is no shortage of low power commercial AM stations in every town for this kind of programming. They don't need to add even more stations to the mix competing for the same limited local dollars. Use non-commercial as an advantage, not as a limitation.

As you may have noticed by this entire thread, the whole discussion has been hypothetical--not as LPFM is mandated now. However, if an LPAM service ever sees the light of day or if a new class of FM or changes to the LPFM service are proposed in the future and given the financial challenges facing the broadcasting industry (and a growing loss of support from underwriters) some flexibility should be permitted in the airing of commercials.

As for existing stations providing local programming, this is not the case in many areas. Again, I point to where I live. We have 4 stations licensed to our community. Two are non-com (one-religious, one-NPR) and two have moved their studios to Los Angeles. So, no, we do not have a community station--no low power AM station as you suggest--which can provide local programming. Such a station would be most welcomed here.

c5

 

[TheBigA]

As for existing stations providing local programming, this is not the case in many areas.

When I say "low power AM," I mean anything under 50K. So if there's a 5K nearby, and they're not religious, they'd qualify.

 

[Flying-Dutchman]

Low Power AM is actually a very good idea. There are frequencies that could be used in many
large cities. Also, good community radio could bring some life back to the AM band.

Commercial stations can be very expensive to buy and operate. There is no cost in filing for
a non-commercial license from the FCC. Non commercial is tax exempt and has no FCC fees.
They use a volunteer staff and go to the listeners for donations.

Remember the golden rule. He who has the gold makes the rules. In other words, he who
pays for the station keeps it on the air. If you are commercial, then you must please the
business people. If you are non-commercial, your listeners donate. If you want to do your
own thing-reach into your own wallet.

Success in broadcasting has come to a few of us. But, when Lady Luck smiles on you, don't
get the big ego. Don't give yourself all the credit. Most of it really was just the grace of God.

 

[TheBigA]

More troubling to me is the assumption by some that all LPFMs are just alike.

I hear you, and I know what you mean. But when dealing with an entity like the federal government, there is no individuality. Case in point: Army uniforms. They come in one style and color. Same with radio regulations. So you come up with a new classification, and it's one size fits all. And in this case, it's non-commercial.

Having written my masters thesis on the Public Broadcasting Act of 1967, I can tell you exactly why the government wanted these stations to be non-commercial. The words of Newton Minnow echo in our heads. The "vast wasteland" got that way because of commercialization. The government, for the most part, doesn't like commercialization. It likes a certain level of dependence. It likes it when communities need each other, rather than catering to the needs and desires of private business. That's part of the battle going on right now over health care. You can see how the lines are drawn.

So that's why I'm so passionate about these new stations retaining their non-commercial character.

 

[Flying-Dutchman]

I recently helped a friend start a community station that serves Indianapolis. They have 6,000 watts.
They got their license for free and got on just for the cost of equipment. A commercial license to do
this might have cost 7 million dollars. So, they are 7 million ahead at the starting gate by being
non-commercial.

 

[Goat Rodeo Cowboy]

The government, for the most part, doesn't like commercialization. It likes a certain level of dependence. It likes it when communities need each other, rather than catering to the needs and desires of private business. That's part of the battle going on right now over health care. You can see how the lines are drawn.

So that's why I'm so passionate about these new stations retaining their non-commercial character.

I wasn't sure for a moment where you were going with that logic. I like where you took it.

For many years the hospital world was dominated by not-for-profit organizations. Circa 1970 we saw the rise of corporate ownership of some hospitals. Today we have a healthy tension between the two forces.

City and county governments have traditionally provided services from street cleaning to sewage plants with public-sector employees, a not-for-profit organization. Today we see a push toward outsourcing some of these services to commercial contractors. Another example of a healthy tension between the two forces.

I think you have made a good case that broadcasting needs a segment of the family to remain in the hand of not-for-profit licensees operating in a non-commercial mode. Can we call it a healthy tension.... both for the INDUSTRY and for the NATION.

Thank you for the image.

 

[Carmine5]

Low Power AM is actually a very good idea. There are frequencies that could be used in many
large cities. Also, good community radio could bring some life back to the AM band.

Commercial stations can be very expensive to buy and operate. There is no cost in filing for
a non-commercial license from the FCC. Non commercial is tax exempt and has no FCC fees.
They use a volunteer staff and go to the listeners for donations.

Remember the golden rule. He who has the gold makes the rules. In other words, he who
pays for the station keeps it on the air. If you are commercial, then you must please the
business people. If you are non-commercial, your listeners donate. If you want to do your
own thing-reach into your own wallet.

Success in broadcasting has come to a few of us. But, when Lady Luck smiles on you, don't
get the big ego. Don't give yourself all the credit. Most of it really was just the grace of God.

LPAM has been proposed to the FCC as far back as '05. This article in Radio Magazine makes reference to one such proposal:

"Existing broadcasters would be ineligible to apply, Local residence, at least initially, would be required. Power levels of up to 100W, 24 hours per day are proposed,Interference calculations would be made under existing AM allocation rules, but with a 100W application treated as one for 1kW."

http://radiomagonline.com/fcc/radio_fcc_considers_lowpower/

http://www.recnet.com/fcc/RM-11287_petition.pdf

There was another proposal for LPAM which closely mirrored the specs for TIS stations. The only difference was the programming, ownership requirements and status of such stations. As much as such a service is needed (and I believe there is a need) it has still to come up on the FCC docket after all these years.

c5

 

[TheBigA]

There was another proposal for LPAM which closely mirrored the specs for TIS stations. The only difference was the programming, ownership requirements and status of such stations. As much as such a service is needed (and I believe there is a need) it has still to come up on the FCC docket after all these years.

If they wait another year or two, they won't need to license LPAM, because 5K frequencies will be available for free. I really believe a lot of owners are simply waiting for the FCC to come up with favorable terms for them to donate their AMs to non-profits, especially minorities.

 

[Flying-Dutchman]

I think the FCC will allow LPAM. It will take some time. It took almost
20 years to get LPFM going again after it was discontinued by the
Commission in the 1970s.

As for the LPFM movement, three guys filed petitions in the 1990s..
But, none of them resemble what was passed. What does resemble
what was passed is a petition I filed in the 1980's. Here's from the
FCC public notice in the 1980's

From the FCC
Bruce Quinn petitions to allow the use of class D stations
operating on any FM channel. Licensing
would be based on spacing requirements only, not based on
allocations. These stations would operate on a
secondary basis, noncommercial only.

the FCC states, "We also invote comment on
authorizing increased program origination by FM translaotrs as
proposed by Craver, La Tour, Quinn and Jacoby. We observe that
to permit unlimited program origination has the potential to make
available more channels of radio programming in less rural areas
of the country. In these areas, program origination authority
may result in programming tailored to small audiences with
specialized tastes rather than to a least common denominator mass
audience. We seek comments on the value, need, and desirability
of expanding the FM translator authority to permit increased
program origination. Since the expected location of such
translators would affect listeners' options as well as competing
full-service stations, we request comments on the expected
location of such new translators. We also request information
regarding the extend to which the service provied by full-power
FM stations may not meet the public's needs or wants and how
expanded translator program origination might further the public
interest in this regard.