Why does Community Radio have to be LPFM?

[Bongwater]

And I think it's high time we closed some loopholes here with the translator/repeater laws of non-commercial stations. They should really be limited to within the MEASURABLE fringe signals of their primary stations, like commercial stations.

And this also includes these NPR college/university "networks". Local college/community radio affiliates, fine. But NOT massive statewide networks.

I think there's a place for those statewide networks, and it goes back to the original purpose of the FM translator service way back in the early 1970s: believe it or not, there are still parts of our great nation that have no local radio service at all. I lived in such a "radio white area" in the late 1980s, out in the remote high desert on the Nevada/California line, and there are still many areas like that in deepest Nevada and Utah and Arizona and other western states, too.

Those places can easily be 300 or more miles from the nearest city big enough to support a public radio outlet, far beyond any ability to receive an input signal over the air. In most cases, there's plenty of spectrum available to support both a satellite- or microwave-fed public radio translator and a local LPFM or small class A. The question is: how do you craft regulations that provide and protect the needed service to those tiny communities while preventing the loopholes that have been so flagrantly abused in recent years?

Well, point taken. But not even the Jesuscasters would set up a translator out there (and if it REALLY wasn't about MONEY for them, how ironic.) Exceptions for state/university networks can be made in REAL hardship cases. But seriously, every effort should be made to support locally originating programming on NCE stations at every opportunity.

 

[Chuck]

If I were making the rules (and I'm not) I'd grandfather existing translator networks, both religious and public. I'd do it, not because I necessarily like it, but because these people applied in good faith under the rules as they existed at the time of their application. It is hard to condemn someone for taking advantage of poorly written rules. It is a little like asking people to pay more taxes than they legally owe. As long as they followed the letter of the law in their application, then I can’t see penalizing anyone. Of course, this would allow state NPR networks to continue with business as usual.

That said, I would make sure this can never happen again in the future. The FCC's translator rules are a patched together mess of compromises and band-aid approaches. The Commission needs to start fresh and simplify the entire process. The "KISS" principle (Keep it Simple Stupid) should be the mantra. To that end, I think anyone should be allowed to own a translator, and that translator must be close enough to the originating station to receive it off the air during normal conditions. The current rule that it must be received off air if the originating station is in the commercial band is silly. Given the technology we have today there are simply more reliable ways to do it. Rather than going through some complicated formula and requiring stacks of exhibits to demonstrate the probability of actual off air reception, why not just make the rule that the translator must be within 125 miles of the originating station? That’s about as far as any station ever goes.

Further, I’d dismiss a lot of the backlog of Translator applications. The FCC has proposed putting a retroactive cap on applications, setting the number at 50. I think that is reasonable, but I can see how it might have a legal challenge, thus further delaying any future filing windows for translators or LPFM. Still, I think they need to get on with it. It’s been about 9 years since the last translator filing window, and that is simply too long to ask anyone to hang on, waiting for a decision.

 

[fybush]

But seriously, every effort should be made to support locally originating programming on NCE stations at every opportunity.

No argument there. But unless you've lived in one of these incredibly remote places, it's hard to imagine just how remote we're talking about. Look up "Dyer, Nevada" on a map to see what I mean. Without translator service, there's never going to be any "local" radio there...and even having translator service there all but requires the use of microwave/satellite relay to get a signal into town.

For what it's worth, there is a religious translator there, relaying a signal out of Bishop, California, which is only 30 miles or so away as the crow flies - but a challenging two-hour drive over a pair of 7000' one-lane mountain passes. And that's fine - there's lots and lots of open FM dial out that way, and room for anyone who wants to broadcast to the few hundred people within range.

 

[fybush]

To that end, I think anyone should be allowed to own a translator, and that translator must be close enough to the originating station to receive it off the air during normal conditions. The current rule that it must be received off air if the originating station is in the commercial band is silly. Given the technology we have today there are simply more reliable ways to do it. Rather than going through some complicated formula and requiring stacks of exhibits to demonstrate the probability of actual off air reception, why not just make the rule that the translator must be within 125 miles of the originating station? That’s about as far as any station ever goes.

And again, where probably 99% of the US population is concerned, I'd agree with you. But unless you've lived in "the middle of nowhere," it's hard to appreciate just how important the original purpose of the translator service still is to those remote areas. Those of us who live in the densely packed coastal states sometimes have a hard time imagining that there are places where you can drive three or four hours at top speed and never enter a community big enough to support its own public broadcaster or a full slate of commercial formats.

It's very, very hard to craft a single rule that can provide reasonable (and supportable) levels of service to both Alpine, Texas and Brooklyn, New York.

 

[Chuck]

It's very, very hard to craft a single rule that can provide reasonable (and supportable) levels of service to both Alpine, Texas and Brooklyn, New York.

True indeed. To that end, the FCC should consider (and grant) waivers on a case by case basis. For every rule, there is sometimes good cause for an exception, just as you point out. Remember, I'm not talking about taking away anything that has already been granted. I'm speaking only about new applications.

 

[fybush]

In my experience with the FCC, they really don't like to issue waivers. There's a strong preference for rules that are clearly drafted (at least in theory, if not in practice) to set out the agency's mission in a way that doesn't force an already-overtaxed bureau staff to spend time considering waiver requests. The waiver process, when it exists, is meant for the truly exceptional set of circumstances that might arise from time to time, and it's hard to argue that the very purpose for which the FM translator service was created - the provision of some very limited degree of FM service to communities otherwise so isolated as to have no such service - is "exceptional" enough to be handled through waivers instead of as a part of the rules themselves.

 

[Chuck]

In my experience with the FCC, they really don't like to issue waivers. There's a strong preference for rules that are clearly drafted (at least in theory, if not in practice) to set out the agency's mission in a way that doesn't force an already-overtaxed bureau staff to spend time considering waiver requests. The waiver process, when it exists, is meant for the truly exceptional set of circumstances that might arise from time to time, and it's hard to argue that the very purpose for which the FM translator service was created - the provision of some very limited degree of FM service to communities otherwise so isolated as to have no such service - is "exceptional" enough to be handled through waivers instead of as a part of the rules themselves.

You could probably codify the whole thing by allowing exceptions in areas where the population density is below a certain threshold. Off hand, I'm not sure what that threshold is, but somebody could take a look at Nevada, Wyoming, Alaska, etc. and come up with something reasonable. The information is readily available through the Census.

 

[Goat Rodeo Cowboy]

But each such state has at least one metropolitan area and the "hot dogs", the "sharpies" among us play games and still end up corrupting the waiver process trying to sweeten the pie in the metro area, sometimes pulling in frequencies that ought to be better used a little farther from town.

Doing government is a messy business.

Part of the "messy business" of implementing LPFM is the great variety (or is it the lack thereof) of definitions of what is really community radio.

Most of the religious LPFMs are not community... except to the one narrow church community that they serve.

We who are radio people, and who used to be radio people, and those who want to be radio people do not seem to share much of a common definition of "community broadcasting". I expect that community radio is going to sound a little bit different from one community to the next because their needs, their "features" are all going to be slightly different.

Community Radio as I would define it requires a lot of people power. That means an organized bunch of gung-ho volunteers. I have spent a lot of time trying to reduce a definition to writing. I have spent a lot of time trying to visualize how you bend and pervert an automation system to be community friendly. I don't recall ever coming across a good article in a publication or on the web in which the primary there is: "Here is how to do Community Radio by using automation mechanisms to extend the power of your people." I have no doubt it is being done. But how do we find the success stories?

 

[Chuck]

"Organizing a bunch of gung-ho volunteers" isn't as easy as it sounds. It is even harder to keep them working together after you have finally reached your goal of getting on the air. After a few weeks, reality sets in and many of them discover that being on the radio is actually work and requires some effort on their part.

Finding reliable volunteers is not unique to just Community Radio. Well established clubs and service organizations face the same problems. Volunteers tend to burn out fast when the challenges of everyday life intervene. In fact, keeping members is getting to be a significant problem for many service organizations and clubs. Young people aren't as inclined to be "joiners" as my generation was.

Because it is hard to have a large motivated group of reliable volunteers, automation is really your best friend in a small station. It doesn't miss air shifts, quit because of ego disputes or have temper tantrums. It is simply a tool that does what you tell it to. There is no reason that automation can't sound extremely local. It just depends what you put into it. That part is up to you. Don't blame a lack of localism on automation. Blame it on a lack of vision and/or desire on the part of its operator.

 

[Dtv]

Your local AM radio sounds like the type of station I would love to have in my area, for the simple reason am radio could be received at a greater distance. I love listing to my local watd -fm(watd is the only local- true local station in my area) but, with 1600 watts on fm it can fade only 8-10 mi away! With small fm's you need a good line of sight. 1600 watts on am would cover the area much better. If I can wjib 740 boston with 200 watts day to day outside of its service area, imagine how good a local 1000 watt am would sound.

 

[pianoplayer88key]

Your local AM radio sounds like the type of station I would love to have in my area, for the simple reason am radio could be received at a greater distance. I love listing to my local watd -fm(watd is the only local- true local station in my area) but, with 1600 watts on fm it can fade only 8-10 mi away! With small fm's you need a good line of sight. 1600 watts on am would cover the area much better. If I can wjib 740 boston with 200 watts day to day outside of its service area, imagine how good a local 1000 watt am would sound.

I too prefer AM over FM, due to the distance it can go. And, you might not even NEED 250 watts (that's what WJIB is listed as), and could maybe go higher in frequency and still get decent coverage.

For example, this was 990 KTMS on a SRF-59 then a PL-606 several months ago around 1:45pm - at a distance of 181 miles and with an ERP of 16.4 *WATTS* toward the listening location! Also that station uses two antennas that, according to the FCC figure 8 calculator (the info for the station itself references the RMS field for the station's 5 kW transmitter power due to it being directional), have an efficiency of only approximately 305.775 mV/m @ 1 km for 1 kW.

If a community AM station used something like this type of setup with an efficiency of 510 mV/m @ 1 km for 1 kW (or even higher - wonder if R Fry knows of any types of antennas with higher efficiency, for example the circle group aerial mentioned here - how efficient might that be?), I wonder how far a signal like that would get out, and still not require much power (saving money on the power bill)?
Or am I the only one on these boards that prefers transmitting antennas with an efficiency exceeding 500 mV/m/km/kW? Also a couple more questions for the Fry: what might be the efficiency of some multi-bay FM and TV antennas (in mV/m @ 1 km for 1 kW)? And what would be the efficiency (for 1 kW) at 540, 1120 or 1600 kHz (and is there a relatively easy way to "interpolate" for other frequencies?) for an antenna that is functionally compliant with 15.219 (b), using a few different types of grounds from the full 120x 90-degree radials, down to no ground at all?

Of course that's not quiiiite as good of a signal as what most non-DXers would want to listen to (if I'm understanding David Eduardo correctly when he references listening within the 10-15 mV/m contour in major markets), but if it's still that good at a little over 180 miles even with such low power in that direction, wouldn't it be pretty clear by the time you get to within 100 or 80 miles or so? What LPFM stations can be reliably heard at that distance (unless their transmitter is mounted on a 2000-foot tower atop a 14,000-foot mountain with the plains all around below sea level, and you yourself are on another 14,000-foot mountain listening on a XDR-F1HD or PL-390)?

 

[Chuck]

If you look around, you'll find a lot of small AM stations that can be purchased for very reasonable prices. Way less than the price of a modest house and sometimes for as little as what you'd pay for a well equipped car. Some are even in rated markets. Usually, they are in a bad state of repair with equipment that would charitably be referred to as "vintage," but they can be fixed. It just takes someone with the determination and vision to bring them back. You won't get rich, but if serving a community is your desire, then they are another possibility.

 

[druidhillsradio]

A small AM station here is $450,000.

 

[Chuck]

You may have to move to a different community, but I know of one AM within 75 miles of me that recently sold for under $50,000. That community has an Interstate highway running past it and has a couple of major tourist attractions. There are lots of small stations for sale in the $100,000 range. Keep in mind that these are usually distresed properties. Real Estate people would call them "Fixer-Uppers," but that doesn't mean they couldn't be turned around.

 

[FreddyE1977]

A 1kW station just sold here on the edge of Pittsburgh, covering much of a #24 market, for $75,000.

 

[Chuck]

A 1kW station just sold here on the edge of Pittsburgh, covering much of a #24 market, for $75,000.

You should be able to make some money with that. It just depends how dedicated you are. Sweat equity could turn it around.

 

[KeyTimes950]

A 1kW station just sold here on the edge of Pittsburgh, covering much of a #24 market, for $75,000.

It was a reported letter of intent to buy WLFP, not an agreement to sell the station. And, as it turns out, that may have fallen through. From the Sept. 10 McKeesport (PA) Daily News ...

(Terry Lee) said he did not sign a reported letter of intent to buy WLFP-1550 in Braddock for $75,000. Business Talk Radio CEO Michael Metter denied selling AM 1550.
“We are still there and we are still on the air,” he said, questioning interest in a “cockamamie” station like WLFP, which he earlier offered for $225,000.
“If anyone wants to buy it, they can buy it,” he added.
“Not counting the real estate, the license is worth $50,000 with the basic equipment,” said Pittsburgh broker Ray Rosenblum, who isn’t involved with WLFP.
• Metter was indicted in August 2010 by a Brooklyn, N.Y., federal grand jury on securities fraud charges tied to his role from 2001-07 as CEO of Spongetech Deliv­ery Systems Inc., which allegedly faked 99 percent of its sales.
The Securities and Exchange Commis­sion froze BTR accounts and other Metter assets, but approved a BTR thaw through Sept. 30 provided that Metter “relinquish all authority, including signatory author­ity,” over BTR.
Much of the government case against Metter reportedly was tossed out in May by Brooklyn U.S. District Judge Dora Irizarry because prosecutors took too long to review evidence seized at his home.
Metter still faces oral arguments before Irizarry Nov. 9. Six co-defendants have plead guilty and/or been sentenced.

 

[Carmine5]

A 1kW station just sold here on the edge of Pittsburgh, covering much of a #24 market, for $75,000.

You should be able to make some money with that. It just depends how dedicated you are. Sweat equity could turn it around.

Exactly. The RW article on Ben Downs and his small market AM stations is great. He basically said forget the large footprint signal, super serve the community, talk about things that interest them, get involved in events like food drives, parades and charity functions, join organizations local businesses are a part of. It's a lot of work but his stations are growing in revenue. The advantage of small market radio, according to Ben, is that local businesses can actually afford to advertise on your station. Plus the local flavor of the station will set it apart from Pandora.