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5/2/99

June first is the deadline for the public to file comments on the FCC's proposed LPFM rulemaking.  Comments must be received in Washington, D.C. by August 2. So, for all intents and purposes, you've got less than a month and a half to make yourself heard.

You can talk all you want about how wonderful legal LPFM is to your friends, family and co-workers, but unless you file formal, public comments with the Commission, the people that need to hear your opinions won't - and all you'll have done is spout hot air.

The following is a primer into how to file comments - what you write is up to you, and if you need help figuring out what to say feel free to browse through previous features; there's more than enough food for thought there.

What to Say
How to Say It
How to File

What to Say

While this is a formal rulemaking proceeding, what you write doesn't need to be lengthy or detailed.  However, it does help if you sit down and compose what amounts to a short letter (maybe half a page to a page or so should do it well). Think of it this way - if you can think of five reasons why legal LPFM should be created and how the service should operate, and you can put each one in a sentence, that's all you need.

You don't have to be a technical wizard or know the radio business inside and out in order to file, either. What is most important, actually, is that the FCC get a good feel for just how disenchanted people are with the current state of radio and what we'd like to see changed. What the FCC needs to know right now is that the public, in general, is aware of and in support of LPFM; if enough people make their voices heard loud enough, the FCC will take care of the technical end in a way to make it happen.

Talk about what you envision an LPFM station doing where you live. Come up with examples. Maybe like what a church, school or community group could do with expanded access to the airwaves. Most importantly, tell the FCC why you would listen to the radio more if an LPFM station went on the air in your area. If there's already an LPFM station broadcasting in your area, and you listen to it, tell the Commission why you chose it over the "traditional" broadcast outlets available.

Scan your radio dial, and notice all of the changes that have taken place over the past three years.  Think back to when "your favorite station" used to play good stuff, or reminisce about when it was like before they changed formats. Whatever happened to your favorite personality? Did he or she get replaced with a "jock in a box," like syndicated programming? Call your local stations and ask them how many are in their radio "group" - when I worked for a Madison station, many didn't know it was one of five the "group" owned in Madison, accounting for about a third of all the stations in the city. Get a feel for just how consolidated the market you live in is.

Support all three classes of proposed LPFM station - from 10 to 1000 watts. Talk about the area in which you live - how big it is geographically and population-wise. Think of what your area might need - remember, LP-10 stations would cover about four miles, LP-100 about seven miles, and LP-1000 about 18 miles of flat terrain.

Push for strict ownership rules and local-programming requirements. Without these, the big broadcast companies could come in, apply for all available LPFM frequencies, and syndicate their programming on all of them, creating what amounts to a smaller-size version of the status quo. One station, one owner rules are optimal; as far as local programming goes, there is no hard-and-fast recommendation, although think about what you'd rather hear - would it rather be a local music concert or political debate, or trash talk from New York? (no offense to New Yorkers intended) (up)

How to Say It

What's most important here is that you use your legal name and address. Hundreds of anonymous comments were thrown out by the FCC when it was considering the original ideas which led to this proposed rulemaking. If you're not willing to put your name to your own ideas, then nobody needs to hear from you.

It's just like speaking at the local city council or county board meeting - Those in charge will take what John Anderson has to say more seriously than what "Dog Breath" does.

Preface your remarks by telling the FCC a little about yourself - whether you're a high-powered corporate executive or a housewife, let them know. One of the things the NAB would like the FCC to believe is that those pushing for LPFM are radio "pirates" who, for the most part, are lawbreaking rabble-rousers with no sense of responsibility or civic duty. Tell them otherwise. Even try to tie it in to why you're in favor of LPFM.

Chairman Kennard has touted LPFM as a way to bring the "community" back into broadcasting. If he can get a feeling of just how widespread support is for the proposal, that gives his argument more weight. With a tie vote pretty much already a done deal, and one commissioner who appears to be undecided on the issue, strengthening the argument of the Commission's chairman is something we want to do right now.

Speak rationally. While you may have a theory that all large corporations, broadcast included, are owned and controlled by a secluded bunch of monks in the Grand Caymans ultimately bent to reshape the world in their image, the FCC is not looking at such a big picture.

Please also refrain from anti-NAB epithets, like "air hog," "corporate bloodsucking money-hungry bastards," or even the simple "scum." However, a few diplomatically-worded jabs might not hurt, as long as you can provide proof. Remember, you're writing to provide support for something, not oppose someone.

And remember what they taught you in kindergarten - a smile goes a much longer way than a frown!

Finally, use common sense - write in logical, complete sentences. You don't have to spice it up with legalese like "forthwith," "heretofore" or "per se" - just write in a way that gets your point across the most rationally. After all, while we are dealing with the government here, they are people, too. (up)

How to File

There are different ways to file comments with the FCC. While some are as simple as point-and-click, the ones that take a little more time and effort to file carry more weight. This does NOT mean that everyone has to file printed copies by mail, but it is something to think about, depending on how strongly you feel about LPFM.

First of all, EVERY comment MUST include your legal name, address and the FCC Docket Number (for the LPFM proposal it is MM 99-25) for it to be placed "on the record." What comes after that is up to you.

The most simple way to file comments is via e-mail. Simply click here and follow the very basic instructions. They even have an example!

Secondly, you can file via the web, using the FCC's Electronic Comment Filing System (ECFS). This involves a little more effort (essentially filling out multiple government "cyber-forms"), but is better than simple e-mail.

The most formal way, and the way which will provide the most impact, are with "written" comments. This involves filing hard copies of your comments under the FCC's formatting rules. Make ten copies of your comments and mail them to:

Office of the Secretary
FEDERAL COMMUNICATIONS COMMISSION
The Portals
455 Twelfth Street S.W.
Washington, DC 20554

Remember, these must be in the FCC's mailbox by August 2, not postmarked by then!

PLEASE don't get me wrong - ANY way to file comments is fine! It's just important that your voice be heard. It sounds like a cliché, but it can't be helped. Take a couple of minutes before surfing along to change the face of radio. You've got nothing to lose and some of your lost rights to gain.  (up)