been a busy man (again). He's part of the National
Lawyer's Guild Committee on Democratic Communications, and he's
going through all of the comments filed so far during the FCC's ongoing
LPFM rulemaking machinations. While this list in no way is meant
to be a complete overview of who's saying what, it is a good snapshot
in how the two sides are arguing their case.
Last week, we heard from our friends. Now the foes sound off -
judge for yourself whether the arguments are worthy.
I have summarized about
100 of the comments received by the FCC in the microradio proceeding.
I believe there are about 150-160 total. While I went through them fairly
randomly, I think I got more of the in favor than opposing. Therefore,
when I post the complete summaries, there will probably be a lot more
in opposition. I am posting a partial list for those who might want
to start looking it over now. I have decided to group them by state.
The following comments
OPPOSE microradio (note: some of the comments do not completely
oppose microradio, but express serious concerns or reservations.)
Unknown or Multistate or Attorney Location Only given
--National Association of Broadcasters.
Inefficient user of spectrum, interference, interfere with IBOC, consolidation
has not affected diversity. Audience is mobile, stations serving
small areas would be ineffective. Alternatives exist: find time
on full-power stations, apply for public radio license, Internet. Would
worsen "pirate" problem. Administrative nightmare for FCC.
of State Broadcasters Associations. (43 State Associations plus D.C.
and Puerto Rico.)
LPFM service would be technically inferior, would give a "microphone
and transmitter to virtually anyone who wanted one," "makes
a mockery of the word 'broadcast'", creates "CB-ization"
of radio. No public service obligation on LPFM. Result in catastrophic
enforcement problems for FCC. Broadcasters already provide sufficient
local service. Consolidation has led to improved programming and facilities
to the public's benefit. Absentee ownership does not detract from ability
to provide local service. LPFM assertions of need or utility are unsupported
and just the personal complaints of "hobbyists". Administrative
nightmare for FCC. LPFM programming will be redundant, or sporadic.
Economic fragmentation will most hurt small, independent, local full-power
broadcasters. LPFM will demand power increases, transmitter height increases,
etc. and inch their way to becoming full-power. Interference to full-power
broadcasters and aviation. "Pirate" radio will increase. Will
impede digital radio.
Congestion, interference, impede IBOC. Proposals lack specifics; regulation
would be complex; administrative nightmare for FCC. No guarantee that
LPFM would actually accomplish the goals stated: stations are too small
and technically inferior to gain significant audience. Alternatives
available such as Internet. Unless stations are non-commercial, competitive
auction necessary. Also, 1996 Act removed national ownership limits
on commercial radio stations and liberalized local limits.
and Virginia Broadcasters Associations.
Interference, administrative nightmare for FCC, impede digital radio,
FCC will have admitted that it cannot police pirate radio "miscreants",
no evidence that "minority" or "diverse" viewpoints
will actually be served. Recent court ruling makes questionable policies
specifically aimed at creating specific benefits for ethnic minorities.
Major developer of In-Band On-Channel (IBOC) digital radio systems.
Partnership of CBS and Gannett. Does not oppose microradio in principle.
Is very concerned about potential interference impact of microradio
on future combined digital/analog signals. Suggests freeze on microradio
proceeding until IBOC implemented and actual interference effects can
Group Radio Station Owner. Interference, IBOC. No real economic opportunities
in micro-radio. Alternatives like internet exist. Will encourage pirates.
- Interference. - Financial fragmentation, especially of minority and
Crowding and interference, inefficient use of spectrum, administrative
nightmare for FCC.
--KLAM/KCDV Radio (J.R. Lewis).
Economic competition from LPFM will destroy small, independent, local
stations in small towns.
Station owner, media broker. Alternatives are available: cable
TV public access, Internet, public radio, leasing on commercial stations.
Interference, FCC administrative nightmare, IBOC problems, economic
fragmentation. Might support re-establishment of 10 watt service in
FM non-commercial band with strict local ownership.
Owns a chain of, apparently, religious stations--2 AM, 14 FM, 24 translators.
Interference. 1 watt stations would be useless. If LPFM is initiated,
wants to be sure current translators are protected. Does not appear
to completely oppose microradio, only has a number of concerns, esp.
re FM translators. Supports event broadcasting and concept of local
(Owns one radio, 2 LPTV, 2 radio apps pending.)
LPFM would be inefficient use of spectrum, economic disaster for stand
alone FM and AM stations, there are opportunities to purchase small
market radio stations, would not create new jobs. Stations currently
provide local programming. If such a service is allowed it should
be locally owned and one to a licensee. No cross-ownership with other
media. Should be similar to FM translator service. If service implemented,
AM stations that cut power at night should have first opportunity.
--Robert L. Caron. (GM of 3 station" cluster").
Interference, administrative nightmare for FCC, no demonstrated need,
emergency action system (EAS) interface, not a constitutional violation,
rewards "pirates", public radio, college stations, cable TV
public access provide alternatives, interfere with IBOC.
AM and FM too congested, integrity of spectrum, couldn't afford to pay
FCC, ASCAP, BMI fees, etc. Will become like CB radio. Economic competition
will harm independent full-power stations. FCC administrative nightmare.
--Kurt Tuckerman, Sandyworld. IL.
Small station and translator owner. Many concerns having to do with
commercial competition, non-local programming.
--Kevin Lange. Broadcaster.
Lambasts Skinner's RM-9242 for a large variety of reasons and questions
Skinner's personal motivations. But doesn't appear to necessarily oppose
LPFM in principle.
--Southern Minnesota Broadcasting Co. (9 radio stations).
Interference to both full-power radio stations and aviation.
--New Jersey Broadcasting Association.
Interference, FCC administrative nightmare, pirates will continue anyway.
Broadcasting, Inc. (4 radio stations).
(3 radio stations).
Interference, administrative nightmare for FCC. No guarantee that "diversity"
or "minority" goals would be achieved. Internet provides an
--Luna County Broadcasting. (2 radio stations).
Interference, enforcement nightmare, no demonstrated need, "pirates"
will increase. "What's to keep militiamen, religious fanatics,
drug culturists, alternative life stylists, and various and assorted
crackpots, hucksters, and con artists from taking over the new service?
Pirates are "ego driven". LPFM will not be able to provide
adequate services, will cause marketplace confusion, we lead to a host
of administrative problems and discrepancies.
--Oregon Association of Broadcasters.
Interference, rewards "pirates", administrative nightmare
for FCC, no required "public interest" obligations, financial
calamity, especially for full-power stations in smaller markets.
Area Radio Council. (22 Portland area broadcasters.)
Interference with full-power radio, aviation, cell phones, emergency
services. No need, local community is well served. Will reward
"pirates", FCC administrative nightmare, no public interest
obligations, economic "chaos and calamity".
--KVST-FM Radio (Benjamin Amato).
Financial disaster for small, independent station in small town (Conroe,
--WJLS (AM/FM) (William O'Brien).
Interference, "every Tom, Dick, and Mary will want to be the owner
of their own station", Administrative nightmare, economic fragmentation.
Local service is being provided, no "need" for new service.
National Lawyers Guild Committee on Democratic Communications (CDC)
558 Capp Street
San Francisco, CA 94110