Thanks to curious loopholes in the FCC’s FM licensing rules, several religious broadcast companies have created national networks on the cheap using low-power, mostly-automated FM transmitters. Using their intimate familiarity with FCC bureaucracy, these companies also engage in spectrum hoarding and speculation.

The practice of spectrum speculation is nothing new, it’s a kind of side-industry in the broadcast business. Although they very seldom actually build a radio station, speculators apply for and acquire radio station construction permits and then sell them to the highest bidder. Channel spaces on the FM dial are a finite commodity – where supply is low and demand high a savvy speculator can make quite a bit of money if they have permits to build radio stations in growing markets.

Mounting evidence suggests that some religious broadcast companies, which are ostensibly non-commercial and listener-supported, are manipulating the FCC’s licensing system for profit. Doubly damning is the fact that the spectrum being monetized could have provided thousands of opportunities for low-power FM community radio of the truly local kind. Indeed, these same speculators also manage to benefit from the LPFM proceedings – turning stations intended to be live and local into gospel rebroadcasters.

It is not clear if rules have been broken here: that is something best left for the FCC to say. Hopefully, it will say something soon, because this entire ungodly saga is about ready to consume what precious little access remains to the FM dial.

The Translator Station

What makes religious radio networks like Calvary Satellite Network, American Family Radio, and EMF Broadcasting such effective mass media platforms is the fact that they do not own and run many full-power FM stations. Full-power FM stations are also full-service stations, meaning they require local staff and constant attention. Instead, religious broadcast networks employ what are known as FM Translator stations. Translators are a special class of FM radio station: they are limited to a maximum broadcast power of 250 watts or less and by law may only rebroadcast another program source.

The FCC’s translator station rules were initially designed (in 1970) to assist those FM stations which, in certain circumstances (mostly terrain-related), needed more than one frequency to serve their primary coverage area. Commercial translator stations usually sit near the fringe of a main station’s signal. They are not much more than a transmitter and antenna plugged into a radio receiver tuned to the parent station.

In 1990 the FCC made major amendments to the FM translator service rules. One big change allowed non-commercial broadcasters to operate translator stations independent of any parent station (aka satellite-fed).

This provided a lift for a few community radio stations and many public radio systems, which applied for FM translators as a way to extend their service areas cheaply. Since translators are simply repeaters of another signal, they cost little to install and maintain. Sometimes a local benefactor will pick up the expense of installing and maintaining a translator.

Religious broadcasters exploited the economic poential of this rule change most effectively. Evangelists, especially, saw the light. Several flavors of Christian radio network now flourish, ranging from the Roman Catholic to the Southern Baptist. Most consist of one or two full-power FM stations somewhere, uplinked via satellite to a growing chain of dozens or hundreds of translator signals.

Success is a self-fulfilling prophecy: more translators increases the reach of one’s evangelism, attracting more faithful who provide more support. Then it’s just a matter of investing returns in growth. A translator station more than pays for itself over time; this is guaranteed if startup and/or maintenance costs are pre-paid.

The myriad “godcasters” in existence worship the same Jesus but in widely varying ways, although many share a special bond: a knack for mastering the FCC paperwork jungle.

Sampling the Translator-Mongers

Ever since FM translator station proliferation became a growth industry some 15 years ago, religious broadcasters have, by far, exploited the resource in a way that must be very fulfilling to those who place special importance on evangelism. Compared to the billion-dollar world of mainstream commercial radio, religious broadcasting is small potatoes, although its annual “commerce” certainly ranges in the tens of millions of dollars. Someone has yet to do the legwork to sketch out “the industry” and its size and scope.

But religious broadcasting as industry undoubtedly exists, and three examples are illustrative. EMF Broadcasting, the most mainstream of the three, is the mainstay project of the Educational Media Foundation. Using full-power FM stations in California, EMF feeds two Christian music formats to nationwide networks of translators. The first, K-LOVE, is a contemporary format carried on more than 100 translator stations in some 40 states. The second, AIR-1, is a more youth-oriented “alternative” format. It can be heard on more than four dozen translators in two dozen states. AIR-1 was actually an acquisition EMF made in 1999 – a move whose brainchild was EMF President Dick Jenkins, the 19-year veteran orchestrant of EMF’s expansion.

Theologically, both EMF networks carry themes of reaching out to heal people through positive, uplifting entertainment. The primary point of each network’s statement of faith/belief is that the Bible is the “infallible and authoritative Word of God,” although the point is to teach this without being preachy. It is safe to call these networks major arteries when it comes to circulating the lifeblood of Christian evangelist popular culture.

Year-to-year financials provided by MinistryWatch and Charity Navigator bear out EMF’s fiscal success. From revenues of $18.2 million in 2000 to $40.9 million in 2003, it nearly doubled its profits over the period. Those have probably crested the $10 million mark by now.

Another flavor of religious broadcasting is American Family Radio, a subsidiary of the American Family Association conglomerate. AFN feeds “Christian Classics” and contemporary music from a full-power station in Tupelo, MS to more than 170 translators in 28 states, with affiliate (unowned) stations extending the network’s reach into four more. Tower space rental is also part of the AFR business plan.

The American Family Association is one of the most powerful religious lobbies in the country. Activism lies at its roots. Its inaugural project was a media watch division and only in 1987 did the media production begin, which now includes a news division.

American Family Radio’s “about us” page begins thusly: “BACK IN 1987, THE VISION GOD gave the American Family Association Founder, Don Wildmon, was to use satellite and the latest technology to build hundreds of American Family Radio stations across America.” The Association’s “about us” page notes, “Don Wildmon and other AFA personnel have appeared on programs such as Good Morning America, The Today Show, MacNeill Lehrer Report, Nightline, The 700 Club, Meet the Press, Crossfire, and Focus on the Family.”

AFA is convinced popular secular culture is the bane of America and are doing everything they valiantly can to hold back the forces of darkness, which include most anything rampantly leftist or gay. This includes demonstrating a propensity for frank biblical fundamentalism.

The financials for the American Family Association (of which AFR is a part) show it moving from a half-million dollar operating deficit in FY 2000 to a 2003 profit of nearly $2.3 million.

Our third and final religious broadcaster of interest is the Calvary Satellite Network, headquartered at the Calvary Chapel church of Twin Falls, Idaho. CSN was launched in 1995 and has demonstrated the most explosive growth of any religious broadcast network: it is now heard on more than 350 stations nationwide, with several stations supported by individual Calvary Chapel churches. Additionally, CSN/Calvary Chapel Twin Falls filed a petition for rulemaking with the FCC in 2002 asking for further expansion of satellite-fed translator stations (no action has been taken).

Its blend of “Solid Bible Teaching and Passionate Praise and Worship” underscores the evangelist message; the Calvary Chapel theologic “brand” is positioned as non-denominational. The network’s home page contains a link to “CSN Partner” Prohpecy Update which provides “Prophecy News for the End Times.”

Interestingly, Calvary Chapel is not listed as a charity in the research tools used here. The web site for Calvary Chapel-Twin Falls used to be a directory off the de facto “main” calvarychapel.com portal. That page is missing now and a replacement does not seem forthcoming. Additionally, Calvary Chapel-Twin Falls is not listed in calvarychapel.com’s nationwide directory.

Religious broadcast executives don’t necessarily believe in poverty. The perks of righteousness are somewhat unquantifiable.

Evangelizing on LPFM

Recognition of religious radio’s sophistication set in following the FCC’s low power FM rulemaking in 2000. The agency opened a series of five-day application windows for interested potential LPFM licensees, in groups of states staggered by date. According to the good people at REC Networks, who have a long history mining the FCC’s licensing databases in support of LPFM policymaking, of the 3,223 LPFM license applications that were filed in the first round, approximately 560 of the 620 stations approved are now on the air.

Depending on whose estimate you believe, religious broadcasters account for anywhere from 1/3 to 1/2 of all LPFM stations. Many are independent, local churches that truly hope to be positive voices in their communities. But LPFM policy was also a point of concerted study at a regional radio convention in 2003.

Calvary Chapel churches applied for LPFM stations in droves. The FCC ended up throwing out several applications after questioning their “local purpose.” Still, Calvary Chapel churches have at least two dozen LPFM stations licensed in their collective name today.

On the flip side, EMF Broadcasting launched a petition and publicity drive in protest of unsubstantiated “threats” of interference that LPFM stations would cause its translator networks (many of which operate with more than twice the power of the most powerful LPFM station).

2003: The Great Translator Invasion

As with the LPFM application filing windows, the FCC does not accept FM translator station applications at random. In fact, in order to introduce the LPFM service the FCC deferred opening windows for new FM translator station applications. This most definitely put a crimp in religious radio’s growth mode.

Inexplicably, the FCC decided to open a short filing window for new FM translator stations in March of 2003. It was whomped with more than 13,000 license applications. Had the FCC approved them all, it would have doubled the number of licensed radio signals in the U.S. overnight.

A spectrum land-rush was on. It was a logical development: before the FCC introduced LPFM, the only low-power radio station game in town was the FM translator. LPFM stations represented competition for cheap yet effective access to the airwaves. The invasion of translators was designed to crowd out LPFM stations.

Of the 13,000 applications filed, more than one-third were traced to four organizations. Two were familiar: Calvary Chapel (and its derivatives) accounted for 385 translator applications while Educational Media Foundation filed 875. The two largest filers, however, were unknowns: Radio Assist Ministry (2,454) and Edgewater Broadcasting (1,766).

The plot thickened when it became known that Radio Assist Ministry and Edgewater Broadcasting shared mailing addresses – in Twin Falls, Idaho, home of the Calvary Satellite Network.

CSN Programming and Music Director Don Mills publicly disavowed any connection between CSN, Calvary Chapel of Twin Falls, and the two mega-applicants. Wrote Mills:

CCTF and CSN INTERNATIONAL have been unfairly lumped together with the LPFM stations. WE HAVE NOTHING TO DO WITH THEM. We did not file for them and we are not in contact with any of them. We have also been accused of filing for 4,000 commercial translators which we, DID NOT DO. We did file for just under 400 of which we won’t get near that many. One reason I think we have been lumped together is because we did have an employee who worked for us 3 years ago and he has started his own business. He has started Radio Assist Ministries, Edgewater Ministries and World Radio link.

That was 10 months ago.

Speculation and Shadow Corps: REC Networks Strikes Again

The former employee of Calvary Satellite Network – the individual presumably behind Radio Assist Ministries and Edgewater Broadcasting – certainly learned the rules of translator application-filing well, as the two companies with a single address tendered more than 4,200 applications during the 2003 filing window. A clear sign of spectrum speculation: unknown companies with no prior broadcast history flood the system with requests for channels.

The sheer number of applications filed guarantees some success. So far the Edgewater/RAM duo have been granted more than 1,000 construction permits for FM translator stations around the country. Another 2,300 applications are still pending – it’s highly unlikely all will be approved, but the take from the leftovers won’t be shabby.

Now the mastermind behind Edgewater/RAM has begun to cash in on the hoarded station permits. According to Pete triDish of the Prometheus Radio Project, a “rate card” of sorts exists listing the going price for translator channels for sale around the country: “they generally sell them for about $6,000 for very rural areas; medium-areas they sell them for $10,000; and slightly more populated areas they go for $14,000 a piece.”

In a recent sample of FCC database information collected as part of a special tool set up specificlally to track the Edgewater/RAM translator-trafficking, REC Networks listed the results of 83 station construction permits changing hands. Many of them had been sold, netting the Edgewater/RAM cartel total revenues of $803,000.

The biggest deal of them all involved three listed transactions totaling $326,500, which paid for 26 FM translators in Florida. REC’s data lists the buyer as “Reach Communications (Calvary Chapel Church, Inc.).” The second-largest group deal involved 20 translator permits in California, Oregon, and Washington, sold for $219,000. REC’s data lists the buyer as “Horizon Christian Fellowship.” Horizon is a well-endowed group whose founder came to Christ through a Calvary Chapel church in California. Not only does the Fellowship appear to be loosely structured around Calvary Chapel-style theology, but Horizon also has a budding radio network with links to the Calvary Satellite Network (aka Twin Falls).

Other interesting translator permit purchasers include Laramie Mountain Broadcasting, the owner of some commercial stations in Wyoming; something called “Airport Investors,” which dropped $31,000 for translators in three northeastern states; and the American Family Association which ended up getting some free translator permits out of the windfall.

Conclusions and Implications

Religious broadcasting has exploded in the last 15 years, thanks in large part to the FCC’s 1990 decision to allow non-commercial broadcasters the ability to feed FM translator stations via satellite. This rule opened the door to low-cost national radio networking, which religious groups have, by far, exploited most effectively.

LPFM directly interfered with the growth of networks based on FM translator stations.

At least one religious broadcast company, Calvary Chapel, attempted and partially succeeded in assimilating LPFM stations into an FM translator network.

Calvary Chapel is not a monolith but the majority of broadcast activity is conducted and coordinated from Calvary Chapel of Twin Falls, Idaho. This entity has applied for both LPFM stations and translators, applications summing into the hundreds.

A former employee of Calvary Satellite Network went into business under multiple corporate names, two of which are Edgewater Broadcasting and Radio Assist Ministries. This was reported by CSN’s own Program and Music Director in a 2004 e-mail denying allegations of collusion for the purposes of spectrum speculation between the Twin Falls-based parties.

Edgewater Broadcasting and Radio Assist Ministries applied for more than 4,000 translator construction permits and to-date have been awarded more than 1,000. Of these, Edgewater/RAM sold or transferred at least 83. Total revenue generated to Edgewater/RAM from these transactions is $803,500.

About half of the translator construction permits sold by Edgewater/RAM went to other Calvary Chapel-affiliated organizations; these deals accounted for more than half the revenue Edgewater/RAM generated for itself.

One of these notable transactions involves what appears to be a shell company (Reach Communications) purchasing the permits for 26 FM translator stations in Florida. The shell company appears to be working on behalf of Calvary Chapel Twin Falls (Calvary Chapel, Inc.). If true this contradicts CSN’s denial.

Other notable religious translator networks will also benefit from this translator filing window. EMF Broadcasting applied for more than 800 construction permits. If it were awarded even half of them that would be enough to effectively double the company’s reach.

Navigating the FCC’s plethora of databases is time-consuming and complicated. Evidence of spectrum speculation exists, hopefully REC archives well its ongoing find. Monitoring the speculation’s progress may shed light on the way religious broadcasters jockey for position to maximize their evangelistic opportunities.

Even with a small data sample one can make some startling speculative calculations. For hypothetical purposes, let us low-ball the average worth of each FM translator construction permit held by Edgewater Broadcasting and Radio Assist Ministries ($5,000). The permits the two already own are worth an estimated $4.7 million. Another 2,000+ translator applications are pending: if just half come through Edgewater/RAM doubles in value.

At the very least, the FCC’s licensing system is being played like a well-crafted instrument by people who monetize spectrum that otherwise would have been used for real community radio. At the very worst, active collusion is occurring among religious media corporations bent on dominating swaths of FM radio spectrum while profiting in the process.

There is an obvious need for the FCC to pay closer attention to the grinding of its own bureaucratic wheels. An FM translator filing window should not have been opened until after the LPFM applications had been dealt with – unless the agency’s actual intent all along was to purposely pollute/dilute LPFM’s potential growth. The sheer volume of applications received should have set off an alarm or two within the Media Bureau and the shady nature of some of the entities involved should have prompted a rudimentary investigative response.

Whether or not the translator station invasion can be mitigated or reversed is unclear. Edgewater/RAM will not dally in trying to move its inventory of construction permits. The longer one languishes the more likely it is that someone may come along and file a competing (LPFM) application for the channel. Additionally, a rulemaking in development at the FCC and legislation pending in the U.S. Senate offer the possibility of carving out spectrum for more LPFM stations. This chance increases dramatically if the policy change involves granting real community radio (LPFM) stations primacy over FM translator stations.

That such a dilemma stems from some who claim to speak with/for Jesus makes him cry instead.