While the proliferation of FM translator stations by religious broadcast groups arguably constitutes spectrum abuse, it’s just one perspective on a larger problem. Religious broadcasters are not only snapping up translator channels on which real community LPFM stations might have been sited, they’re also engaged in LPFM broadcasting.

A recent SF Chronicle story illustrates how Calvary Chapel organizes LPFM station affiliate growth:

This month, the Calvary Chapel Radio Ministry of Costa Mesa in Orange County hosted 170 mostly Christian low-power broadcasters, offering them operational tips as well as up to “16 hours per day, seven days a week” of programming beamed in via satellite, according to its Web site.

Paul Riismandel @ Mediageek notes the clever structure of the Calvary Chapel “church,” which I alternatively call a “brand.” Ministers individually receive permission to use the “brand” and then set up their own Calvary Chapels. Paul further notes that the Calvary Chapels in Costa Mesa and Twin Falls are publicly linked as working together via the Calvary Satellite Network (CSN International). Decentralized control, Paul surmises, gives the “brand” as a whole plausible deniability when one segment of the Calvary Chapel radio empire appears to engage in unethical behavior.

The situation is even more complicated than that. The Calvary Chapels of Costa Mesa and Twin Falls appear to have, at the very least, sparked a trend that other Calvary Chapels now seek to emulate: radio broadcast market penetration by brute signal proliferation. Questions remain, however, about the relationships between the facilitators of this trend and the various Calvary Chapels involved.

New Calvary Networks Share Similarities

Neither Calvary Chapel of Twin Falls nor Calvary Chapel of Costa Mesa were involved in the controversial $326,500 sale of some two dozen FM translator stations in Florida. These were sold by the Edgewater Broadcasting/Radio Assist Ministry cartel to “Reach Communications (Calvary Chapel, Inc.),” which references Calvary Chapel of Fort Lauderdale.

Thus Calvary Chapel of Fort Lauderdale initially purchased the translator permits from Edgewater/RAM. It then transferred the permits to “Reach Communications, Inc.” According to an FCC filing reflecting the transfer of control,

CALVARY CHAPEL CHURCH, INC. (CCC), PERMITTEE OF THE REFERENCED FM TRANSLATOR STATIONS, WISHES TO ASSIGN ITS RIGHTS TO A COMMONLY-CONTROLLED NON-STOCK ENTITY, REACH COMMUNICATIONS, INC.(RCI). AS SHOWN IN THE OWNERSHIP EXHIBIT INCLUDED IN THIS APPLICATION, THE BOARD OF RCI CONSISTS OF 10 OF THE 14 MEMBERS OF THE CCC BOARD….

Reach Communications, Inc. is also the holding company for full-power WREH-FM in Fort Lauderdale. This 100,000-watt station is otherwise known as “ReachFM.” It is a new station, on the air only since late last year (following Florida’s rough hurricane season). According to the station’s web site, The “Pastor of the Month” is Bob Coy, founding pastor of Calvary Chapel of Fort Lauderdale, and presumably the same Robert J. Coy whose name is listed on the FCC filing as president of both entities involved in the multi-translator transfer.

Also prominently featured on the ReachFM site is a “Coverage Map” showing the signal reach of WREH supplemented by little circles all over the state of Florida (it is unclear just which circles have already been acquired and which are simply coveted). The map is explicitly marked, in bold yellow type, “2005-06 EXPANSION.” Calvary Chapel of Fort Lauderdale is undoubtedly positioning itself to become a statewide player in the religious radio market niche.

Similarly, the San Diego, California-based Horizon Christian Fellowship also purchased a turnkey radio network ministry from the Edgewater/RAM cartel, involving FM translator construction permits in California, Washington, and Idaho. A March 2004 document outlining the payment protocol for the deal notes that Horizon Christian Fellowship’s president (and founding pastor) Mike MacIntosh put $49,500 down for “options” on 18 translator construction permits, with the remainder payable within 10 days of the FCC’s rubber-stamp approval of the sale.

According to FCC information this transaction was completed in July. While none of the documentation clearly identifies the total value of the transactions REC Networks puts it at $219,000. Horizon Christian Fellowship seems to be a “meta-chapel” with definitive links to the Calvary Chapel brand. It also runs a budding record label: a great compliment to any radio network.

Players Identified

Calvary Chapel-affiliated entities bought FM translator construction permits from Radio Assist Ministry/Edgewater Broadcasting, and Edgewater/RAM is comprised of alumni that once worked for Calvary Chapel of Twin Falls. This does not constitute active collusion between all the Calvary Chapels with regard to development of their radio ministries. However, the Calvary Chapels are replicating similar models of signal proliferation around the country, which strongly suggests they communicate strategically.

A couple of people most likely know the whole truth. The first is Clark Parrish, whose name is listed on FCC-filings as president of Radio Assist Ministry and Edgewater Broadcasting. He has also been previously identified as a representative of the group.

The second, more promising key to these schemes is Harry Martin. He is an attorney with Fletcher, Heald & Hildreth, “a Washington, DC area full-service communications law firm.” It is safe to call FH&H one of the major-league communications law firms in the U.S., and one positioned well-inside the Beltway. Mr. Martin is listed on FCC documents as the contact representative for both Horizon Christian Fellowship (CA) and Calvary Chapel of Fort Lauderdale (FL). He represents a direct link between transactions involving Edgewater/RAM and at least two Calvary Chapel-affiliated radio projects.

Harry Martin is no run-of-the-mill telecoms lawyer. He’s president of the Federal Communications Bar Association – the primary trade group of sorts for “attorneys and other professionals, including engineers, consultants, economists, and government officials…involved in the development, interpretation and practice of communications law and policy.”

The plot thickens.

Full-Power Plays

The Calvary Chapel spectrum development occurring in Florida also highlights a heretofore unrecognized dimension to the collective Calvary Chapel broadcast empire. The proliferation of Calvary Chapel radio stations is not just limited to the FM translator and LPFM station-classes. CSN International alone claims to own and operate more than 30 full-power radio stations in 17 states.

This list does not include applications (some pending, some granted) to the FCC for new full-power radio stations, of which there are several. One of them came to attention recently when a volunteer journalist working at WZBC, the 1,000 watt FM station at Boston College, discovered that Calvary Chapel of Costa Mesa had applied for and was granted a construction permit for a full-power station that will be located just one channel away from WZBC on the FM dial. The permit was initially granted in April of 2003; there is no signal on the air yet.

The 21,600-watt station, assigned the call letters WSMA, meets FCC interference protection requirements because it will be located in a community south of Boston and will use a directional antenna pattern to aim its signal toward the Boston metro area in rimshot fashion.

Those who enjoy WZBC outside of its relatively small primary (and protected) coverage area – a station that also happens to be a very lonely community radio voice for a market the size of Boston’s – will find it more difficult to hear through WSMA’s signal (21.6 times stronger) parked next door on the dial.

WZBC only recognized a problem existed when Calvary Chapel filed a petition last month to waive the main studio requirement for WSMA. This implies that any new full-power FM station will simply act as a repeater for another Calvary Chapel station in the area. That would be WFGL, an AM station located west of the Boston metropolitan area which is “owned, operated, and staffed by CSN International.”

In essence, CSN will bracket Boston with a full-power AM and a full-power FM signal to properly fulfill its evangelistic mission.

Revised Conclusions

Calvary Chapel ministries are not structured around an identifiable center of control. Instead, individual ministers get approved to use the Calvary Chapel “brand” to set up ministries around the country. These appear to operate independently of each other.

Several Calvary Chapels employ radio as an evangelical tool. They have become adept at exploiting FCC rules to establish radio networks on the cheap using LPFM and/or FM translator stations, although they are also active in full-power station proliferation. The most prominent example of full-spectrum expansion involves the Calvary Chapels of Twin Falls (ID) and Costa Mesa (CA), which jointly own and control the Calvary Satellite Network (CSN International). CSN is known to actively recruit LPFM applicants.

One of the major constituencies involved in the Great Translator Invasion of 2003 were other Calvary Chapels emulating the CSN radio ministry model. Two of them, Calvary Chapel of Fort Lauderdale and Horizon Christian Fellowship, are in the process of setting up state or regional broadcasting networks. In Florida this involves dozens of FM (translator) signals anchored by a 100,000-watt powerhouse.

Unlike the Calvary Chapels of Twin Falls and Costa Mesa, which had to grow their networks over time by applying for more and more FM stations when they could, Calvary Chapel of Fort Lauderdale and Horizon Christian Fellowship are buying their reach via an intermediary corporation whose founding alumni once worked for Calvary Chapel of Twin Falls, an originator of the FM signal proliferation strategy.

The intermediary, which does business under multiple names (Edgewater/RAM), is actively facilitating this expansion by providing construction permits hoarded in the Invasion, both for sale and for free. It is important to remember that Calvary Chapel is just one of several religious broadcast networks who hoard spectrum. Many others are benefiting from spectrum windfall, either as direct applicants new stations or as the buyers or beneficiaries of construction permits which were initially awarded to Edgewater/RAM. This additionally implicates Edgewater/RAM as a spectrum broker coordinating purchases and trades between several religious broadcast groups, of which some are Calvary Chapel-affiliated groups.

Then there’s the zinger: the person working the FCC filings for at least two Calvary Chapel radio entities is the sitting president of the Federal Communications Bar Association.

Electronic Filing Abuse

Educated opinion on the workings of the FCC electronic filing systems suggests that Edgewater/RAM may have used an automated application to “spam” the FCC with the 4,000+ translator applications it filed in 2003 (from which it has so far harvested an estimated $4.7 million worth of FM spectrum). The idea of one person, or even a small group, individually filling out each online form required during such a short filing window is difficult to believe. One clue pointing in this direction is Edgewater/RAM’s apparent use of Census data to target where it would apply for FM translator stations.

Census data contains a special quirk: some U.S. communities are named differently in CensusLand than they are in the conventional (real) world. Edgewater/RAM applications followed the CensusLand syntax in its translator filings involving those communities where such a disparity exists. A pre-loaded custom form-filler script could certainly file 4,000+ electronic applications in a handful of days.