Philip Tymon’s 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.)
Location 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.
–Joint Statement 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.
–National Public 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.
–North Carolina 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.
–USA Digital Radio Partners.
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 be measured.
–Greater Media.
Group Radio Station Owner. Interference, IBOC. No real economic opportunities in micro-radio. Alternatives like internet exist. Will encourage pirates.
–E.C.I. License Company.
– Interference. – Financial fragmentation, especially of minority and niche formats.
–Cox Radio.
Crowding and interference, inefficient use of spectrum, administrative nightmare for FCC.
Alaska
–KLAM/KCDV Radio (J.R. Lewis).
Economic competition from LPFM will destroy small, independent, local stations in small towns.
California
–Chester Coleman.
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.
–Educational Media Foundation.
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 frequency coordination.
–Kidd Communications. (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.
Florida
–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.
–WAVS (Roy Bresky).
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.
Illinois
–Kurt Tuckerman, Sandyworld. IL.
Small station and translator owner. Many concerns having to do with commercial competition, non-local programming.
Indiana
–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.
Minnesota
–Southern Minnesota Broadcasting Co. (9 radio stations).
Interference to both full-power radio stations and aviation.
New Jersey
–New Jersey Broadcasting Association.
Interference, FCC administrative nightmare, pirates will continue anyway.
–New Jersey Broadcasting, Inc. (4 radio stations).
Interference.
–Press Communications. (3 radio stations).
Interference, administrative nightmare for FCC. No guarantee that “diversity” or “minority” goals would be achieved. Internet provides an alternative.
New Mexico
–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
–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.
–Portland 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”.
Texas
–KVST-FM Radio (Benjamin Amato).
Financial disaster for small, independent station in small town (Conroe, TX).
West Virginia
–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.
Philip Tymon
National Lawyers Guild Committee on Democratic Communications (CDC)
558 Capp Street
San Francisco, CA 94110
415.648.8450
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