LPFM Current News
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"Ownership Diversity" Comment Period Extended

A coalition of 29 diverse organizations called DCS (Diversity and Competition Supporters) requested that the FCC extend the comment period for its proposal to increase broadcasting opportunities for minority and women-owned businesses (and other new entrants).  The FCC agreed; the comment period now ends June 30 with the Reply Comments now due July 14.

6/6/08 LPFM Meeting to Start Professional Organization
By John Broomall, Christian Community Broadcasters

The CCB discussion group has about 90 members; 32 participated in our survey (only half of these are current LPFM operators).  Various insightful ideas and recommendations on how LPFM operators and advocates should protect and advance our fledgling industry came from a half-dozen active and motivated members of the group.  

Two-thirds of the members of this group did not participated in the short online survey.  Why?  Those who did participate probably do not why the others did not.  Actually a high percentage of all LPFM operators are "silent and independent."  Radio Mall, the leading compiler of radio address and contact information, personally calls all radio broadcasters (including full-power and commercial) to verify data such as key staff.  Most broadcasters cooperate; however one third of all LPFM groups have ignore attempts to reach them by phone, email, or "snail-mail."

What should we do next?  Let's meet, interact, and plan:

Who - Everyone interested in the future of LPFM and local community radio

What - A face-to-face meeting to create a professional organization and a lobbying plan

When - Wednesday, June 18 noon (extended "Dutch Treat" luncheon meeting).

Where - Nashville, TN - Opryland Hotel

Why June 18? - The NRB (National Religious Broadcasters) Radio Advisory Committee will be holding its annual Planning Meeting at Opryland on June 19-20.  What we decide on June 18 can be present to NRB representatives the next day to see if we can get their cooperation.

Cost - Nothing except your meal and personal traval / lodging expenses (you do not have to stay at the Opryland Hotel).

Have the time and money to attend?  Great!  Tell us you are coming.  See you there!
Have time but not the money?  We will see if someone can cover your travel / personal expenses
Have the money but not the time? You are encouraged to sponsor the travel of someone else
No money or time?  We will announce attendees in advance so you can contact them to present your interests.

The FCC requires that LPFM organizations be IRS-recognized non-profit groups.  As such the IRS severely limits lobbying activities by your station.  However, we believe that individuals can contribute to lobbying activities personally even if they are affiliated with a non-profit.  (This is subject to confirmation.)

All options and issues will be discussed at this meeting and priorities will be established.  A report will be submitted via this website and discussion group, and by other means.  "Out-of-the-box" creative solutions include:

1. Urging the FCC to open a special window for LPFM and other community-based (and prospective) non-profit applicants and allow they to file for full-power NCE stations on all 100 FM channels.  Like the October 2007 Window, applicants would be permitted any power available, any pattern, and the right to own up to ten stations (including translators).  
2. With Congressional and/or FCC approval, Second and Third Adjacent filings could be accepted using the above guidelines. 

Who Supports LPFM ... and Why
By John Broomall, Christian Community Broadcasters

LPFM has four types of supporters:
(1) Current LPFM broadcasters who want to preserve what they have
(2) Current LPFM broadcasters who want to reach more people in the future
(3) Prospective LPFM broadcasters
(4) Localism and "social change" advocates

(1) Operators of LPFM stations are concerned they might lose everything because of full-power encroachment.  For them, second and third channel displacement options offer more relief than Primary Status.  If Congress or the FCC granted Primary Status, it would not be retroactive.  The FCC would announce, for example, that effective January 1, 2009, all applications, full and low power, would be treated on a "first-come first-serve" basis.  This would mean that full powers would be filing for minor mod upgrade through December 31, 2008

If future Primary Status is the only form of relief, that would mean that low powers could be displaced not only by operating stations but by all CPs and applications through the end of the year.  An application filed this year might result in a new interfering station five years from now.  If, however, low powers has displacement options not available to other station, a LP could "hide in the shadow" of a FP thus preventing future encroachment displacement.  A LPFM with frequency agile transmitter and a broadband antenna could change frequencies in five minutes.

(2) LPFMers who wish to reach more people in the future are interested in more power, new coverage patterns, and ownership of multiple LPFM and/or translator stations.  No one has suggested that current LPFMers be given priority rights over prospective rights.  If present and prospect low power groups had more power and the right to own multiple stations this would create many new MX pools that would not be resolved for years.  (Consider the massive MX mess created by the 2007 NCE window.)

(3) Prospective LPFM operators are competing for spectrum against all classes or current broadcasters plus all other "want-a-bees".  These new groups will not be well represented and do not understand the LPFM regulatory challenges.  Clearly the position of current operators is "me first."  However, a sacrificial (or frustrated) current LPFM station can no longer be sold if it has not be in operation for three years.

(4) Social change media advocates like Prometheus and Free Press oppose media consolidation and support "localism."  LPFM is just one of many options.  A community-oriented local AM could offer the diversity they seek.  Actually, if would appear that most LPFM broadcaster would like to have a full power station.  Thus it is surprising that more LPFMers did not apply during the October 07 window.  (Possibly many did apply but used different names, making it difficult to compile accurate statistics.
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6/4 LPFM Industry Goals and Political Action
By John Broomall, Christian Community Broadcasters

What do LPFM broadcasters want from the FCC?  There are approximately 850 operating stations.  CCB asked 92 members of its online discussion group their opinions concerning the LPFM industry.  Thirty-two responded to date.  18 of these operate LPFM stations; 72% need more financial support, 40% need replacement / backup equipment and 35% need more volunteers.  

81% view the future of LPFM as "fair to good."  77% believe the industry needs a professional trade organization / lobbyist, and 62% are willing to pay $100 to $150 per year dues.  In addition to secular and Christian stations, 68% believe LPAM advocates should be included; 64% OK new entrant NCE groups.  The top goals are Primary Status (82%) while "more power" was a distance second with 43% 

While "more displacement options" gained less that 4% support,  several members of the discussion group believe that lobbying Congress to get the Community Radio Act of 2007 (remove 3rd adjacent limitations) should have top priority because this is already being considered.  Equally vocal members affirm that Primary Status should trump 3rd Adjacent.

At this point, we have no idea how much money can be raised or the cost of various proposed lobbying efforts for one or issues.  Which is more "winnable"?  Timing is critical.  Democrats and Republicans agree - there will be new Senators, Representatives, and Commissioners next year.

(90% say the CCB discussion group is their number one source of LPFM information.)

6/2 Trade Organization Planned for LPFM Operators
By John Broomall, Christian Community Broadcasters

For years LPFM operators have discussed forming a new independent professional organization on LPFM discussion groups such as ccbroadcasters@Yahoogroups.com  Currently I am conducting formal online survey of CCB clients and discussion group members.  This survey will be expanded and all 850+ LPFM operators.

Many ideas have been suggested.  One is that a database of LPFM information be formed that is more user-friendly than a blog.  CCB will provide this service until the organization is founded and has its own website and database.  The consensus is that the organization should be independent and not take a stand for - or against - programming (i.e. social and religious views aired).

Key questions have been raised, "who should the organization serve?" and "How should it be structured?"  Options include:
1. A "professional trade organization" for LPFM operators / advocates only
2. A "professional trade organization" for LPFM groups and other small / new broadcasters
3. Option "1" and/or a PAC (Political Action Committee)
4. Option "2" and/or a PAC.

As of today, 31 survey results from members of the discussion group  indicate: 
Of 30 respondents:
23 (77%) support "a professional organization with a paid lobbyist."  (no question was asked concerning a trade organization without a paid lobbist).
 7 (23%) say "no"

Of 27 respondents (multiple answers permitted): 
26 (96%) - the association should serve both secular and Christian groups
18 (67%) - LPAM advocates should be included 
17 (63%) - Part 15 advocates - supporters should be included.

Based on my wording of the questions, several people opposed to a organization still voted on "who should the organization represent?"!  Also, $100 was the typical answer concerning "annual dues."  At this point, we have heard from only 31 of 850+ LPFM broadcasters

If the new organization were incorporated, significant funds would be needed to get started.  Probably the cost of setting up a PAC would be even greater.  Members would be frustrated if their money was spent on structure and nothing left for the mission.  This would be like buying a new car and parking it because there was no money for insurance and gasoline!

Based on 27 responses, the top goals were "primary status" (82%), more power (44%), and the right to air commercials (33%).  New NCE organizations have more power and primary status; LPAM does not exist.  Would each of these subgroups approve their money being used to advance someone else's goals?

The "easy answer"" is to separately fund each goal or PAC.  There might not be enough money raised to properly lobby for one objective, let alone several.

What's in a Name?