Opinions are coming in on the Federal Communications Commission’s proposal to let public broadcasters spend a little more on air time running fundraising campaigns for charities and related nonprofits. One divide is obvious. Religious broadcasters love this idea. NPR hates it.
“Removing the prohibition on third-party fundraising would create the potential for stations to be inundated with requests from local nonprofits, jeopardizing relationships with potential programming partners and imposing an administrative burden on station staff,” a letter from NPR to the FCC warns. “Perhaps most importantly, a removal of the prohibition may also undermine stations’ ability to raise funds from their members, who are vital to stations’ economic well-being.”
On the other hand, there is the perspective of National Religious Broadcasters on the question. “We believe that the educational content provided by on-air fundraising by non-commercial NCE stations on behalf of non-profit groups will serve a vital public interest,” the group writes; “it will energize citizens to desire an increased spirit of volunteerism, and will assist the NCE [non-commercial educational] stations and the charities that they promoted so they can meet critical social and humanitarian needs during a challenging economic time.”
At present, NCE stations can only raise funds for themselves, as they do during station drive marathons. Periodically, the FCC grants waivers letting public stations raise donation cash for big disasters (Hurricane Katrina; September 11 in NYC; the 2010 Haiti earthquake), but that’s pretty much as far as it goes.
Then the Commission released a report titled The Information Needs of Communities, which suggested a loosening of this restriction:
We recommend that the FCC consider allowing stations or programmers that are not grantees of the CPB [Corporation for Public Broadcasting], such as most religious broadcasters, to spend up to one percent of their airtime doing fundraising for charities and other third-party nonprofits. The broadcasters should disclose how this time is used—including how much is helping charities in the local community—so the FCC can make an assessment about the efficacy of this experiment.
The FCC’s Notice of Proposed Rulemaking asks for public comment on this idea, including whether to bar CPB stations from taking advantage of the new proposed fundraising window. NPR is particularly nervous about the risk that some public radio stations will decide which charities to fundraise for based on the self-interested proclivities of their respective boards of directors:
A relaxation of the current prohibition on third-party fundraising could tempt licensees to use the station to raise funds for their own discrete interests. NCE stations could face pressure to raise funds for a variety of projects or endeavors wholly apart from the core mission of the station. Especially in the case of a station licensed to a small nonprofit organization, the station could be used to produce a financial windfall for the organization’s officers and directors, and it would be difficult for the FCC to police such matters.
But the College Bible Broadcasting Company has no qualms on these questions. The non-profit runs stations WRCM-FM in Wingate, North Carolina and WMHK-FM in Columbia, South Carolina and wants to offer more help for what it describes as “crisis pregnancy centers.”
“Working with these types of local organizations would serve to educate our listeners more fully about the needs of women in our own community that have nowhere to turn when faced with an unplanned pregnancy,” the College Bible company writes. “Listeners would have new opportunities to get involved and make a difference.”
As for procedural and transparency concerns, College Bible apparently has none:
The FCC should reject any requirement for the NCE station itself to conduct all third party fundraising activities. The collection and distribution of funds and all incidental activities would create an undue burden on most NCE stations and would dampen worthy efforts to serve the public.
Finally, CBCBC agrees that while we have no objection to including reports in our local public inspection file on any third-party fundraising activities, it would be burdensome for NCE stations such as ours to be required to also file periodic reports to the FCC.
Most of the comments in this proceeding are coming from religious broadcasters, but a consortium of radio stations licensed by colleges, universities, and schools shares NPR’s concerns.
“It is important that the FCC not make the change,” writes the University Station Alliance:
“Shifting the third-party fundraising protocol from extraordinary needs to ordinary needs would result in unintended consequences that create a negative station/licensee gatekeeper effect. By telling the community 88 hours of programming time is possibly up for grabs, entities desiring fundraising air-time could interpret FCC maximums for third-party fundraising as mandates. The criteria for air time would be from relief fundraising due to devastating events such as hurricanes, wide-spread flooding, tornadoes, and earthquakes, to ordinary fundraising. This change would create a competition among not-for-profits to gain access to air-time.”
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