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Let the Cities In! Advocates want lower powered Low Power FM

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Three Petitions for Reconsideration have been submitted to the Federal Communications Commission since the agency passed its fifth Low Power FM Order and announced a LPFM application window for October. One is filed by a group called “Let the Cities In.” The missive asks the Commission to authorize LPFMs below 50 watts in “urban core” areas of the United States. The FCC only licensed 100 watt stations in its decision. The agency’s judgment on “LP10” and “LP50” class low power stations was pretty blunt:

“Licensing LP10 stations would be an inefficient use of available spectrum,” the agency ruled, and “we believe that LP50 stations would suffer many of the same technical deficiencies as LP10 stations. Accordingly, we have decided not to adopt the proposed LP50 class.”

To which Let the Cities In responds:

Let’s review, once again, some of the “bottom line” consequences of the FCC’s “LP100s only” policy in highly urban areas. Zero LPFM stations in New York City, Detroit and San Jose. (That’s roughly 10 million people right there) One LPFM station apiece for Boston, Pittsburgh, San Diego and Denver. (That’s another 3 million people, roughly) Only two LPFM stations apiece in Los Angeles, Chicago, San Francisco and Washington, DC. (That’s about 8 million people more) So a total of 21 million Americans, in 11 cities, will have grossly restricted LPFM coverage — or no LPFM coverage at all. Add in some underserved suburbs of those cities, plus similarly underserved metropolitan areas in smaller Arbitron Markets, and we estimate at least 40 million metropolitan Americans will be LPFM “have nots”.

Meanwhile, the country as a whole will have thousands of frequencies for new LPFMs. Because racial and ethnic minorities tend to be disproportionately concentrated in and near our cities, an LPFM licensing policy which leaves out the cities will also have a disproportionately negative impact on members of racial and ethnic minorities. Members of these groups will suffer a disproportionate adverse impact as radio listeners (avoidably deprived of community radio listening choices that are available elsewhere) and also as aspiring LPFM broadcasters (avoidably deprived of frequencies that LP10 licenses and/or LP50 licenses would have made available).

Meanwhile religious network LifeTalk Radio objects to restrictions on ownership of LPFMs. These include requirements that any bidder for a LPFM connected to a larger entity must be “separately incorporated” and have a “distinct local presence and mission,” and that “no license shall be granted to any party if the grant of such authorization will result in the same party holding an attributable interest in any other non-LPFM broadcast station, including any FM translator or low power television station, or any other media subject to our broadcast ownership restrictions.”

LifeTalk protests that “the aggregate affect of these two rules would appear to preclude any unincorporated local chapter from LPFM ownership if the larger parent organization has other broadcast interests.”

This petition has already drawn negative feedback from other FCC filers. “Allowing chain broadcasters to qualify as ‘local’ radio broadcasters as requested in the Life Talk Radio Petition would block opportunities for communities to have radio that is truly local,” warns Susan Raybuck.

In our community, we hope to establish an LPFM with an educational mission that not only includes diverse educational content on a variety of public safety, health and wellness, and civic issues as well as music from local musicians, and perspectives created by local people, we hope to educate students and interested adults in how to create their own content and broadcast. A chain would have less commitment to the community and less incentive to be a true public servant. Allowing chains to be considered local would subvert real localism. Please rule against the petitioners in this matter and for the local communities the LCRA [Local Community Radio Act] was designed to serve.

Also filed is a petition for partial reconsideration by REC networks proposing modifications of the Commission’s LPFM “periodic announcement” rule asking for feedback on possible interference with full power stations.

“The new rule, if taken literally, would require an LPFM station to run announcements for full power station hundreds and thousands of miles away,” REC warns.

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4 Responses to Let the Cities In! Advocates want lower powered Low Power FM

  1. My LPFM consulting firm, Christian Community Broadcasters, has been helping local churches, ministries, schools, and community group file for, construct, and operate LPFM stations from New England to Hawaii since LPFM started in 2000. Neither Let the Cities In (LTCI) nor LifeTalk fully understand the LPFM ownership rules that have existed in 2000.

    My own LPFM, WPCG-LP, is owned by Cherokee FM Radio, an un-incorporated association, recognized by IRS and the FCC as a 501(C)3. Many people have assumed that Seventh Day Adventist Churches cannot own LPFM stations since SDA Conferences own all church property in the conference. They are wrong. My client, Tallahassee SDA, is a member of a Conference but the FCC accepted my claim that they were “locally owned and operated.” They have been on the air for years without a challenge.

    Let’s say Small Town, USA has four churches at a downtown intersection, all established in the same year and all with about the same number of members. One is Catholic, another SDA, a third Southern Baptist, and a fourth independent Pentacostal. They all have different legal/ownership structures. Should the FCC discriminate between them? Absolutely not! If the FCC starting favoring one church over another based on “ownership of property”, this would be a case for the Supreme Court!

    One Burger King might be locally owned and operated; the next one might be a “company store.” The public considers them all as a “national chain” even though some are locally owned and operated.

    Some years ago, 25 LPFM apps by Calvary Chapels were Dismissed because a petitioner claimed Pastor Chuck Smith controlled them all, and all the apps had very similar wording and all were “Calvary Chapel”. Counter-arguments were filed. A couple years later the FCC reversed its first decision and re-instated all 25, because they were locally owned and operate.



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