Dedicated Corporation for Public Broadcasting watchers all know by now that “Radio Catskill” station WJFF-FM in New York has been hit with a $15k fine for violating the CPB’s rules about Community Advisory Board meetings. WJFF collected over $90,000 in CPB grants in 2010 and 2011, but dropped the ball on public notice of its CAB events.
Still, it is worth reviewing a detailed snapshot of the reasons for the fine. To wit, in a 2013 audit the CPB found that WJFF did not:
• make quarterly on-air announcements explaining the station’s open meeting policy;
• have evidence that open meeting announcements for the CAB, Board of Trustees, or the committees of the Board of Trustees were made seven or more days prior to the meetings;
• maintain records of CAB members attendance at public meetings held prior to June 2013 to verify a quorum was present;
• always provide written statements explaining the reasons for closing meetings to the public; and
• develop documentation or written procedures to explain how the station complied with the open meeting, open financial records, CAB, EEO, or donor list and political activities requirements of the [Communications] Act.
Radio stations that take CPB money must create and run Community Advisory Boards, intended to “provide a vehicle for effective community input to the station’s governing body about station programming, community service and impact on the community from the station’s major policy decisions.”
As the sentence suggests, CABs operate in partnership with but separately from governing boards. That is how it should be, I think, since governing boards and their individual members should not make direct decisions about station programming. But open CAB meetings are essential for a variety of reasons.
First, if you are going to take public money, your station ought to listen to the public. That means letting everybody know when your CAB meets and keeping records of what transpired at meetings. The CPB also takes complaints from listeners about CPB stations, and expects those stations to respond to those complaints (as opposed to ignoring them). The grant making body employs Inspectors who audit stations, and an Ombudsman who raises public concerns about station board behavior—for example, a governor of a public radio station running for public office while staying on the station board.
Second, at their best, CABs draw to their gatherings a variety of people who make constructive suggestions or raise important questions about the station’s air time. My experience is that stations that don’t comply with CPB CAB rules don’t for three different reasons, which I refer to as the “Three Es”: exasperation, exhaustion, and ennui.
The exasperation comes from enduring CAB meeting after meeting attended by small groups of angry air time seekers, sometimes energized by marginal viewpoints. Impatience with this condition is understandable, but CABs often have themselves to blame for the problem. Good CABs make the effort to encourage a variety of people in the station signal area to drop by and offer input. Bad CABs don’t, and wind up with the same old veterans saying the same old things over and over.
The exhaustion factor is also understandable. But as crazy making as running a public radio station can be, you just can’t put CAB meetings last on your list of priorities, given your willingness to take CPB funds.
Finally, station managers and governing board leaders sometimes get ennui when it comes to Community Advisory Boards. What’s the point, they wonder? Do these advisory bodies really represent “the listeners,” as station activists sometimes claim? True enough, they sometimes do not. Like the voters in mid-term elections, they can tend to represent the passionate and the determined, less so listeners with no spare time to show up at CAB meetings.
So think of CABs as one important tool in a kit of station input devices, among them web polls, letters and emails, and external metric surveys. CABs are the face-to-face tool.
The CPB requires three kinds of notice for CAB meetings:
1. Notice placed in the “Legal Notices” or the radio and television schedules section of a local newspaper in general circulation in the station’s coverage area; or, notice is available through a recorded announcement that is accessible on the station’s phone system; or, notice is available through an announcement that is accessible on the station’s web page.
2. Notice communicated by letter, e-mail, fax, phone, or in person to any individuals who have specifically requested that they be notified.
3. On-air announcements on at least three consecutive days once during each calendar quarter that explain the station’s open meeting policy and provides information about how the public can obtain information regarding specific dates, times, and locations.
WJFF appealed the CPB fine and lost, even though the station is under a new management that takes its CPB responsibilities much more seriously. Bottom line: if you treat CABs as just an annoyance, that’s what they’ll become, and with a vengeance.