The 2011 survey team managed to contact 149 LPFM stations. Among the study’s findings: 31 percent of the stations reported no income from underwriting. Another 32 percent disclosed that between one to 25 percent of their budget came from underwriting. Nine percent acknowledged that 26 to 50 percent of their budget came from underwriting.

Bottom line: 72 percent of these signals reported that less than 50 percent of their income came from an underwriting source.

source: Prometheus Radio

“Based on the budget ranges provided by the stations which answered this question, we calculate the total number of underwriting dollars for these respondents as $947,000,” Prometheus’s Brandy Doyle writes. “If these responses hold for all LPFM stations, then the underwriting revenue for the LPFM service as a whole would be approximately $7,284,615. To put this in context of commercial broadcast radio advertising revenue, this number represents .0005% of the over $15 billion in revenue for U.S. commercial radio in 2010, a negligible amount.”

Thus, “LPFM stations are highly unlikely to have a detrimental economic impact on full power commercial stations.”

Why is this even a question? Prometheus filed the data in an FCC proceeding titled the “Economic impact of Low-Power FM Stations on Full-Service Commercial FM Stations.” Congress required the Commission to conduct the inquiry when it authorized more LPFM stations earlier this year. If you’ve been waiting for the National Association of Broadcaster’s shoe to drop, here it comes.

In its comments in the proceeding, the NAB wants the FCC to pay particular attention to the impact that new LPFM’s might have on commercial “niche” stations:

NAB agrees that some advertisers who now reach minority or niche audiences over commercial stations may divert their radio budgets to underwriting of LPFM stations. Even if that does not occur, however, a lowpower station that diverts audiences from a full-service station will reduce the full-service station’s advertising revenues because the full-service station may no longer garner as many listeners, regardless of whether particular advertisers choose to support the LPFM station. Particularly for full-service stations serving niche audiences, the loss of listeners may reduce advertising revenues to a point where the station is no longer financially viable or where it would be forced to change to a more mainstream format.

To which Prometheus responds:

The Commission’s role is not to protect incumbent stations from competitors, but to ensure that licensees serve the public interest. The LPFM service is relatively new, and has been hampered by restrictions that relegate LPFM stations to rural areas. It is our hope that both existing and future LPFM stations will continue to grow in their community impact, and in some cases, this growth will include larger budgets and increased revenue from underwriting. Such growth will likely create a positive economic impact in the communities where stations are located. In the long term, new LPFM stations may indeed have a positive economic impact on their full power commercial neighbors as well, by pushing radio to return to its roots of local community service and keeping broadcasting relevant.

In a statement, Congressman Doyle said,

“The benefits of low power FM radio have been demonstrated time and time again. These stations have been instrumental in local news reporting, emergency response, and cultural enrichment. I hope the FCC will recognize these important values so that many more Americans, in Pittsburgh and all other cities and towns, can enjoy the richness of local radio.”

The 28 House members also urged the Commission “to ensure the licenses are awarded to truly local churches, non-profit organizations, local governments and schools.” Given that local ownership is strictly required by FCC for LPFM licenses one has to wonder if this isn’t a bit of a swipe at the networks of translators piping in distinctly non-local and distant signals which compete with LPFMs for space on the dial.

The deadline to comment on the FCC’s rulemaking on pending translator applications and the implementation of the Local Community Radio Act was Tuesday, September 6.

The National Association of Broadcasters slipped its comments [PDF] in Tuesday just under the wire, pretty much urging the FCC to reduce the priority of licensing LPFM stations in the most densely populated urban cores, while asking the Commission to process and license as many translator stations as possible before moving on to opening up LPFM licensing windows. In particular the NAB suggests the FCC rely on Arbitron markets for determining the availability of LPFM frequencies, rather than the currently proposed method which focuses on keeping frequencies available inside a city’s urban core. Using an Arbitron market as the geographical measure, the requisite number of LPFM-eligible frequencies may remain available, however they could be only on the fringes, unable to serve the city centers that were a priority for many of the Congresspeople who supported the Local Community Radio Act.

The Commission is now accepting replies to comments that have been submitted. This is when the sparks really start to fly, as LPFM advocates attack the NAB’s counter-proposal, and the groups hoping for new translator licenses return the favor. The deadline to submit these reply comments is September 20.

As we reported back in July, the purpose of this rulemaking is to set the implementation of the Local Community Radio Act, which expands the opportunity for more new LPFM community stations.

In particular the FCC asked for comments on how to proceed with pending translator repeater station applications, given that these stations can be placed on frequencies that are also appropriate for new LPFMs. The Commission proposes setting a “floor” for the minimum number of LPFM-appropriate frequencies that must remain available in a given market after translator licensed are granted.

LPFM advocacy group the Prometheus Radio Project has created a video that explains this proposal. Prometheus also has an “action” page for those who want help submitting comments to the FCC.

The applications for new translators–which are low-powered stations that may only rebroadcast the signal of a full-power station–would be processed for small markets and rural communities. In order to leave some space on the dial for new LPFM stations the Commission proposes dismissing translator applications in larger markets where new translators would fill up any last available space appropriate for LPFMs.

In 2007 the FCC froze the processing of 6,500 pending applications for FM translator stations because the Commission concluded that doing so would “frustrate” the further development of LPFM. It then established a limit of ten applications per applicant, which the Commission has now reconsidered. Instead, the FCC proposes a policy based on the availability of spectrum for LPFM on a market-by-market basis. This is in part motivated by a stipulation in last year’s Local Community Radio Act, under which the Commission is required “to ensure that licenses are available for LPFM and FM translator stations; licensing decisions are based on community needs; and translator and LPFM stations remain equal in status.” The change is also propelled by the recognition that a simple translator application cap likely would not preserve spectrum space for LPFM in the largest, most crowded radio markets.

In today’s proposal the Commission suggests a “floor” specifying a minimum number of LPFM frequencies that must remain available in a market in order for translator applications to be processed and awarded.

Responding to the FCC’s proposal, Brandy Doyle, Policy Director at the Prometheus Radio Project, said,

Today the FCC starts to redeem the promise made to thousands of community groups and national organizations that successfully fought to pass the Local Community Radio Act. The Act requires the FCC to ensure channels for low power stations, and we believe a market-specific solution could accomplish that.

Congressman Mike Doyle (D-PA), lead cosponsor of the Local Community Radio Act, said,

I am delighted to see that the FCC is moving forward to carry out legislation I championed for so many years. This is a major victory for community radio, and I urge the FCC to license as many LPFM stations as possible.

Ever since the passage of the Local Community Radio Act, the big question has been how the FCC will deal with its backlog of applications for translator repeater stations. Translators are low-power stations that may only rebroadcast the signal of an existing full-power station, and can be fit in many of the spaces on the dial that could also accommodate low-power FM community stations under the provisions of the Act.

The answer to that question may soon be on the horizon. The Commission has an item on the agenda for its July 12 open meeting that addresses the issue. Unfortunately there’s little indication as to what the exact decision at hand might be. The agenda only says we can expect a “Notice of Proposed Rule Making seeking comment on the impact of the Local Community Radio Act on the future licensing of low power FM and FM translator stations.”

LPFM advocates are certainly hoping that the Commission will propose opening up a new application window for low-power stations first, while those with translator applications in the queue are hoping to be dealt with first. I suspect that the FCC’s proposed rulemaking will try to find some middle ground, if that’s possible. In any event, there should be a public comment period following the announced proposal.

Yes, the Local Community Radio Act of 2010finally passed both the House and Senate almost two weeks ago. But it’s not official until the president signs it. And that he did, today.

Today is just the start of the process to bring more community radio stations to the air. There is a lot of work yet to be done, not the least of which is on the part of the FCC, which will have to determine the rules of the next application window. Still, first that Commission has to resolve pending translator applications which could use up a lot of frequencies that otherwise are appropriate for LPFM stations under the provisions of this new law.

In the coming days and weeks we at Radio Survivor will bring you additional news and analysis on the rollout of this second phase of LPFM.

“The revised legislation will expand the number of LPFM stations in the U.S. while providing full-power radio stations with the protection and clarity we have long sought. NAB salutes today’s House action and offers its support for Senate passage as well.”

From the side of long-standing support for LPFM, Kamilla Kovacs, Communications and Development Director of Media Access Project, said,

“MAP is delighted to see House passage of the Local Community Radio Act. It looks forward to Senate enactment of this important legislation, so that LPFM advocates including MAP can finally begin to work with the Federal Communications Commission to expand opportunities for community radio stations nationwide.”

Now the bill should move to the Senate for a vote by acclimation.

The text of the legislation is not yet available, though it was announced on the House floor that the National Association of Broadcasters has given the bill a letter of support. Now, one would guess that this bill going to the Senate where we might suppose the NAB won’t be fighting it, given their letter of support for the House version. But anything can happen, so it should be an interesting ride.

Grassroots heat has been getting hotter this week as the Senate runs out of time to vote on the Local Community Radio Act, expanding low-power FM. There are some signs that the action is having some effect.

Free Press campaign director Tim Karr tweeted on Thursday,

NAB lobbyists overheard at DC event: “We’re getting beat up on Twitter about LPFM”

Indeed, the twitter petition site act.ly itself tweeted later in the day,

Today’s #1 petition @nabtweets to stop lobbying Congress to block new, independent radio stations

And DC insider newspaper Politico ran a story on how all the NAB lobbying pressure “is pinching the nerves of some lawmakers on Capitol Hill.” So much so, in fact, that congressional staffers are saying their bosses are getting tired of negotiating with the NAB because the lobby is not showing any willingness to compromise on issues like LPFM.

Even the Oregonian, the home paper of NAB president and former-senator Gordon Smith, took notice with a piece on Wednesday that observed,

Gordon Smith is no longer one of Oregon’s U.S. senators, but community radio activists are trying to paint him as still pulling secretive strings in Congress.

It’s unclear how much the NAB cares about the increasingly negative press. However, I’m certain the lobby does care quite a bit how members of Congress are perceiving its efforts, with many starting to wonder if it isn’t squandering its clout and resources on an issue that is more symbolic than any kind of real threat to commercial broadcasters.

The question is whether or not the NAB is willing to risk some standing in order to score a win on LPFM. Or it may be that the broadcast lobby is betting a Republican House and more Republican Senate won’t care or remember come January 1. Given the bipartisan support for LPFM, that may not be the surest bet. But that hasn’t seemed to stop the NAB in the previous nine years, either.

Dean Wormer would call this double-secret probation.

On Friday word came down that Wyoming Sen. John Barrasso removed his hold on the Local Community Radio Act. If passed, this bill would restore low-power FM standards to FCC’s original specification, thereby allowing hundreds more stations to take to the air. And yet, still no action? That’s because there are still other holds on the bill, which also remain secret under the rules of the Senate until either someone cops to it, or the holders are identified through a process of elimination.

It’s as if Senate Republicans are playing tag-team on holding this bill, swapping it anonymously once one of the holders gets discovered. I keep thinking we’re going to uncover Dean Wormer working the Senate to keep the bill on double-secret probation.

So Prometheus Radio Project is asking low-power radio supporters to help identify which Senators are holding this bill now, by calling one’s local senator and asking if s/he’s blocking the Local Community Radio Act.

Time is running out on this session of Congress, and unfortunately Senate Republicans don’t seem to perceive much political risk in playing hide-and-seek with future of community radio.