80361 & counting. That's the number of comments filed so far in the localism NOI with the FCC. Seems that some of the satellite fed translator owners are nervous about the prospect of LPFM stations earning a higher level of preference when it comes to allocations... and they should be nervous!
Translators are restricted, for all intents and purposes from providing local content. LPFM stations, on the other hand were created to enhance local content. Since the NOI is all about localism, who should come out as the hands down winner, the station that provides no local content or the station that is required, by regulation to provide local content?
Seems like a no brainer, but you have to look at the bigger picture. Who puts on the translators (for the most part)? Colleges and Universities? Local ministries with local content? The answer are the large religous outfits. This blog entry is by no means anti-religion, but is about what priorities the FCC should use in its criteria concerning localism. If it truly is concerned about localism, the non-local translators would not stand a chance against a college, community group or local religous organization. The rub here is that the FCC pretends to portray a leaning towards localism as a means for spectrum allocations, yet the elected leaders fear the retribution of the religous organizations at the polls if they change the status quo. The status quo is that the well funded have used and abused the rules to establish non-local translators which were never the intent of the statute or the regulations.
The genie has long been out of the bottle. Long ago, those with the financial resources figured out a way to use loopholes to their advantage. This gives them a big foot up in this important policy decision. They have established large networks of stations (many of which don't meet local main studio rules) and translators and thus built a very substantial audience. Displacement of the translators by LPFM would mean that these programmers/owners would loose a substantial portion of their audience (and the donations derived from these audiences). So this again translates into a $$$ issue.
Now that the FCC has issued an NOI, what happens? 80,000 + comments! Take a wild guess at who has filed the majority of the comments? NAB members? College Stations? Those seeking local stations via LPFM? No. The majority of the respondents appear (we haven't read all 80,000 just yet!!!) to have come from listeners to K-Love and AIR1 (both owned by the same corporation).
The K-Love website states, "There is a possibility that you might lose your local K-LOVE station!" This is obvious fear mongering designed to generate a response. It doesn't explain which signals are in jeopardy or why.
The linked page http://www.klove.com/fcc.asp goes on to explain that LPFM stations could take precedence over K-Love translators, but fails to explain the difference between translators and full service stations or LPFM stations. Thus listeners are urged, out of fear, to file comments with the FCC, not knowing or even being provided with a list of which signals could be jeopardized. Thus listeners to 'full service' stations file comments on behalf of K-Love out of fear that their favorite station could go away when that is simply not possible. Given that translators are 'normally' low power versions of the main station, who do you think filed the majority of comments in favor of translators? Those who actually listen to them and would be affected by a ruling in favor of LPFM or those who listen to the normally high powered full service K-Love station?
This whole process opens another issue... should the FCC take comments from the public via electronically filed comments? Ideally, the answer should be yes, but looking at this specific example the answer becomes much less clear. Should those already in power be able to abuse the system in order to maintain or perhaps increase their power? More on this in the next edition. For the sake of maintaining a record of what is posted, the K-Love page text is posted at the end of this unusually long blog.
OH BLL-20031021AAB WUHS-LP 132046 WEST UNION HIGH SCHOOL Lic. to cover E 96.9
WNCG-LP 132055 NORTH CENTRAL STATE COLLEGE Lic. to cover E 95.7 MHZ MANSFIELD, OH
OH BLL-20040128ABE WBWH-LP 131338 BLUFFTON COLLEGE Lic. to cover E 99.3 MHZ BLUFFTON, OH
AR BLL-20040220AAV KRMN-LP 134109 RICH MOUNTAIN COMMUNITY COLLEGE Lic. to cover E 101.1 MHZ MENA, AR
VA BLED-20041022ACN WCWM 65555 THE COLLEGE OF WILLIAM & MARY IN VA. Lic. to cover E 90.9 MHZ WILLIAMSBURG, VA
FM AUXILIARY TRANSMITTING ANTENNA APPLICATIONS FOR MODIFICATION OF AUXILIARY PERMIT GRANTED -------------------------------------------------------------
WI BMXPED-20040902ACC WYMS 42669 MILWAUKEE BOARD OF SCHOOL DIRECTORS Mod of CP for auxiliary purposes. E 88.9 MHZ MILWAUKEE, WI
FM AUXILIARY TRANSMITTING ANTENNA APPLICATIONS FOR AUXILIARY PERMIT GRANTED ---------------------------------------------------------------------------
PA BXPED-20040825ABC WMCE 41215 MERCYHURST COLLEGE CP for auxiliary purposes. E 88.5 MHZ ERIE, PA
NE BXPED-20040830ACJ KVNO 69395 THE BOARD OF REGENTS OF UNIV. OF NEBRASKA CP for auxiliary purposes. E 90.7 MHZ OMAHA, NE
IMPORTANT NOTICE: The Federal Communications Commission (FCC) is now considering making changes to the way FM radio is heard in your community. Advocates of a new broadcast service known as Low Power FM (LPFM) are proposing to expand this service in a way that would allow the new LPFM stations to take priority over current FM translator service. We are bringing this to your attention because K-LOVE is a national and regional broadcaster with many local FM translators used to bring the Positive & Encouraging K-LOVE signal to communities across the nation. What this means to you is that you may lose your local K-LOVE FM Radio service!We need your help! The FCC is currently requesting public comment on this issue. You can make your opinion known by taking a few minutes to fill out a form on the FCC website.IMPORTANT: This form requires specific information to be included. In section 1, labeled "Proceeding", please enter the numbers "04-233" and where you are asked for Document Type in section 12, please choose "comment.'We are asking our listeners to include the following three points in their comments to the FCC:1. How K-LOVE serves you as a resident of the local community.2. The effect on the local community if K-LOVE were to be displaced by an LPFM broadcaster providing other programming.3. Why you believe that the service provided by K-LOVE is in the public interest.Thank you for taking the time to support YOUR local K-LOVE station!
