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A Non-com question

Just wanted to ak a question. Where I live we have several NCE Christian Station. Some are truley NCE 90 or below others are NCE on Commercial Frequencies. Heres the question if the station on the commercial frequency states they are a NCE listener supported, then just tell how can they do underwriting, Advertising (with calls to action) and do pledge drives. Now I understand that since they are on a commercial frequency theycan sell true advertising. So they have the best of both worlds, where the non-commercial can only do underwriting and pldge drives. It seems to me that their should be a rule for the stations claiming to be NCE on commercial frequencies. If some one could give me a staright answer I would apprciate it. One othe thing can someone tell me where in the FCC rules does it state that a NCE can only be supported by a certain amount of underwriting.
 
> Just wanted to ak a question. Where I live we have several
> NCE Christian Station. Some are truley NCE 90 or below
> others are NCE on Commercial Frequencies. Heres the
> question if the station on the commercial frequency states
> they are a NCE listener supported, then just tell how can
> they do underwriting, Advertising (with calls to action) and
> do pledge drives. Now I understand that since they are on a
> commercial frequency theycan sell true advertising. So they
> have the best of both worlds, where the non-commercial can
> only do underwriting and pldge drives. It seems to me that
> their should be a rule for the stations claiming to be NCE
> on commercial frequencies. If some one could give me a
> staright answer I would apprciate it. One othe thing can
> someone tell me where in the FCC rules does it state that a
> NCE can only be supported by a certain amount of
> underwriting.
>

I don't know of any FCC rule, I do know that WBUR owns several commercial frequencies (WBUR AM, WRNI, WXNI are all commercial freqs) but maintains the non-commercial underwriting standards on them.
 
Religious broadcasters - Commercial and Noncommercial

What is NCE?

FM frequecies from 88.1 to 91.9 Megahertz (not 90 and below) are reserved for non-commercial use. Public radio, educational, community and religious broadcasters share this band. All other FM frequencies and all AM frequencies are available for commercial broadcast use (but non-commercial use is not excluded). Some public radio stations operate outside the non-commercial band (for example, in New York, WNYC-AM, WNYC-FM, and Pacfica Radio's WBAI). They operate as non-commercial stations and hold pledge drives and seek corporate underwriting.

Many, perhaps most, Christian radio stations are owned and operated by for profit corporations (such as Salem Communications) and operate outside the non-commercial FM band (all religious stations on AM are licensed as commercial stations). Religious broadcasting is a big business. Various ministries buy time on religious-format radio stations. Time is not donated to these ministries. (The same is true for Sunday morning religious broadcasts on secular radio stations; churches and radio ministries buy the time, just like any advertiser.) And various types of religious-oriented music are also profitable formats. Many religious broadcasters clearly serve mammon; it is debateable to what extent they serve God.


> Just wanted to ak a question. Where I live we have several
> NCE Christian Station. Some are truley NCE 90 or below
> others are NCE on Commercial Frequencies. Heres the
> question if the station on the commercial frequency states
> they are a NCE listener supported, then just tell how can
> they do underwriting, Advertising (with calls to action) and
> do pledge drives. Now I understand that since they are on a
> commercial frequency theycan sell true advertising. So they
> have the best of both worlds, where the non-commercial can
> only do underwriting and pldge drives. It seems to me that
> their should be a rule for the stations claiming to be NCE
> on commercial frequencies. If some one could give me a
> staright answer I would apprciate it. One othe thing can
> someone tell me where in the FCC rules does it state that a
> NCE can only be supported by a certain amount of
> underwriting.
>
 
Unless you give specific examples, ie call sign, frequency, location, it would be tough to say. Non-commercial entities can own and operate commercial stations. Nothing wrong with that, at least it keeps tax attorneys busy! It is also possible that a commercial licensed station is operated non-commercial, in terms of being licensed non-commercial, as is WNYC-FM at 93.9 in New York, is a licensed Non-commercial station on 93.9FM. WBAI-FM is a commercial station operating non-commercial owned by Pacifica. Both air underwrtiting and are goverened by the non-commercial rules.

What you may be hearing is translators in the commercial band of distant stations. SOme of the religious stations do violate the rules frequently or at the very least stretch them to the breaking point. However, if the business they are "advertising" is a non-for-profit, a commercial is legal, and that is how some of these church type businesses operate. One of the satellator broadcasters has an insurance ad, but the business in question is run as a 501c3, so it is legal. Translators also can run 1 30 second commercial from their local owner to help cover costs. This you may be hearing, as well.
 
The Commission does not require a commercial station to run commercials. In fact there are still quite a few that don't run commercials -- involuntarily.

If you are a non-commercial entity with an allocation in the non-reserved band (i.e. 92.1 and above), you may elect to operate the station non-commercially with the commission. This formal election will allow you to take advantage of the non-commercial rules -- such as main studio waiver, etc. The disadvantage is that you would have to re-petition to have non-commercial election reversed.

In some cases, such as in NYC, non-commercial operators were able to get a non-reserved band allocation by pledging to operate non-commercially. This is still done in order to remove an allocation from the auction process. Non-comms do not compete at auction for allocations.
 
> I couldn't agree with you more. Let's look at WNYC in New York. An FM,
in the commercial band, but non-commercial. To boot, it's also got an AM
counterpart on the simulcast. Well, there's no NCE rules on the AM band
at all!! So, their underwriting announcements continuously break natural regulations altogether, and all the time BTW. I'd be listening to these 'station acknowledgements' and copying much of the language, assuming it's okay...

Only to find out that the FCC doesn't allow it on my station - how could that be? Doesn't NPR check and balance its announcements on all of its stations?

And why should that be considered fair? If you've got a big station and I've got a small station, why should I be discriminated against because I'm small?
This country was founded on the equal opportunities for all, and in the case of radio broadcasting... "Why" should WNYC be allowed to say "quality meats" in a local sausage manufacturer 'commercial' , when I can't follwing the SAME NPR NEWSCAST? So, they fall above channel 220 ? Big Deal!

Honestly, I hope the government decides to dispose of its policy to fund public radio and let EVERYONE fend for themselves. I get criticized for not serving the public on my puny Class-D of all things, and this is because I am a Class-D. When the other Non-Coms 10 and 20 times my signal strength and stations even bigger like WNYC have to fight for their money, they'll understand that selling a non-ad, isn't as easy as everyone proclaims it is. It is a regulation that only benefits the larger corportations on larger stations and not the smaller commununity dollar, other than non-profit groups. Well, non-profit means no-money...and no-money means you can't pay the bills. I don't want to hear rhetorical statements about how there's value in the non-announcements either. This is "sales talk" and not real business talk. Non commercial underwriting sounds awful to a big money advertiser...It's the "emporer's new clothes" of advertising. Can you imagine the looks on advertisers faces when I tell them I can't mention prices, then they turn the station on and they hear "We thank Everything 99-cents for their support". Does that mean the advertiser should change his store name to "The Best Pizza on The Planet for 1.29 a slice, of Union Beach?" - of course it does. That's what we're saying indirectly.

or let's look at the concept of underwriting if the same rules applied elsewhere...

How well would 'personal ads' go if you couldn't say how tall you were, or what your hobbies were? No one would reply, or would even read them for that matter. Unless,i say UNLESS you say you're Donald Trump. Need you say more? - You now understand my point, now go fix the problem.

bex-hex
 
...but maintains the non-commercial underwriting standards on them.


Let me just add that it probably wouldn't matter if they slip up
and add a prices or calls to action in the copy. You wouldn't turn
down corporate funding for something like that. I'm sure they (your examples) follow the rules voluntarily , but I have many examples on of stations NOT doing it, and in some of the biggest cities. I've submitted these recordings and the transcripts to broadcast attorneys who deal with the FCC, not as a series of complaints, but for verification on whether the 'rule' has been broken. The answer is always, well, they're in the commercial band anyway... go figure.






>
 
> > I couldn't agree with you more. Let's look at WNYC in New
> York. An FM,
> in the commercial band, but non-commercial. To boot, it's
> also got an AM
> counterpart on the simulcast. Well, there's no NCE rules on
> the AM band
> at all!! So, their underwriting announcements continuously
> break natural regulations altogether, and all the time BTW.
> I'd be listening to these 'station acknowledgements' and
> copying much of the language, assuming it's okay...
>
> Only to find out that the FCC doesn't allow it on my station
> - how could that be? Doesn't NPR check and balance its
> announcements on all of its stations?
>
> And why should that be considered fair? If you've got a big
> station and I've got a small station, why should I be
> discriminated against because I'm small?
> This country was founded on the equal opportunities for all,
> and in the case of radio broadcasting... "Why" should WNYC
> be allowed to say "quality meats" in a local sausage
> manufacturer 'commercial' , when I can't follwing the SAME
> NPR NEWSCAST? So, they fall above channel 220 ? Big Deal!
>
>
> Honestly, I hope the government decides to dispose of its
> policy to fund public radio and let EVERYONE fend for
> themselves. I get criticized for not serving the public on
> my puny Class-D of all things, and this is because I am a
> Class-D. When the other Non-Coms 10 and 20 times my signal
> strength and stations even bigger like WNYC have to fight
> for their money, they'll understand that selling a non-ad,
> isn't as easy as everyone proclaims it is. It is a
> regulation that only benefits the larger corportations on
> larger stations and not the smaller commununity dollar,
> other than non-profit groups. Well, non-profit means
> no-money...and no-money means you can't pay the bills. I
> don't want to hear rhetorical statements about how there's
> value in the non-announcements either. This is "sales talk"
> and not real business talk. Non commercial underwriting
> sounds awful to a big money advertiser...It's the "emporer's
> new clothes" of advertising. Can you imagine the looks on
> advertisers faces when I tell them I can't mention prices,
> then they turn the station on and they hear "We thank
> Everything 99-cents for their support". Does that mean the
> advertiser should change his store name to "The Best Pizza
> on The Planet for 1.29 a slice, of Union Beach?" - of course
> it does. That's what we're saying indirectly.
>
> or let's look at the concept of underwriting if the same
> rules applied elsewhere...
>
> How well would 'personal ads' go if you couldn't say how
> tall you were, or what your hobbies were? No one would
> reply, or would even read them for that matter. Unless,i
> say UNLESS you say you're Donald Trump. Need you say more? -
> You now understand my point, now go fix the problem.
>
> bex-hex
> You are so right. I just don't get why this station that is claiming to be a NCE still is able to take advantage of all three worlds (Comercials. Underwriting and pPledge Drives) I feel if they are on a commercial frequency their support should come from commercials only and they should never be able to do a Pledge Drive. Just more bad rules by the FCC. I agree with you when you talk to a client aand tell them you can not mention prices because you are a NCE then the NCE on the commercial frequeny comes in sells him spots where they can mention the price. Makes you look like a fool!
 
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