Call letters & legal IDs: obsolete?

[w9wi]

The question came up on another thread: is there a point to requiring stations to run verbal legal IDs? (visual, for TV)

With RBDS and HD-PAD technologies for FM radio; PSIP for television; and now possibly ADDS for AM radio, stations often are identifying themselves 24/7 digitally. Is it necessary to require them to transmit the call letters verbally as well, when many stations would obviously prefer not to do so? (given the stations that "bury" their IDs)

For that matter, are call letters and legal IDs obsolete altogether? In many of the world's countries, stations don't even *have* call letters.

In the days before broadcasting, call letters were necessary. If a marine shore station wanted to communicate with a ship, it needed to identify *which* ship it wanted to talk to -- and sending "M/V TALLAHASSEE DE SHORE STATION ST PETERSBURG" could take a long time using Morse Code! KRIC DE WSP was a lot more practical... Broadcasting stations inherited the marine regulations; in any case, arguably requiring early broadcasters to ID made it possible for the FRC inspectors to figure out which station was 800Hz off-channel.

What purpose does the legal ID serve today? Certainly a station must create an identity with the listeners, but in many cases the station has made it plain it wants that identity to be "Newstalk 930". If a kid at Sycamore High School tells you she listens to WRVW, you've probably just located the school's electronics geek... who has to explain to her friends that's the same station the rest of them call "107.5 The River"...

Commission field technical staff has equipment capable of determining which antenna a "freebander" is using to make illegal transmissions in the 27.4-28MHz band. Certainly they don't need to hear call letters to know which broadcast station is radiating a spurious signal on 109.3MHz, or who hasn't run an EAS RWT in two years, or which TV station just showed a part of the female anatomy they shouldn't have.

Is the legal ID necessary for the public to be able to file a complaint against a station? (to know *which* station they're complaining about?) It hardly seems likely the FCC would be unable to figure out a complaint about "103.7 FM in Milwaukee" means the station licensed to Entercom in Wauwatosa. (I'll bet most complaints they're receiving *today* don't contain call letters)

Are call letters necessary for internal recordkeeping? Well, they're not particularly useful for the purpose. Call letters change too often... For their Consolidated Data Base System, the primary key for most functions is a number called a "facility_id". The aforementioned 103.7 FM in Milwaukee is, to the database, Station #27031 -- not "WXSS". (or is it WEZW, or WTOS, or ????) It's not only the Media Bureau using the facility_id; when the Enforcement Bureau issues a Notice of Apparent Liability (or other notice) against a broadcaster, it says both "Licensee of Station KFSD" *and* "Facility ID #49205". Obviously the Commission's staff doesn't require call letters to keep track of the nation's broadcasters.

So what I'm asking is:

1. Should the FCC drop the requirement for legal IDs?
1a. Should they do so only if the station transmits its call letters digitally, using TV-PSIP, FM-RBDS, FM-HD-PAD, and/or AM-ADDS?
2. Should the FCC drop call letters altogether, tracking stations only by their facility_id?

 

[oldiesfan6479]

1. Should the FCC drop the requirement for legal IDs?
1a. Should they do so only if the station transmits its call letters digitally, using TV-PSIP, FM-RBDS, FM-HD-PAD, and/or AM-ADDS?
2. Should the FCC drop call letters altogether, tracking stations only by their facility_id?

No.
No.
Hell no.

Without calls and legal IDs, listening to KAZG Scottsdale (aka "Lumberyard 1440")
wouldn't be fun anymore! Imagine that, a cold carrier dump and no legal ID... ;D

 

[danikayser84]

I disagree with this, actually... legal IDs should and will always be part of American radio. Plus, some radio stations still use call letters for their branding

 

[KeithE4]

I disagree with this, actually... legal IDs should and will always be part of American radio. Plus, some radio stations still use call letters for their branding

They could still do that if they wanted to. What difference does it make if the all news station in Chicago IDs as "WBBM Newsradio 780" or just "Newsradio 780" - or even "Chicago Newsradio" if they wanted to? None whatsoever, but if they still wanted to use the WBBM call letters, they certainly could since it's their "brand." Trademark laws would still prevent some other station from using it if the term "WBBM" was removed from the FCC database.

But the use of call letters as a legal ID is pretty much obsolete for almost every service licensed by the FCC except for Amateur Radio. I can't think of any other where call letters are still useful, or even widely used, other than for legal purposes in broadcasting. As was mentioned above, the FCC keeps track by Facility ID, not call letters. Call letters are pretty much a marketing thing and have been ever since the Feds allowed stations to choose their own back in the 1920s.

 

[TheBigA]

I think it's a good question, and you make lots of great points.

However, we're talking about the government here, and the FCC in particular. They still do a lot of obsolete things and require a lot of obsolete procedures. So I doubt very much that they would even consider such a proposal.

 

[KeithE4]

Without calls and legal IDs, listening to KAZG Scottsdale (aka "Lumberyard 1440") wouldn't be fun anymore! Imagine that, a cold carrier dump and no legal ID... ;D

Not to mention it would end the longest thread in the history of the Phoenix radio board. ;D

 

[w9wi]

I think it's a good question, and you make lots of great points.

However, we're talking about the government here, and the FCC in particular. They still do a lot of obsolete things and require a lot of obsolete procedures. So I doubt very much that they would even consider such a proposal.

If broadcasters asked for it, I suspect the FCC would be willing to go along. It was the Commission that proposed to drop the K/W separation thing a few years back -- and it was the industry that said "no".



Given the frequent call changes & reuse of the same calls elsewhere, I think call letters have lost almost all relevance in the regulatory process. Again, witness the use of the facility_id as the primary key relating non-technical datakeeping with the technical database tables.

(the Canadian database uses calls as the primary key. It results in a lot of inconsistencies, even though call changes are considerably less frequent up there...)

 

[TheBigA]

If broadcasters asked for it, I suspect the FCC would be willing to go along.

I think their "ask" list is pretty long right now. Unless eliminating call letters would help with PPM (and it might), I'd see no reason for this to move above much bigger issues.

 

[davideduardo]

If broadcasters asked for it, I suspect the FCC would be willing to go along. It was the Commission that proposed to drop the K/W separation thing a few years back -- and it was the industry that said "no".

I see no reason why broadcasters would ask for such a change. Call letters are the one thing that ad agencies (and ratings companies) can use as a standard identifier for stations.

 

[ixnay]

I think it's a good question, and you make lots of great points.

However, we're talking about the government here, and the FCC in particular. They still do a lot of obsolete things and require a lot of obsolete procedures. So I doubt very much that they would even consider such a proposal.

If broadcasters asked for it, I suspect the FCC would be willing to go along. It was the Commission that proposed to drop the K/W separation thing a few years back -- and it was the industry that said "no".

Good thinking, industry. Who'd want a Los Angeles oldies station called W-Earth?

ixnay

P.S. Why does this topic call to my mind Bruce Springsteen's "Radio Nowhere"?

 

[w9wi]

If broadcasters asked for it, I suspect the FCC would be willing to go along. It was the Commission that proposed to drop the K/W separation thing a few years back -- and it was the industry that said "no".

I see no reason why broadcasters would ask for such a change. Call letters are the one thing that ad agencies (and ratings companies) can use as a standard identifier for stations.

I was going to try to argue with you on that, but I'm having a hard time coming up with a good counterpoint

Being a TV guy I have to beg a bit of ignorance about how ratings are done in radio -- so if (hypothetical) KXOL-FM 96.3 Los Angeles "moves to 104.3"*, buyers want the ratings to go with the call letters, not the frequency? I suppose for that particular (and important!) purpose that actually makes quite a bit of sense.

Although... we had a situation here in Nashville last year, where a station flipped from sports to CHR without changing call letters. A few years ago, another station flipped from rock to country, again without changing (heritage) calls. If you bought **WKDF thinking it was the rock station, you probably didn't get what you paid for. (of course, you checked before buying -- but in that case does it really matter whether you looked up "WKDF" or "#16896"?) Such flips are not unique to Nashville. I can also think of situations here and in Milwaukee where stations changed call letters without a significant change in format.

In any case, as someone else posted, even if the FCC stopped requiring - or even issuing - call letters, that wouldn't mean stations would have to stop using them. If you already had calls you could keep them, and if you didn't, you could assign yourself a set, as long as you didn't run into trademark issues with another station.



* "Moves to 104.3" of course really means 104.3 changes calls from KBIG-FM to KXOL-FM and changes format to whatever they were running on 96.3.

** time on WKDF. Not buying the whole station.

 

[davideduardo]

Being a TV guy I have to beg a bit of ignorance about how ratings are done in radio -- so if (hypothetical) KXOL-FM 96.3 Los Angeles "moves to 104.3"*, buyers want the ratings to go with the call letters, not the frequency?

Agencies and large in-house buyers probably don't even know the frequency of most if not all the stations they buy. What they look for is the size of the audience in the specific age (or other criteria) they are looking for so they can evaluate that audience vs. the rates the station quotes.

If the KXOL calls and format move to another frequency, the KXOL past and future ratings are attached to the call letters, per an Arbitron rule.

Although... we had a situation here in Nashville last year, where a station flipped from sports to CHR without changing call letters. A few years ago, another station flipped from rock to country, again without changing (heritage) calls. If you bought **WKDF thinking it was the rock station, you probably didn't get what you paid for. (of course, you checked before buying -- but in that case does it really matter whether you looked up "WKDF" or "#16896"?)

The Arbitron software stations and agencies use can show format. However, in many cases a station is bought without even lookiing at format. And a station with low ratings that switches format is not likely to be on an agency buy anyway, as the obvious reason for the flip is lack of revenue or revenue potential.

I'm guilty of telling this story before: when in Argentina programming a station, we licensed some software from a US company. That company required call letters in the contract, and we didn't know them. We could not find them anyplace in the station. It took two days to call the government equivalent of the FCC and for them to find the call letters. Of course, in a country with only a few hundred licensed stations, it's easy to tell them apart (the real issue is the thousand or so pirates...).

So, you can get along without calls, but it certainly makes having a unique, licenced number look good.

 

[radioplayer]

As someone who recently was a consultant for a station involving a listener with an interference 'complaint',
I can tell you that the call letter 'top of the hour' requirement SAVED the station from a lot of unnecessary hassle!

It turned out that another local station was the issue & my station was not, but had the Calls and the legal ID requirement not been the case the station that I was in consultation with more than likely would STILL be dealing with the interference issue.

Legal ID's may not be as useful from a marketing standpoint anymore, but this is still about transmitters and broadcasting a carrier wave and there still are issues which can effect the signal(s) and their propagation out there.

I think the issue ought to be looked at in technical terms and sometimes the simple ID is far superior than any fancy computerized triangulation of sorts on a signal.

For the programmers, seriously, a mere 2 seconds for an ID isn't asking for much. I suppose however, that given the course of 24 x 2 that one could almost sell 1 30 and a perhaps another 20 sec spot in a whole broadcast day.....

Is radio becoming this desperate?

 

[spunker88]

No it won't and shouldn't happen for a while.

With PSIP's since it accompanies a digital signal, you have to receive the PSP when you receive the station. With RDS data will come in garbled or not at all if the station signal is weak, plus not all FM stations have RDS or HD yet, and many with RDS don't transmit call letters. On AM few stations broadcast in HD and you have to have a strong signal to get the call letters.

If we were to go to a 100% digital radio service, then legal ID's would be obsolete because it would become just like DTV with PSIPs.

 

[w9wi]

No it won't and shouldn't happen for a while.

With PSIP's since it accompanies a digital signal, you have to receive the PSP when you receive the station. With RDS data will come in garbled or not at all if the station signal is weak, plus not all FM stations have RDS or HD yet, and many with RDS don't transmit call letters. On AM few stations broadcast in HD and you have to have a strong signal to get the call letters.

If we were to go to a 100% digital radio service, then legal ID's would be obsolete because it would become just like DTV with PSIPs.

I suppose not all RDS decoders are equal (and different stations inject it at different levels) but in general in my experience if I've got a 60dBu signal, the RDS works..

Do we consider continuing to issue call letters, but not requiring stations to use them on the air **if** they transmit the assigned call letters via RDS and/or HD-PAD? (what about, with RDS, allowing stations to put anything in the PS field as long as the PI field matches the callsign=>PI standard?)