EMF name change?

[Delete My Account]

I recall in a very ancient filing I can no longer locate, in the early days of the LPFM movement, EMF actually said that if local churches were enabled to operate low power stations, it would potentially damage their fundraising, thereby harming the sustenance of their programming.

Now I understand other broadcasters had objections to LPFM and the right to file them. But it seems a poor argument for the organization benefitting from no local origination requirements on 250 watt signals (at the time, they hadn't been buying the full powers as they later did) to tell the government "hey, we're doing well with how we worked this into a national network, but if you let a local church do it, that might harm our business model." Even for PR reasons, I thought it was bad form.

To me it's similar to being upset at social media companies when you're making money off their "free" platform. EMF was building the competitive advantage through their savvy, but asking the government to exercise protection of their business over the local Christian groups. Too, it makes little sense as things turned out. Of the LPFMs that even got built and stay on the air, I doubt many of them have much impact on EMF.

 

[secondchoice]

I'm not a tax attorney, but I know a few. There are differences between a foundation and a corporation. The tax laws in the state of Tennessee are not the same as the laws in California. Tennessee appears to be trying to become the new Delaware or Nevada in terms of corporate tax laws.

As a "non profit" it doesn't really matter that much.

IMHO the move to Tennessee was because of the lower cost of living, no state income tax for the employees, and last and probably the most important reason: A lot of CCM is recorded in the Nashville studios.

 

[davideduardo]

Mark is correct that, until the main studio rule was repealed, non-commercial operators had to apply for waivers with a justification and an explanation of where the public file would be kept. I suppose the FCC could’ve granted them systematically and/or presumed them in the public interest, but the waivers had to be filed.

And, is there any case where a waiver was not granted?

I always found EMF's waiver applications to be somewhat cringeworthy since they usually more or less pleaded poverty, even when the organization was raking in tens of millions every year.

And their point was that they would not be able to cover operations were each station to require a stand-alone studio location.

Beyond that, a huge percentage of EMF's stations are translators. I don't recall for how long, but for as long as I remember non-com translators were not required to have "local" studios and they did not have to be within the contours of the originating station.

I don’t ever recall any numbers as part of the application to show where those dollars were going and why they couldn’t be used to staff and maintain a main studio.

But EMF for decades has been among the highest rated non-profits for transparency and disclosure. The full financials, available easily, demonstrate why they operated as a network, not a set of independent stations.

 

[Kent]

And, is there any case where a waiver was not granted?

I don't know. I just know the waivers had to be filed. I'm not sure what the FCC's rejection rate of waivers for commercial stations was either. I know far fewer commercial stations filed them, but I understand it has happened before.

Beyond that, a huge percentage of EMF's stations are translators. I don't recall for how long, but for as long as I remember non-com translators were not required to have "local" studios and they did not have to be within the contours of the originating station.

Translators have never required local studios. Even non-fill-in translators for commercial operations don't require local studios. They just have to get the signal over-the-air. Translators in the noncommercial band, of course, may be fed by alternate means even if they are outside of the primary contour of the originating station, though I understand that exemption doesn't apply to translators in the commercial band, even if they air noncommercial programming.

 

[Miss Tuned]

It boils down to something very simple: nobody forces anyone to give any money to EMF, and the listeners who give money presumably value what they get in return. It doesn't matter whether you or I think they're spending their money wisely, people have given it freely. If the public hated K-Love's non-local output and thought it was ripping off donors and providing crappy programming, it would quickly disappear through lack of funds.

 

[davideduardo]

I don't know. I just know the waivers had to be filed. I'm not sure what the FCC's rejection rate of waivers for commercial stations was either. I know far fewer commercial stations filed them, but I understand it has happened before.

I had to file a main studio waiver for WQII in San Juan in 1975 to locate to the site of the FM on a hill in the municipio (Puerto Rico has neither cities nor counties, just municipalities). It was granted, but the process of explaining that, technically, no station in Puerto Rico had a "city of license" to begin with really confused the M Street folks.

Our attorney at Koteen & Burt was tempted to send them the original charters of the Spanish Colony of Puerto Rico in 16th Century Spanish but, instead, we got a statement from the Commonwealth Statistics Bureau clarifying the issue.

Translators have never required local studios. Even non-fill-in translators for commercial operations don't require local studios. They just have to get the signal over-the-air. Translators in the noncommercial band, of course, may be fed by alternate means even if they are outside of the primary contour of the originating station, though I understand that exemption doesn't apply to translators in the commercial band, even if they air noncommercial programming.

And my point is that much of the EMF portfolio is made up of translators. When I still had access to BIA, I once checked (a few years ago) and more than 70% of all EMF licensed facilities were translators. While that still makes them a very big operator of "full" facilities, they have a significant translator base.

 

[Miss Tuned]

Translators have never required local studios. Even non-fill-in translators for commercial operations don't require local studios. They just have to get the signal over-the-air. Translators in the noncommercial band, of course, may be fed by alternate means even if they are outside of the primary contour of the originating station, though I understand that exemption doesn't apply to translators in the commercial band, even if they air noncommercial programming.

Do they have to actually get the signal over the air, or does it have to just be a 100% simulcast of the originating station's output regardless of technical source? I'm thinking of FM translators of AM stations, which would sound terrible if they were actually rebroadcasting the AM, or to a lesser extent HD-fed stations, which would sound a bit tinny compared to analog if they were relaying the HD on FM.

 

[CTListener]

It boils down to something very simple: nobody forces anyone to give any money to EMF, and the listeners who give money presumably value what they get in return. It doesn't matter whether you or I think they're spending their money wisely, people have given it freely. If the public hated K-Love's non-local output and thought it was ripping off donors and providing crappy programming, it would quickly disappear through lack of funds.

The obsession with "local" must be purely American. Even older listeners over there, like the ones to your Boom Radio, seem to love what that station is providing, even if it isn't originating from Leeds or Bristol or Newcastle or wherever else they may be listening.

 

[Miss Tuned]

The obsession with "local" must be purely American. Even older listeners over there, like the ones to your Boom Radio, seem to love what that station is providing, even if it isn't originating from Leeds or Bristol or Newcastle or wherever else they may be listening.

I'm afraid we have just as many people who complain endlessly when a radio station is no longer local - not so much for the likes of Boom which have always been national platforms, but all the stations that were a live-and-local full service for a town back in 1992 and are now some network or other.

As for K-Love, is it out of the question that the national programming is a strength? For this type of station, the listener may value and take comfort from feeling like they're part of a community of listeners that stretches coast-to-coast.

 

[davideduardo]

The obsession with "local" must be purely American. Even older listeners over there, like the ones to your Boom Radio, seem to love what that station is providing, even if it isn't originating from Leeds or Bristol or Newcastle or wherever else they may be listening.

I believe, from my historical perspective, that legislators in D.C. in the later 20's and early 30's enforced and promoted "localism" to prevent broadcasters from having many stations or very powerful ones. Senators feared stations that, alone, could cover a whole state or region and made sure that we got lots of Class IV's with 250 watts and nothing over 50 kw (with one exception that was eventually cancelled).

Meanwhile, all across Latin America, stations created networks using shortwave to relay programs... and then by the 50's FM. In fact, many traveled to New England to see how Armstrong had engineered a network of FMs that were, at the same time, relay stations. This was copied in many nations, such as Colombia, Venezuela and Chile, to link AM stations nation wide. The linked stations did not originate local programming, and nobody complained as they got "big city radio" in tiny little markets!

 

[Kent]

Do they have to actually get the signal over the air, or does it have to just be a 100% simulcast of the originating station's output regardless of technical source? I'm thinking of FM translators of AM stations, which would sound terrible if they were actually rebroadcasting the AM, or to a lesser extent HD-fed stations, which would sound a bit tinny compared to analog if they were relaying the HD on FM.

Within the primary signal contour, a translator may be fed directly or through alternate means. The requirement that translators be fed over-the-air only applies to non-fill-in translators (and non-fill-in translators in the commercial band at that). In the case of FM translators for AM stations, they are considered fill-in translators due to the mileage and/or signal contour restrictions and are usually fed directly.

Most of the translators that relay HD subchannels are also fill-in translators. I believe most are fed directly as well. While I understand it's theoretically possible to relay an HD subchannel outside the primary signal contour, I'm told it's very difficult in practice because any translator that did so would have to capture the HD signal over-the-air.

 

[Mark Roberts]

I don't know. I just know the waivers had to be filed. I'm not sure what the FCC's rejection rate of waivers for commercial stations was either. I know far fewer commercial stations filed them, but I understand it has happened before.

The staff probably didn't want to have to deal with another situation like the Milam-Lansman petition, which aroused the angry evangelical hornets from their nests, bombarding the FCC offices with letters, and later, emails, lonnnnnng after that petition had been rejected. So the easy track is just to approve them if they're not egregious and go on. While the intent may not have been to give religious broadcasters kid-glove treatment, that's effectively what has happened.

Translators have never required local studios. Even non-fill-in translators for commercial operations don't require local studios. They just have to get the signal over-the-air.

This one caught out Eastern New Mexico University, which has a translator on the commercial part of the band in Texas, intended for KENW, but relaying a commercial station because they can't get the KENW signal out to it. If KENW had been a religious broadcaster, they might have gotten away with it, but KENW took the honest approach, to their credit.

Translators in the noncommercial band, of course, may be fed by alternate means even if they are outside of the primary contour of the originating station, though I understand that exemption doesn't apply to translators in the commercial band, even if they air noncommercial programming.

This is one reason translators are a secondary service. They can always be bumped if a primary service conflicts.

 

[Mark Roberts]

The obsession with "local" must be purely American. Even older listeners over there, like the ones to your Boom Radio, seem to love what that station is providing, even if it isn't originating from Leeds or Bristol or Newcastle or wherever else they may be listening.

Some of it is that the United States is a big, diverse country. Differences have shrunk over time, and are less notable than before. But some are still there. You're not going to find a Hy-Vee in California, for one thing.

 

[Kent]

IMHO the move to Tennessee was because of the lower cost of living, no state income tax for the employees, and last and probably the most important reason: A lot of CCM is recorded in the Nashville studios.

I suspect it's probably a lot of the latter as well as the larger church presence. Not sure if K-Love has any staff with nationwide jobs, but, if your job requires a lot of travel, you can get around the country from Nashville much more easily than you can from Sacramento.

No income tax is great (though Tennessee does tax unearned income), but the notion that Tennessee has a low cost of living is mostly a myth. Tennessee borders eight states and has a higher cost of living and tax burden than all but two of them. The sales tax in Tennessee is really high, and the property tax rate isn’t much different from California's. Plus, the median housing prices in Nashville and Sacramento are about the same. If you’re on the lower side of the income spectrum, you won't live better in Nashville.

 

[TheBigA]

No income tax is great (though Tennessee does tax unearned income)

That was repealed in 2021:

https://revenue.support.tn.gov/hc/en-us/articles/360057828631-HIT-3-Hall-Income-Tax-Repealed-Beginning-January-1-2021

 

[Kent]

That was repealed in 2021:

https://revenue.support.tn.gov/hc/en-us/articles/360057828631-HIT-3-Hall-Income-Tax-Repealed-Beginning-January-1-2021

Then, I stand corrected on that matter. Thanks for the update.

 

[fybush]

I live in "high-tax" New York, and it's always an unpleasant hit to get my annual property and school tax bills.

And then I talk to people who've left for areas with "lower taxes," and it turns out TANSTAAFL is in full effect for most of them. Fewer services, worse services, worse schools that then pull property values down, and lots of extra fees for things they were accustomed to having paid for out of those "high" taxes.

To keep this topical, it's worth noting that whatever advantages there are to being in Tennessee, a decent chunk of the EMF engineering and technical brain trust didn't have any desire to move from Sacramento.

 

[Theater of My Mind]

Meanwhile, all across Latin America, stations created networks using shortwave to relay programs... and then by the 50's FM. In fact, many traveled to New England to see how Armstrong had engineered a network of FMs that were, at the same time, relay stations. This was copied in many nations, such as Colombia, Venezuela and Chile, to link AM stations nation wide. The linked stations did not originate local programming, and nobody complained as they got "big city radio" in tiny little markets!

An obstacle to doing good national live radio in the United States is the number of time zones in this vast country. If you want to have a national station with a regular schedule such as morning and afternoon drive shows, then you have to time shift the programming across all the time zones which means the shows will be pre-recorded in at least 2 or 3 of them. That may not be a concern for a format with no dayparts and/or no live shows but it's not like this is Colombia or Venezuela where one live show can wake up the whole country at the same time. Even in Chile, most of the country is in sync enough to do that, give or take just one hour.

 

[CTListener]

An obstacle to doing good national live radio in the United States is the number of time zones in this vast country. If you want to have a national station with a regular schedule such as morning and afternoon drive shows, then you have to time shift the programming across all the time zones which means the shows will be pre-recorded in at least 2 or 3 of them. That may not be a concern for a format with no dayparts and/or no live shows but it's not like this is Colombia or Venezuela where one live show can wake up the whole country at the same time. Even in Chile, most of the country is in sync enough to do that, give or take just one hour.

SiriusXM doesn't seem to mind that its hosted shows, on the channels that have them, all run on Eastern Time schedules, even if it means that listeners in California hear the "morning drive" shows between 1 and 5 a.m. (or miss them entirely because they're in bed), and that's been the case ever since it was two separate companies. Since Sirius, XM, and the current SiriusXM had and have their HQ on the East Coast, and since the Eastern time zone has the largest population of the four zones In the contiguous U.S., this is convenient for management and talent alike, as well as the largest share of the service's listeners. Subscriber complaints from PST/PDT Land are ignored.

 

[xkxrx]

Subscriber complaints from PST/PDT Land are ignored.

I'm not familiar with SiriusXM, but isn't there a way you can just listen to the show after it airs, like you can with a podcast?