I'm glad to see the argument being raised by the Commission, but I think they need to look carefully at what all they're proposing and consider the effect on all operators large and small.
I'm not altogether against dereg (I think there have been positives...and negatives from it), but I also think the FCC abdicated its' oversight responsibilities badly in the past 10 years or so. So, while I'm against radical changes, I am for some limited regulation combined with oversight from the FCC.
I think a station operator should be required to tell the Commission at license renewal time how much, or how little local news and public affairs programming will be presented. One would think every station is capable of doing something, even if, due to smaller staffing, the amount of such programming is more limited.
(I mean: a pre-recorded 10 minute conversation with the local school superintendent, or the local sheriff, can be considered "public affairs" on "issues" of interest that you are supposed to have in your public file. Perhaps the typical 30 minute PA show isn't producable on a tiny scale...but other things could be done, and re-aired on other days/dayparts.) A one-hour Saturday morning call-in program on local issues could also qualify. (And hey...maybe you'd get a sponsor or two there.) I'm sorry, I don't buy the idea that, with a tiny staff, nothing can be done. (It's one of the responsibilities of that license you hold.)
Any suggestion that voice-tracking needs to be "identified" as such is, for the most part, a crock. Done properly, voice-tracking can accomplish what it's designed to accomplish. But, voice-tracking should not userp the responsibility of the owner-operator to make sure emergency messages get broadcast properly and in a timely manner. A station is licensed to serve the public "interest, convenience and necessity". I think at renewal time, a station should submit to the FCC it's "emergency broadcast plan" and explain how, during times of necessity, the station will serve the public. At renewal time, the station can document to the FCC how the plan worked, lessons learned and what changes were made to the plan to make it better.
24/7 operators? That depends. If you're operating a multiple station cluster in a town, where multiple stations are on the air 24/7, one would think hiring a college kid or two to work from 12 am to 4 am doing network commercial dubs, or dubs and tags while monitoring the operations of all of the stations and being prepared to air weather and/or emergency information "should" be possible. However, a well drawn up "emergency plan" that is taken seriously and actually put in use when needed might, indeed, suffice.
In smaller markets, whoever is the "Program Director" needs to understand it is not, nor will it ever be, a 5 day, 40 hour work week. That's the responsibility you take on for making the (ah-hem) "big bucks". When I was PD of a smaller-town station, I slept with a weather radio in my bedroom and, quite often, got out of bed and drove to the station at 2 AM to do coverage of a local weather situation. I did this, because I wanted to "protect the license". It's the stations that continue "on the bird" or "on the computer" when the local tornado sirens are going off airing one "warning" produced by an EAS receiver that are the ones that catch the grief, and should. These are extenuating circumstances and every licensee, large or small, should be prepared to deal with them.
And this often-spoken of suggestion that stations be required to air "locally produced music" by "local" artists smacks to me of the Canadian content laws that have wreaked havoc with Canadian broadcasters over the years. In the 35 years I've been in radio, I can remember only about a dozen instances where a local record broke through well enough to deserve regular airplay. No artist has, or should have a constitutional right to radio airplay. However, it's not true that all of radio ignores local music. Ask the listeners of WWHP in Farmer City, Illinois...or the listeners to WWCD in Grove City, Ohio, which has featured local acts. This smacks to me of a musical form of "Fairness Doctrine" that is trying to be forced upon talk radio.
And, oh yeah...on "The Fairness Doctrine". You want it back? Fine. But require the "liberal" talk stations to carry "conservative" programming. Make it apply to the over the air TV networks, and to PBS, too.
After all: fair is fair.
