Is this legal?

[e-dawg]

Is this legal for KOIT to say these call letter on the top of the hour?

"FM 96 POINT 5 AND AM 12-60 KOIT AM AND FM SAN FRANCISCO"

If not, then how should KOIT read their call letter?

 

[KevinFodor]

Call letter rules say:

Call letters immediately followed by City Of License.

Many AM/FM combos would ID "WXXX AM and FM/City" back in the 1960's, so I would think it's probably ok.

 

[1069_KIFR]

Yes.

 

[tophour]

It's not technically legal, but it follows the spirit of the law if not the letter, so they're not going to get in any trouble for it.

 

[michael hagerty]

I don't understand...what's the technicality? Set aside the frequencies..."KOIT AM and FM, San Francisco" is a legal ID, isn't it?

My favorite of all time was in the mid 80s when KIIS AM/FM Los Angeles were simulcasting and came up with this whopper:

"102-point-7, KIIS-FM is K-I-I-S AM and FM, Los Angeles."

---Michael Hagerty

 

[e-dawg]

I thought call letters have to be this.

KOIT San Francisco, KOIT-FM San Francisco instead of KOIT AM AND FM San Francisco.

 

[boiseengineer]

73.1201 Station identification
<snip>
b) Content. (1) Official station identification shall consist of
the station's call letters immediately followed by the community or
communities specified in its license as the station's location;
Provided, That the name of the licensee, the station's frequency, the
station's channel number, as stated on the station's license, and/or the
station's network affiliation may be inserted between the call letters
and station location.
<snip>
(c) Channel--(1) General. Except as otherwise provided in this
paragraph, in making the identification announcement the call letters
shall be given only on the channel, or channels in the case of a broadcaster that is
multicasting more than a single channel, identified thereby.
<snip>
(ii) In the case of aural broadcast stations, such announcements, in
addition to the information required by paragraph (b)(1) of this
section, shall include the frequency on which each station is operating.

 

[davideduardo]

I thought call letters have to be this.

KOIT San Francisco, KOIT-FM San Francisco instead of KOIT AM AND FM San Francisco.

ID is legal 100% with KOIT and KOIT FM, San Francisco. "AM" is not part of anyone's calls...

But, as noted, there is no chance of getting cited as they are doing the right interpretation if not a perfect one. Calls are such an anachronism that you can get away with most anything now.

 

[oldiesfan6479]

I thought call letters have to be this.
KOIT San Francisco, KOIT-FM San Francisco instead of KOIT AM AND FM San Francisco.

e-dawg is correct if Uncle Charlie feels like strictly interpreting his rule--
but he probably won't, as long as you make a reasonable attempt at doing
something resembling a legal ID somewhere near the TOH (even "buried"
between spots four and five in the :50 stopset ;D).

Somewhere in the (part 73) rules it states that in a simulcast, each
station must be IDed separately, as exampled above.

There are other ID "infractions" which are no doubt also glossed over,
such as KSLX-FM Scottsdale (-FM being part of their legal calls)
being IDed as "KSLX Scottsdale."

Should we also mention a Gumpdusky-owned AM daytimer in the PHX market
which fails to ID itself at sign-on and sign-off?

 

[davideduardo]

I thought call letters have to be this.
KOIT San Francisco, KOIT-FM San Francisco instead of KOIT AM AND FM San Francisco.

e-dawg is correct if Uncle Charlie feels like strictly interpreting his rule--
but he probably won't, as long as you make a reasonable attempt at doing
something resembling a legal ID somewhere near the TOH (even "buried"
between spots four and five in the :50 stopset ;D).

Somewhere in the (part 73) rules it states that in a simulcast, each
station must be IDed separately, as exampled above.

There are other ID "infractions" which are no doubt also glossed over,
such as KSLX-FM Scottsdale (-FM being part of their legal calls)
being IDed as "KSLX Scottsdale."

Should we also mention a Gumpdusky-owned AM daytimer in the PHX market
which fails to ID itself at sign-on and sign-off?

All these little modifications to a strict interpretation of the rules have been going on for decades, and the FCC has not cited anyone I know of. The "close to the top of the hour..." thingie is totally ignored, and things are put between call and COL that are not totally proper... but the FCC does not care, it seems.

Hopefully, IDs will not be required in the future. Call letters are really not necessary today.

 

[Marv-L.A.]

Call letters are and always will be required for diarykeepers.

Otherwise, the ratings system goes into the tank, and so will radio station revenues. Many radio stations do not announce their call letters nearly enough, and then they're shocked when the station and/or its ratings go into the basement.

 

[LKellerIII]

"Call letters are and always will be required for diarykeepers. Otherwise, the ratings system goes into the tank, and so will radio station revenues. Many radio stations do not announce their call letters nearly enough, and then they're shocked when the station and/or its ratings go into the basement."

Is that really still true? If so, it's an anachronism. How many people pay attention to that once an hour station ID to know Star 101.3 is KIOI. At least in the old days, if you wrote down K101 in the diary, it LOOKED like KIOI. The same thing with "Live 105" (KITS), "Alice " (KLLC), Kiss-FM (KISQ) and so on...

 

[davideduardo]

Call letters are and always will be required for diarykeepers.

No, they won't. In fact, the diary is going away in a rollout of the Portable People Meter which detects an encoded signal every 4.5 seconds on each station, HD channel or stream. Arbitron will not need calls, name, dial position or anything to identify a station.

While the diary continues to exist as it migrates towards extinction, calls are among the least frequent ways people mention stations in diaries. Dial position is th emost frequent, with as much as 85% of metions for FMs containing the frequency. Names are second, calls are third, shows are next. Calls are mostly writtend down by listeners to heritage AMs, and since that listenership is shrinking, we can say calls are of no importance in the future for audience measurement.

Otherwise, the ratings system goes into the tank, and so will radio station revenues. Many radio stations do not announce their call letters nearly enough, and then they're shocked when the station and/or its ratings go into the basement.

As I just said, this is not a true statement. Calls are relatively unimportant to most stations; many get ZERO call letter mentions, including the #1 and #2 25-54 stations in LA at this moment. Diarykeepers can write down calls, dial position, name, talent and the station gets credit. In the PPM, calls are totally irrelevant.

 

[davideduardo]

Is that really still true?

It never was true. Any unique identifier has always qualified, including frequency, name, talent name, show name, etc. Even a contest name will get credit.

 

[rickradio]

Is this legal for KOIT to say these call letter on the top of the hour?

"FM 96 POINT 5 AND AM 12-60 KOIT AM AND FM SAN FRANCISCO"

Since the call letters are the same for both AM and FM, and the city of license is the same for both AM and FM, "KOIT AM and FM, San Francisco" is perfectly legal.

 

[LKellerIII]

"It never was true. Any unique identifier has always qualified, including frequency, name, talent name, show name, etc. Even a contest name will get credit."

There was a thread on this board about 6 months ago regarding that "bumper" (if that's what it's called) that 99.7 uses in the middle of the commercial break. First it was Sue Hall saying "99 - KFRC - 99.7." Since the format change, it's that annoying "Brad" guy saying something like "Movin' 99 - Movin' 99.7"

A number of people wrote in to say that this was done for diary keepers - and that as long as the station was identified by the listener in SOME way - image name, or close to the right frequency, it got credit.

 

[davideduardo]

"It never was true. Any unique identifier has always qualified, including frequency, name, talent name, show name, etc. Even a contest name will get credit."

There was a thread on this board about 6 months ago regarding that "bumper" (if that's what it's called) that 99.7 uses in the middle of the commercial break. First it was Sue Hall saying "99 - KFRC - 99.7." Since the format change, it's that annoying "Brad" guy saying something like "Movin' 99 - Movin' 99.7"

A number of people wrote in to say that this was done for diary keepers - and that as long as the station was identified by the listener in SOME way - image name, or close to the right frequency, it got credit.

Any unique identifier will get a station credit. That includes calls, name, exact frequency, positioning statement, DJ or show, program name, contest name, etc. Any approximate identifier goes into waht is called ascription. For example, if in one county of a metro, two stations have some kind of a signal, and the diary says, "American Top 40" Arbitron will decide who gets ccredit based on a complex formula that comes down to the past cume of each station.... if station A has double the trailing cume of B, then they get twice as many chances to get the credit via the ascription procedure. Same with inexact dial positions. Someone writes "FM 107" then any station at 107 gets a chance for it based on ascription. On the other hand, Movin 99 will go directly to Movin as the name is unique.

Right now, any phrase on the air is intended to cue the diarykeeper to write down the listening. By early next year, SF will have the people meter and this will be a moot point.

 

[Marv-L.A.]

David, I see where you're coming from, and PPM will change the ballgame dramatically, but if I'm a diarykeeper and I write down 'Great American Country ' as the station I listen to (that's how the station was identified last year while I was on vacation--no dial position, no call letters), how the hell is the person tabulating the results from my diary going to know which station I'm listening to with such an anemic and worthless ID?

FWIW, this station is in Las Cruces, NM.

I also heard tons of similarly worthless station IDs (if you can call them that!!) throughout Arizona, New Mexico & Texas last October.

 

[w9wi]

Since the call letters are the same for both AM and FM, and the city of license is the same for both AM and FM, "KOIT AM and FM, San Francisco" is perfectly legal.

Strictly speaking, the call letters are NOT the same; the call letters of the FM station are KOIT-FM, not KOIT. Strictly speaking, a legal ID would be "KOIT San Francisco; KOIT-FM San Francisco".

As others have said, "KOIT AM and FM San Francisco" certainly complies with the *spirit* of the rule and stations have been doing it that way for decades without the FCC getting bent out of shape.

 

[cARLOS Blake]

As long as it sez KOIT, San Francisco that takes care of it for both frequencies(if it's a simulcast of course, then it would be dumb to use the same legal for 2 seperate format types). It could say "KOIT, the city by the bay's hottest jams" ...& then proceed into a jam recipe...then say ,... San Francisco :25 later, as long as it sez call letters, then city of license...they can get as fancy as they want. No need to have the dial position/s.
A nuisance for me used to be when we recieved a Browns feed from our flagship & had to pot down their legal at the top & BOTTOM of the hour & just when you thought they were done & we potted ours back up they'd sneak in a quick....WWWE, CLEVELAND..............that was in the early 90's.