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KEYMARKET'S COMMITMENT TO THE INTEGRITY OF

R

rogertoo

Guest
LOCAL BROADCASTING..................

Obviously, there isn't one. Kill off all programming from the local side, but expect the local advertisers to hang in there. Why should an east L business advertise on WOHI or 104, when you offer NO LOCAL CONTENT? No local announcers talking about local sports, weather, community interest events. Are you talking about the local christmas parades? mentioning your support for the holiday food drive, and how your live and well liked afternoon "PERSONALITY" will be side by side with the locals accepting your donations?

How about the LOCAL NEWS and info that WOHI listeners came to expect over the years.....where is that? NO EMPLOYESS WERE KILLED IN THE SHAKEUP OF OUR FORMATS....... loosly anyway..... but when you pull someones airshift, some "leave on there own to seek a position elsewhere.... Sure S.K. is still with the company as is K.B. but you sure don't hear them on the air live in a regular airshift....... You run multiple stations with one airstaff... good for business, bad for local radio.

Funny how there was a time when most of these stations were staffed, LIVE and profitable....... Now, they are shells (or should I say shills) but there is 'mo money for the boys in the suits......

I do have to wonder why you have an expectation of local businesses to continue to spend advertising dollars with your simulcasted "NON PITTSBURGH" stations, when you refuse to support the communities from which you stole their stations?

How does ESPN serve the community? It serves only your bottom line, and you certainly have to make no effort to "SELL" the format... let a few agency dollars cover that...... You didn't pick up and move a furniture store from E.L to a more profitable Moon township location..... You told a government agency whatever you had to get approval to pull up stakes for 104.3. Yet you have no problem sending a salesman into an E.L. business.... Do you still run the "YOUR HOMETOWN STATION SWEEPER"? Which hometown is that? Steubenville? East Liverpool? Carnegie? Pittsburgh? Wampum? Chester?........

Sure you paid for it, it's yours, and this is America, you should be able to do what you want with your business.... Really though all you show is that you are all about the dollar, no commitment to or compassion for, your listeners, the community, or your employees. A regional version of Clear Channel and the other BIGTIME broadcasters....

Generic Radio on the cheap, same as business model type as a Bicoastal, or dozens of other copycat versions of MEGA radio... bigger is better but boring is hell. You don't have to make each station a success on it's own... five mouths only have to feed one stomach......

Seriously, congratulations on your success, but shame on you for doing it at the expense of the local communities you once served. You should also congratulate me for my intelligence and insight as I recognized your ultimate plans several years ago, and pointed them out... I guess my years of experience and broadcast interest allowed me, as well as many other who have an interest in radio in this area, to see the whole picture... Hey remember, sometimes people have far more brains and abilities than their actual position would indicate. Just because a rocket scientist has a job flipping burgers, doesn't mean he is only qualified to flip burgers!
 
The Local Community's commitment to KEYMARKET

While you're on a roll, about about a similar rant for the listeners who live in the hinterlands who selfishly listen to whatever station happens to play what they want to hear, regardless of whether it's "local" or not. How about a rant about people like the citizens of Washington, PA who don't listen to WJPA because they just don't like oldies.

After all, if broadcasters are supposed to cater to "local needs" even if most local people seldom tune in, then shouldn't local listeners be equally compelled to tune in to local stations even if they don't like the programming?

The thing is, people tune in because they like what's being broadcast. Most listeners just don't care about "local" content.

> LOCAL BROADCASTING..................
>
> Obviously, there isn't one. Kill off all programming from
> the local side, but expect the local advertisers to hang in
> there. Why should an east L business advertise on WOHI or
> 104, when you offer NO LOCAL CONTENT? No local announcers
> talking about local sports, weather, community interest
> events. Are you talking about the local christmas parades?
> mentioning your support for the holiday food drive, and how
> your live and well liked afternoon "PERSONALITY" will be
> side by side with the locals accepting your donations?
>
> How about the LOCAL NEWS and info that WOHI listeners came
> to expect over the years.....where is that? NO EMPLOYESS
> WERE KILLED IN THE SHAKEUP OF OUR FORMATS....... loosly
> anyway..... but when you pull someones airshift, some
> "leave on there own to seek a position elsewhere.... Sure
> S.K. is still with the company as is K.B. but you sure
> don't hear them on the air live in a regular airshift.......
> You run multiple stations with one airstaff... good for
> business, bad for local radio.
>
> Funny how there was a time when most of these stations were
> staffed, LIVE and profitable....... Now, they are shells
> (or should I say shills) but there is 'mo money for the boys
> in the suits......
>
> I do have to wonder why you have an expectation of local
> businesses to continue to spend advertising dollars with
> your simulcasted "NON PITTSBURGH" stations, when you refuse
> to support the communities from which you stole their
> stations?
>
> How does ESPN serve the community? It serves only your
> bottom line, and you certainly have to make no effort to
> "SELL" the format... let a few agency dollars cover
> that...... You didn't pick up and move a furniture store
> from E.L to a more profitable Moon township location.....
> You told a government agency whatever you had to get
> approval to pull up stakes for 104.3. Yet you have no
> problem sending a salesman into an E.L. business.... Do you
> still run the "YOUR HOMETOWN STATION SWEEPER"? Which
> hometown is that? Steubenville? East Liverpool? Carnegie?
> Pittsburgh? Wampum? Chester?........
>
> Sure you paid for it, it's yours, and this is America, you
> should be able to do what you want with your business....
> Really though all you show is that you are all about the
> dollar, no commitment to or compassion for, your listeners,
> the community, or your employees. A regional version of
> Clear Channel and the other BIGTIME broadcasters....
>
> Generic Radio on the cheap, same as business model type as a
> Bicoastal, or dozens of other copycat versions of MEGA
> radio... bigger is better but boring is hell. You don't
> have to make each station a success on it's own... five
> mouths only have to feed one stomach......
>
> Seriously, congratulations on your success, but shame on you
> for doing it at the expense of the local communities you
> once served. You should also congratulate me for my
> intelligence and insight as I recognized your ultimate plans
> several years ago, and pointed them out... I guess my years
> of experience and broadcast interest allowed me, as well as
> many other who have an interest in radio in this area, to
> see the whole picture... Hey remember, sometimes people
> have far more brains and abilities than their actual
> position would indicate. Just because a rocket scientist
> has a job flipping burgers, doesn't mean he is only
> qualified to flip burgers!
>
 
Re: The Local Community's commitment to KEYMARKET

...MAYBE THE PRESENTATION and promotion of WJPA is flawed? Lack of effort to integrate the station into the community? marketing problems? under capitalized?
uninteresting, uninspired, non entertaining between the music? doesn't encourage audience interaction? I am sure there are others who could give their opinions on this particular station, but obviously you find a flaw in it. Do you think WJPA could be a viable community oriented station?........



OK, then let's say the biggest cluster in Pitt decides to flip to a format called "The Toad" and they copy the frog playlist and everything else about them, simulcasting 5 stations... now certainly you will have people tuning in to every one of those stations be it frog or toad..... again, EACH station will have a core of listeners, but certainly SOME SEGMENT of the market will suffer.

Are these stations all competing with each other for share, or canabalizing each other for the same group of listeners? do you run them bare bones and count the total audience as one, or do you say Frog A is number 1, Toad B is number 2 Frog D is number 10, and Toad A is number 22........ If Toad A is at 22 do you do a make over and make it a stand alone, or continue to count its audience in the total Toad audience, and then combine Frog and Toad and say the Tight format Country format Is NUMBER 1 overall? meanwhile Toad A was profitable and viable as a local station before making it a part of the Greater Amphibian Empire even though it only had a .4 in the steel city metro book................

pulling the plug on each station as a stand alone,Each with their own audience...It is strictly a "more money" decision as is any Cluster type operation. Let's say I tune into 3ws for oldies...I like the format, and the presentation. Now 3ws flips formats to all disco and no jocks... I am not a fan of disco, and enjoy being entertained by live local announcers, so I scan the dial country... all rock no talk...hip hop..Jack.... country again...another country station that is exactly like the other one... syndicated talk... alternative... morning guy funny then VTs and liners...classic rock.... tne same country as two others down the dial...

Hmmm, no oldies, no personality. I was committed to that oldies station, and now, no oldies anywhere, and not enough personality to hook me into another choice.... Now what?

I listened to WSOM for the local content. When Cumulus moved the station, they dropped the local content... my city news and info my county news and info..... now what? same county WOHI drops local content for ESPN? OK, that's two! Neither station offers me local content, yet I still shop the local business, but since the local businesses are not featured on the local station, maybe I don't shop them as often. Why, I am no longer REMINDED to shop there.
 
Re: The Local Community's commitment to KEYMARKET

...MAYBE THE PRESENTATION and promotion of WJPA is flawed? Lack of effort to integrate the station into the community? marketing problems? under capitalized?
uninteresting, uninspired, non entertaining between the music? doesn't encourage audience interaction? I am sure there are others who could give their opinions on this particular station, but obviously you find a flaw in it. Do you think WJPA could be a viable community oriented station?........



OK, then let's say the biggest cluster in Pitt decides to flip to a format called "The Toad" and they copy the frog playlist and everything else about them, simulcasting 5 stations... now certainly you will have people tuning in to every one of those stations be it frog or toad..... again, EACH station will have a core of listeners, but certainly SOME SEGMENT of the market will suffer.

Are these stations all competing with each other for share, or canabalizing each other for the same group of listeners? do you run them bare bones and count the total audience as one, or do you say Frog A is number 1, Toad B is number 2 Frog D is number 10, and Toad A is number 22........ If Toad A is at 22 do you do a make over and make it a stand alone, or continue to count its audience in the total Toad audience, and then combine Frog and Toad and say the Tight format Country format Is NUMBER 1 overall? meanwhile Toad A was profitable and viable as a local station before making it a part of the Greater Amphibian Empire even though it only had a .4 in the steel city metro book................

pulling the plug on each station as a stand alone,Each with their own audience...It is strictly a "more money" decision as is any Cluster type operation. Let's say I tune into 3ws for oldies...I like the format, and the presentation. Now 3ws flips formats to all disco and no jocks... I am not a fan of disco, and enjoy being entertained by live local announcers, so I scan the dial country... all rock no talk...hip hop..Jack.... country again...another country station that is exactly like the other one... syndicated talk... alternative... morning guy funny then VTs and liners...classic rock.... tne same country as two others down the dial...

Hmmm, no oldies, no personality. I was committed to that oldies station, and now, no oldies anywhere, and not enough personality to hook me into another choice.... Now what?

I listened to WSOM for the local content. When Cumulus moved the station, they dropped the local content... my city news and info my county news and info..... now what? same county WOHI drops local content for ESPN? OK, that's two! Neither station offers me local content, yet I still shop the local business, but since the local businesses are not featured on the local station, maybe I don't shop them as often. Why, I am no longer REMINDED to shop there.

NOW, I have NO STATION IN THIS COUNTY, but 4 were/are licensed to it! You find nothing wrong with that? Different view points I guess.

So to answer your question, I can't support my local content station, because there isn't one! And there isn't the possibility to replace what was taken away. If my local tire dealer closes, Someone else can come into town and open a tire store! It's not possible with a radio station, and THAT is why moveouts are bad for the industry! Sad to say that there is a certain social responsibility that comes with owning a public media, but as time goes on, greed overcomes that responsibility. As I said, while a business owner certainly has the freedom to move his business anywhere he wants, Radio and television fall under a different category. But, as long as the rules have become so lax, then communities will continue to lose their stations and local content without the ability to replace them........ A Froggy ring around the steel city, might be a good business move, but it certainly isn't a responsible social action. As for the AM WOHI.... well again, programming off the bird is certainly cheaper, but at the expense of the LOCALS who did tune in... and they did. More than likely though, it was a revenue decision to kill the local angle, not a lack of local listeners........ You know as well as I do that HIGH DIAL AMs are a tough sell regardless the format. Put one on the air for under 100K, and you have a shot to make it work...... Put a 450K value on it, then that is a nut that you can't crack....... That's BUSINESS...... The Froggy situation is just GREED.






> While you're on a roll, about about a similar rant for the
> listeners who live in the hinterlands who selfishly listen
> to whatever station happens to play what they want to hear,
> regardless of whether it's "local" or not. How about a rant
> about people like the citizens of Washington, PA who don't
> listen to WJPA because they just don't like oldies.
>
> After all, if broadcasters are supposed to cater to "local
> needs" even if most local people seldom tune in, then
> shouldn't local listeners be equally compelled to tune in to
> local stations even if they don't like the programming?
>
> The thing is, people tune in because they like what's being
> broadcast. Most listeners just don't care about "local"
> content.
>
> > LOCAL BROADCASTING..................
> >
> > Obviously, there isn't one. Kill off all programming from
>
> > the local side, but expect the local advertisers to hang
> in
> > there. Why should an east L business advertise on WOHI or
>
> > 104, when you offer NO LOCAL CONTENT? No local announcers
>
> > talking about local sports, weather, community interest
> > events. Are you talking about the local christmas
> parades?
> > mentioning your support for the holiday food drive, and
> how
> > your live and well liked afternoon "PERSONALITY" will be
> > side by side with the locals accepting your donations?
> >
> > How about the LOCAL NEWS and info that WOHI listeners came
>
> > to expect over the years.....where is that? NO EMPLOYESS
>
> > WERE KILLED IN THE SHAKEUP OF OUR FORMATS....... loosly
> > anyway..... but when you pull someones airshift, some
> > "leave on there own to seek a position elsewhere.... Sure
> > S.K. is still with the company as is K.B. but you sure
> > don't hear them on the air live in a regular
> airshift.......
> > You run multiple stations with one airstaff... good for
> > business, bad for local radio.
> >
> > Funny how there was a time when most of these stations
> were
> > staffed, LIVE and profitable....... Now, they are shells
> > (or should I say shills) but there is 'mo money for the
> boys
> > in the suits......
> >
> > I do have to wonder why you have an expectation of local
> > businesses to continue to spend advertising dollars with
> > your simulcasted "NON PITTSBURGH" stations, when you
> refuse
> > to support the communities from which you stole their
> > stations?
> >
> > How does ESPN serve the community? It serves only your
> > bottom line, and you certainly have to make no effort to
> > "SELL" the format... let a few agency dollars cover
> > that...... You didn't pick up and move a furniture store
> > from E.L to a more profitable Moon township location.....
> > You told a government agency whatever you had to get
> > approval to pull up stakes for 104.3. Yet you have no
> > problem sending a salesman into an E.L. business.... Do
> you
> > still run the "YOUR HOMETOWN STATION SWEEPER"? Which
> > hometown is that? Steubenville? East Liverpool? Carnegie?
> > Pittsburgh? Wampum? Chester?........
> >
> > Sure you paid for it, it's yours, and this is America, you
>
> > should be able to do what you want with your business....
>
> > Really though all you show is that you are all about the
> > dollar, no commitment to or compassion for, your
> listeners,
> > the community, or your employees. A regional version of
> > Clear Channel and the other BIGTIME broadcasters....
> >
> > Generic Radio on the cheap, same as business model type as
> a
> > Bicoastal, or dozens of other copycat versions of MEGA
> > radio... bigger is better but boring is hell. You don't
> > have to make each station a success on it's own... five
> > mouths only have to feed one stomach......
> >
> > Seriously, congratulations on your success, but shame on
> you
> > for doing it at the expense of the local communities you
> > once served. You should also congratulate me for my
> > intelligence and insight as I recognized your ultimate
> plans
> > several years ago, and pointed them out... I guess my
> years
> > of experience and broadcast interest allowed me, as well
> as
> > many other who have an interest in radio in this area, to
> > see the whole picture... Hey remember, sometimes people
> > have far more brains and abilities than their actual
> > position would indicate. Just because a rocket scientist
> > has a job flipping burgers, doesn't mean he is only
> > qualified to flip burgers!
> >
>
 
Re: The Local Community's commitment to KEYMARKET

> While you're on a roll, about about a similar rant for the
> listeners who live in the hinterlands who selfishly listen
> to whatever station happens to play what they want to hear,
> regardless of whether it's "local" or not. How about a rant
> about people like the citizens of Washington, PA who don't
> listen to WJPA because they just don't like oldies.
>
> After all, if broadcasters are supposed to cater to "local
> needs" even if most local people seldom tune in, then
> shouldn't local listeners be equally compelled to tune in to
> local stations even if they don't like the programming?

Here's your flaw: listeners are not subject to regulation, other than the limits on numbers of stations receivable and formats available (the former a circumstance of physics, the latter a circumstance of the market). Broadcasters are regulated, and sharply so.

As much as you'd surely like to see the radio industry as a pure business model, it isn't. Broadcasters are granted licenses because the FCC has determined that Broadcaster A will fill a public interest, convenience, and necessity. It's, ab initio, a regulated business and not analogous to a pure business model. The government grants the licenses--that happens in very few other businesses. As part of that license is an obligation to serve the public interest. If a broadcaster doesn't like that requirement, he doesn't have to be a broadcaster. Or, in our republic, he can lobby his legislators to change the law (which would, invariably, lead to the collapse of broadcast regulation itself. Without public interest, part of the rationale behind government regulation fails.)

As much as you and your business sense (and some owners, GMs, and PDs) would like to do away with that public interest, convenience, and necessity requirement, it exists and it is statutory.

While your hyperbole about Washington, PA and WJPA (fact: LOTS of Washingtonians DO listen to WJPA) is nice and all, it doesn't actually support anything. Regardless of what stations have as their public service, listeners will listen to the stations they like. It so happens that WJPA does a damn good job of broadcasting in the public interest: local news and actualities on the hour throughout the day, plus on the half-hour in drive times; local sports, including semi-pro, college, and high school play-by-play; live and local hosts; community remotes and events, including sponsoring job fairs, blood banks, pet adoptions, health clinics, parades; plus extensive community and public affairs segments on Sunday mornings, as well as community "bulletin boards" weekdays. Listeners respond to WJPA--whether its for oldies, or for the community service, or whatever. But Washingtonians listen to WJPA.

I know you want the public interest, convenience, and necessity requirement to be a statutory nullity. But the law doesn't work that way. It's on paper, and in the statute and the FCC rules and regulations for a reason. If it had no effect, it wouldn't be on the books. It is there, and the FCC pulls it out to support lots of things they do: indecency regulation; licensing; allocations; renewals; ownership; staying out of programming decisions; etc. It USED to look deeply at public service when renewing or granting station applications. Now, the Commission makes lip service to the concept, but sort of "waves the vermouth cork" of public service over the "gin martini" of station applications. It is a duty of the Commission to keep that interest in mind when deciding applications and station action

My argument is that public interest, convenience, and necessity means something in every action. It is an affirmative duty of stations and their owners to broadcast IN that public interest. It's about time they went back to actually acknowledging it, instead of sticking a half-hour, pre-recorded, badly-produced interview with the chamber of commerce on Sunday mornings at 5am and calling it a day.
 
Re: The Local Community's commitment to KEYMARKET

> ...MAYBE THE PRESENTATION and promotion of WJPA is flawed?
> Lack of effort to integrate the station into the community?
> marketing problems? under capitalized?
> uninteresting, uninspired, non entertaining between the
> music? doesn't encourage audience interaction? I am sure
> there are others who could give their opinions on this
> particular station, but obviously you find a flaw in it. Do
> you think WJPA could be a viable community oriented
> station?........

No, none of the above. I think WJPA is a fine station, and does an excellent job. But it is in business to make a profit. If it fails to make a profit, then it will go out of business and cease broadcasting.

I simply used it as an example of a station that serves those who live in the range of its signal quite well, and yet still doesn't get 100% listenership.

The point is that people don't listen to a radio station out of any sense of civic duty or loyalty. They listen to what they want to hear.

And, even if there is a good case to be made that stations should broadcast programs that contain important information that is useful or even necessary for local people to hear, the main point in this thread was that the station being discussed no longer had local people in a studio announcing the names of the records being played.


>
>
> OK, then let's say the biggest cluster in Pitt decides to
> flip to a format called "The Toad" and they copy the frog
> playlist and everything else about them, simulcasting 5
> stations... now certainly you will have people tuning in to
> every one of those stations be it frog or toad..... again,
> EACH station will have a core of listeners, but certainly
> SOME SEGMENT of the market will suffer.
>
> Are these stations all competing with each other for share,
> or canabalizing each other for the same group of listeners?
> do you run them bare bones and count the total audience as
> one, or do you say Frog A is number 1, Toad B is number 2
> Frog D is number 10, and Toad A is number 22........ If
> Toad A is at 22 do you do a make over and make it a stand
> alone, or continue to count its audience in the total Toad
> audience, and then combine Frog and Toad and say the Tight
> format Country format Is NUMBER 1 overall? meanwhile Toad
> A was profitable and viable as a local station before making
> it a part of the Greater Amphibian Empire even though it
> only had a .4 in the steel city metro book................
>
> pulling the plug on each station as a stand alone,Each with
> their own audience...It is strictly a "more money" decision
> as is any Cluster type operation. Let's say I tune into 3ws
> for oldies...I like the format, and the presentation. Now
> 3ws flips formats to all disco and no jocks... I am not a
> fan of disco, and enjoy being entertained by live local
> announcers, so I scan the dial country... all rock no
> talk...hip hop..Jack.... country again...another country
> station that is exactly like the other one... syndicated
> talk... alternative... morning guy funny then VTs and
> liners...classic rock.... tne same country as two others
> down the dial...
>
> Hmmm, no oldies, no personality. I was committed to that
> oldies station, and now, no oldies anywhere, and not enough
> personality to hook me into another choice.... Now what?
>
> I listened to WSOM for the local content. When Cumulus
> moved the station, they dropped the local content... my
> city news and info my county news and info..... now what?
> same county WOHI drops local content for ESPN? OK, that's
> two! Neither station offers me local content, yet I still
> shop the local business, but since the local businesses are
> not featured on the local station, maybe I don't shop them
> as often. Why, I am no longer REMINDED to shop there.
>
> NOW, I have NO STATION IN THIS COUNTY, but 4 were/are
> licensed to it! You find nothing wrong with that?
> Different view points I guess.
>
> So to answer your question, I can't support my local content
> station, because there isn't one! And there isn't the
> possibility to replace what was taken away. If my local
> tire dealer closes, Someone else can come into town and
> open a tire store! It's not possible with a radio station,
> and THAT is why moveouts are bad for the industry! Sad to
> say that there is a certain social responsibility that comes
> with owning a public media, but as time goes on, greed
> overcomes that responsibility. As I said, while a business
> owner certainly has the freedom to move his business
> anywhere he wants, Radio and television fall under a
> different category. But, as long as the rules have become
> so lax, then communities will continue to lose their
> stations and local content without the ability to replace
> them........ A Froggy ring around the steel city, might be a
> good business move, but it certainly isn't a responsible
> social action. As for the AM WOHI.... well again,
> programming off the bird is certainly cheaper, but at the
> expense of the LOCALS who did tune in... and they did.
> More than likely though, it was a revenue decision to kill
> the local angle, not a lack of local listeners........ You
> know as well as I do that HIGH DIAL AMs are a tough sell
> regardless the format. Put one on the air for under 100K,
> and you have a shot to make it work...... Put a 450K value
> on it, then that is a nut that you can't crack.......
> That's BUSINESS...... The Froggy situation is just GREED.
>
>
>
>
>
>
> > While you're on a roll, about about a similar rant for the
>
> > listeners who live in the hinterlands who selfishly listen
>
> > to whatever station happens to play what they want to
> hear,
> > regardless of whether it's "local" or not. How about a
> rant
> > about people like the citizens of Washington, PA who don't
>
> > listen to WJPA because they just don't like oldies.
> >
> > After all, if broadcasters are supposed to cater to "local
>
> > needs" even if most local people seldom tune in, then
> > shouldn't local listeners be equally compelled to tune in
> to
> > local stations even if they don't like the programming?
> >
> > The thing is, people tune in because they like what's
> being
> > broadcast. Most listeners just don't care about "local"
> > content.
> >
> > > LOCAL BROADCASTING..................
> > >
> > > Obviously, there isn't one. Kill off all programming
> from
> >
> > > the local side, but expect the local advertisers to hang
>
> > in
> > > there. Why should an east L business advertise on WOHI
> or
> >
> > > 104, when you offer NO LOCAL CONTENT? No local
> announcers
> >
> > > talking about local sports, weather, community interest
> > > events. Are you talking about the local christmas
> > parades?
> > > mentioning your support for the holiday food drive, and
> > how
> > > your live and well liked afternoon "PERSONALITY" will be
>
> > > side by side with the locals accepting your donations?
> > >
> > > How about the LOCAL NEWS and info that WOHI listeners
> came
> >
> > > to expect over the years.....where is that? NO
> EMPLOYESS
> >
> > > WERE KILLED IN THE SHAKEUP OF OUR FORMATS....... loosly
>
> > > anyway..... but when you pull someones airshift, some
> > > "leave on there own to seek a position elsewhere....
> Sure
> > > S.K. is still with the company as is K.B. but you sure
>
> > > don't hear them on the air live in a regular
> > airshift.......
> > > You run multiple stations with one airstaff... good for
>
> > > business, bad for local radio.
> > >
> > > Funny how there was a time when most of these stations
> > were
> > > staffed, LIVE and profitable....... Now, they are
> shells
> > > (or should I say shills) but there is 'mo money for the
> > boys
> > > in the suits......
> > >
> > > I do have to wonder why you have an expectation of local
>
> > > businesses to continue to spend advertising dollars with
>
> > > your simulcasted "NON PITTSBURGH" stations, when you
> > refuse
> > > to support the communities from which you stole their
> > > stations?
> > >
> > > How does ESPN serve the community? It serves only your
> > > bottom line, and you certainly have to make no effort to
>
> > > "SELL" the format... let a few agency dollars cover
> > > that...... You didn't pick up and move a furniture
> store
> > > from E.L to a more profitable Moon township
> location.....
> > > You told a government agency whatever you had to get
> > > approval to pull up stakes for 104.3. Yet you have no
> > > problem sending a salesman into an E.L. business.... Do
>
> > you
> > > still run the "YOUR HOMETOWN STATION SWEEPER"? Which
> > > hometown is that? Steubenville? East Liverpool?
> Carnegie?
> > > Pittsburgh? Wampum? Chester?........
> > >
> > > Sure you paid for it, it's yours, and this is America,
> you
> >
> > > should be able to do what you want with your
> business....
> >
> > > Really though all you show is that you are all about the
>
> > > dollar, no commitment to or compassion for, your
> > listeners,
> > > the community, or your employees. A regional version of
>
> > > Clear Channel and the other BIGTIME broadcasters....
> > >
> > > Generic Radio on the cheap, same as business model type
> as
> > a
> > > Bicoastal, or dozens of other copycat versions of MEGA
> > > radio... bigger is better but boring is hell. You don't
>
> > > have to make each station a success on it's own... five
> > > mouths only have to feed one stomach......
> > >
> > > Seriously, congratulations on your success, but shame on
>
> > you
> > > for doing it at the expense of the local communities you
>
> > > once served. You should also congratulate me for my
> > > intelligence and insight as I recognized your ultimate
> > plans
> > > several years ago, and pointed them out... I guess my
> > years
> > > of experience and broadcast interest allowed me, as well
>
> > as
> > > many other who have an interest in radio in this area,
> to
> > > see the whole picture... Hey remember, sometimes people
>
> > > have far more brains and abilities than their actual
> > > position would indicate. Just because a rocket
> scientist
> > > has a job flipping burgers, doesn't mean he is only
> > > qualified to flip burgers!
> > >
> >
>
 
Re: The Local Community's commitment to KEYMARKET

> > While you're on a roll, about about a similar rant for the
>
> > listeners who live in the hinterlands who selfishly listen
>
> > to whatever station happens to play what they want to
> hear,
> > regardless of whether it's "local" or not. How about a
> rant
> > about people like the citizens of Washington, PA who don't
>
> > listen to WJPA because they just don't like oldies.
> >
> > After all, if broadcasters are supposed to cater to "local
>
> > needs" even if most local people seldom tune in, then
> > shouldn't local listeners be equally compelled to tune in
> to
> > local stations even if they don't like the programming?
>
> Here's your flaw: listeners are not subject to regulation,
> other than the limits on numbers of stations receivable and
> formats available (the former a circumstance of physics, the
> latter a circumstance of the market). Broadcasters are
> regulated, and sharply so.

Yes, they are. But they shouldn't be. Or rather, they should be regulated as to technical aspects so that stations don't step on each others' signals. But regulating radio stations in the "public interest" by requiring them to fulfills some vague and unspecified amount of "public service" is something that is nothing but a tired old holdover from years gone by. It had meaning back in the days when the regulations were promogulated. It no longer has meaning in the third millenium.

> As much as you'd surely like to see the radio industry as a
> pure business model, it isn't. Broadcasters are granted
> licenses because the FCC has determined that Broadcaster A
> will fill a public interest, convenience, and necessity.
> It's, ab initio, a regulated business and not analogous to a
> pure business model. The government grants the
> licenses--that happens in very few other businesses. As
> part of that license is an obligation to serve the public
> interest. If a broadcaster doesn't like that requirement,
> he doesn't have to be a broadcaster. Or, in our republic,
> he can lobby his legislators to change the law (which would,
> invariably, lead to the collapse of broadcast regulation
> itself. Without public interest, part of the rationale
> behind government regulation fails.)

There is very little rationale behind most government regulation. Broadcasting is no different.

> As much as you and your business sense (and some owners,
> GMs, and PDs) would like to do away with that public
> interest, convenience, and necessity requirement, it exists
> and it is statutory.

There are tons of laws on the books on a plethora of subjects that are antiquated, outdated, and in dire need of repeal. The fact that stupid government regulations exist is not proof that they should exist.

> While your hyperbole about Washington, PA and WJPA (fact:
> LOTS of Washingtonians DO listen to WJPA) is nice and all,
> it doesn't actually support anything.

My point was not that there aren't any Washingtonians listening to WJPA, my point was that no matter how good their local service programming is (and it is excellent), they still don't get 100% of the local people listening. And, those local people who listen to WJPA's local programming do so because it is good and compelling local programming, not because of any sense of civic duty or responsibility. If a station can attract listeners because of good local programming, great.

Furthermore, WJPA's truly excellent local programming attracts listeners who care about local programming WHEN THOSE PROGRAMS ARE BEING BROADCAST. The rest of the time, when they're simply spinning old records (OK, CD copies of old records), the people who tune in do so because they like the old records, not because of civic loyalty. Country music fans who live in Washington might tune in Wild Things games, but they don't tune in the disc jockey shows.
 
Re: The Local Community's commitment to KEYMARKET

I think WJPA is a fine station, and
> does an excellent job. But it is in business to make a
> profit. If it fails to make a profit, then it will go out of
> business and cease broadcasting.
>
> I simply used it as an example of a station that serves
> those who live in the range of its signal quite well, and
> yet still doesn't get 100% listenership.
>
Well there you have it...radio doing what it's supposed to do.

and you never get 100 percent listenership. that is an unreasonable expectation

but, operating the station from it's intended location and in the public interest IS a reasonable as well as a legal expectation....making it profitable is up to the owner... the risk of a businessman. do your research before you buy....

Midland doesn't have a Bentley dealership. would it be wise to put one there?

probably not. E.L HAD a station that earned enough revenue to make it viable. KM CHOSE to blow off that market...............

you still don't see that there is a responsiblity that broadcast owners agree to that does not pertain to other businesses..........
 
Re: The Local Community's commitment to KEYMARKET

> you still don't see that there is a responsiblity that
> broadcast owners agree to that does not pertain to other
> businesses..........

I see that there is SOME responsibility, though I would argue that other businesses also share similar responsibilities.

When there is an emergency, such as severe weather or some other natural disaster, local radio stations are obliged to broadcast important and useful local information to help the local people cope with the disaster. But then, local grocery stores are also obliged to provide emergency assistance in a bona-fide emergency. These obligations are moral imperatives, and exist whether some legislature has written them into law or not.

On the other hand, having someone announce the title of each song that's played from a microphone located in a local studio is NOT a bona-fide requirement for fulfilling "local" requirements. If the music was recorded elsewhere, then there's no reason why the spoken voice that announces the title can't also be recorded elsewhere.

The issue is where to draw the line. Getting 100% listenership is impossible. Surviving with 0% listenership is impossible. So there is some percentage in between 0% and 100% that is adequate. I submit that if the percentage of local listenership to routine, ordinary day-to-day programming is only enough to be, as you put it, "viable", then that's an indication that there isn't sufficient local listenership. A business should not be compelled to simply "get by", which is what viable implies. It should be permitted to thrive.

As long as the station serves the needs of the local community in times of emergency, when a lack of service would cause a disaster, then that should be sufficient. Routine local content, like the filler that occupies the pages of most local newspapers, shouldn't be something that stations are required by law to carry.

If you're going to use the term "public interest", then shouldn't that mean things in which the public is actually interested? If only a very tiny percentage of the public is interested in what kind of trees the local parks commission is going to plant alongside Main Street, then how could compelling a radio station to report the news from the local City Council if that's all that was discusssed at the local city council meeting be considered "serving the public interest"?
 
Re: The Local Community's commitment to KEYMARKET

Dude, why do you argue so much with everyone on this board? Why are all your posts these long, philosophical essays belabouring obtuse points? I'm just wondering. I mean, don't you have a hobby or something? Don't you have anything better to do?

You know what you remind me of? When I used to do talk radio there was an interesting little local phenomenon known as the "chronic caller". That would be some old guy, like "Hemorrhoid Harry" was one of ours, who would call EVERY host on EVERY shift and argue ANY point just for the sake of argument. I think maybe his wife died and he missed having anyone who cared to listen to him. About half the time I wouldn't even take his calls. I think my point is, it's one thing to be principled and hold certain views and express them, that's respectable. It's quite another to simply argue with people at length about anything whatsoever for argument's own sake alone. That's annoying and asinine. Which are you? Cuz you seem to have a LOT to say about EVERYTHING.

> > you still don't see that there is a responsiblity that
> > broadcast owners agree to that does not pertain to other
> > businesses..........
>
> I see that there is SOME responsibility, though I would
> argue that other businesses also share similar
> responsibilities.
>
> When there is an emergency, such as severe weather or some
> other natural disaster, local radio stations are obliged to
> broadcast important and useful local information to help the
> local people cope with the disaster. But then, local grocery
> stores are also obliged to provide emergency assistance in a
> bona-fide emergency. These obligations are moral
> imperatives, and exist whether some legislature has written
> them into law or not.
>
> On the other hand, having someone announce the title of each
> song that's played from a microphone located in a local
> studio is NOT a bona-fide requirement for fulfilling "local"
> requirements. If the music was recorded elsewhere, then
> there's no reason why the spoken voice that announces the
> title can't also be recorded elsewhere.
>
> The issue is where to draw the line. Getting 100%
> listenership is impossible. Surviving with 0% listenership
> is impossible. So there is some percentage in between 0% and
> 100% that is adequate. I submit that if the percentage of
> local listenership to routine, ordinary day-to-day
> programming is only enough to be, as you put it, "viable",
> then that's an indication that there isn't sufficient local
> listenership. A business should not be compelled to simply
> "get by", which is what viable implies. It should be
> permitted to thrive.
>
> As long as the station serves the needs of the local
> community in times of emergency, when a lack of service
> would cause a disaster, then that should be sufficient.
> Routine local content, like the filler that occupies the
> pages of most local newspapers, shouldn't be something that
> stations are required by law to carry.
>
> If you're going to use the term "public interest", then
> shouldn't that mean things in which the public is actually
> interested? If only a very tiny percentage of the public is
> interested in what kind of trees the local parks commission
> is going to plant alongside Main Street, then how could
> compelling a radio station to report the news from the local
> City Council if that's all that was discusssed at the local
> city council meeting be considered "serving the public
> interest"?
>
 
Re: The Local Community's commitment to KEYMARKET

> Dude, why do you argue so much with everyone on this board?
> Why are all your posts these long, philosophical essays
> belabouring obtuse points? I'm just wondering. I mean, don't
> you have a hobby or something? Don't you have anything
> better to do?

Are you saying that discussing things on a discussion forum is NOT a hobby?

> You know what you remind me of?

You know what you remind me of? From your double-entendre nickname to your inability to contribute anything meaningful to a discussion, you're like the over-bearing loudmouth in the polyester suit who thinks he's God's gift to the world. You probably laugh at your own jokes, and when you do you're the only one laughing. You get bored with anything that takes more then 15 seconds to read or hear because that's the limit of your attention span. Anything that can't be expressed on a bumper sticker is too deep for you to understand.

You have no opinions of your own on any issue of substance, because that's boring. Your opinion on everything else is whatever the majority of the people you're with believe. And, since you avoid hanging out with anyone who actually thinks, that's not too difficult.

Your idea of a really funny joke is reflected by your chosen nickname.

As for arguing at length, that's only boring to those so brain dead that they can't handle taking any discussion into any level of depth.

Why don't you change your nickname to "Winnie the Pooh"? After all, you're a person with very little brain, and big words bother you.

> When I used to do talk radio
> there was an interesting little local phenomenon known as
> the "chronic caller". That would be some old guy, like
> "Hemorrhoid Harry" was one of ours, who would call EVERY
> host on EVERY shift and argue ANY point just for the sake of
> argument. I think maybe his wife died and he missed having
> anyone who cared to listen to him. About half the time I
> wouldn't even take his calls. I think my point is, it's one
> thing to be principled and hold certain views and express
> them, that's respectable. It's quite another to simply argue
> with people at length about anything whatsoever for
> argument's own sake alone. That's annoying and asinine.
> Which are you? Cuz you seem to have a LOT to say about
> EVERYTHING.
>
> > > you still don't see that there is a responsiblity that
> > > broadcast owners agree to that does not pertain to other
>
> > > businesses..........
> >
> > I see that there is SOME responsibility, though I would
> > argue that other businesses also share similar
> > responsibilities.
> >
> > When there is an emergency, such as severe weather or some
>
> > other natural disaster, local radio stations are obliged
> to
> > broadcast important and useful local information to help
> the
> > local people cope with the disaster. But then, local
> grocery
> > stores are also obliged to provide emergency assistance in
> a
> > bona-fide emergency. These obligations are moral
> > imperatives, and exist whether some legislature has
> written
> > them into law or not.
> >
> > On the other hand, having someone announce the title of
> each
> > song that's played from a microphone located in a local
> > studio is NOT a bona-fide requirement for fulfilling
> "local"
> > requirements. If the music was recorded elsewhere, then
> > there's no reason why the spoken voice that announces the
> > title can't also be recorded elsewhere.
> >
> > The issue is where to draw the line. Getting 100%
> > listenership is impossible. Surviving with 0% listenership
>
> > is impossible. So there is some percentage in between 0%
> and
> > 100% that is adequate. I submit that if the percentage of
> > local listenership to routine, ordinary day-to-day
> > programming is only enough to be, as you put it, "viable",
>
> > then that's an indication that there isn't sufficient
> local
> > listenership. A business should not be compelled to simply
>
> > "get by", which is what viable implies. It should be
> > permitted to thrive.
> >
> > As long as the station serves the needs of the local
> > community in times of emergency, when a lack of service
> > would cause a disaster, then that should be sufficient.
> > Routine local content, like the filler that occupies the
> > pages of most local newspapers, shouldn't be something
> that
> > stations are required by law to carry.
> >
> > If you're going to use the term "public interest", then
> > shouldn't that mean things in which the public is actually
>
> > interested? If only a very tiny percentage of the public
> is
> > interested in what kind of trees the local parks
> commission
> > is going to plant alongside Main Street, then how could
> > compelling a radio station to report the news from the
> local
> > City Council if that's all that was discusssed at the
> local
> > city council meeting be considered "serving the public
> > interest"?
> >
>
 
Re: The Local Community's commitment to KEYMARKET

> > you still don't see that there is a responsiblity that
> > broadcast owners agree to that does not pertain to other
> > businesses..........
>
> I see that there is SOME responsibility, though I would
> argue that other businesses also share similar
> responsibilities.
>
> When there is an emergency, such as severe weather or some
> other natural disaster, local radio stations are obliged to
> broadcast important and useful local information to help the
> local people cope with the disaster. But then, local grocery
> stores are also obliged to provide emergency assistance in a
> bona-fide emergency. These obligations are moral
> imperatives, and exist whether some legislature has written
> them into law or not.

Agreed. But the public interest obligations of broadcasters ARE written into law. So this argument--valid though it may be--is inapposite. Again, what "should be" and what "is" are two separate things.

> On the other hand, having someone announce the title of each
> song that's played from a microphone located in a local
> studio is NOT a bona-fide requirement for fulfilling "local"
> requirements. If the music was recorded elsewhere, then
> there's no reason why the spoken voice that announces the
> title can't also be recorded elsewhere.

I'm not arguing that (totally). It would be nice to be live and local, but voicetracking, syndication, and recorded is the way of the future (and of the past, see most FMs pre-1980).

I'm instead arguing that there are certain local, community, and public service requirements attached to the FCC license. And these requirements hold even more weight when a station is "moved-in" to a seemingly "unserved" community (like Duquesne in the WOGI application).

> The issue is where to draw the line. Getting 100%
> listenership is impossible. Surviving with 0% listenership
> is impossible. So there is some percentage in between 0% and
> 100% that is adequate. I submit that if the percentage of
> local listenership to routine, ordinary day-to-day
> programming is only enough to be, as you put it, "viable",
> then that's an indication that there isn't sufficient local
> listenership. A business should not be compelled to simply
> "get by", which is what viable implies. It should be
> permitted to thrive.

The FCC is not compelling any station to "simply 'get by'". The FCC is saying that broadcasters, as a requirement of getting the license grant have this public service obligation. Broadcasters can take it or leave it. And this obligation does notcompel any level of success. For 70 years broadcasters have had this same public service obligation, and most have performed it with much interest and enthusiasm, and for 70 years they have been successful.

> As long as the station serves the needs of the local
> community in times of emergency, when a lack of service
> would cause a disaster, then that should be sufficient.
> Routine local content, like the filler that occupies the
> pages of most local newspapers, shouldn't be something that
> stations are required by law to carry.

Again, you think it shouldn't be. That's admirable, but the law mandates it. And while the law mandates it, it is a requirement and obligation that must be fulfilled.

> If you're going to use the term "public interest", then
> shouldn't that mean things in which the public is actually
> interested?

Wrong. Public interest does not mean "interested public". Public interest means that which appeals to the public good, the civic spirit, the warm, fuzzy feeling inside. Public interest means the public as a whole, and each one individually. It means the contemporary community.

Not you or me; but we. If that makes any sense.

> If only a very tiny percentage of the public is
> interested in what kind of trees the local parks commission
> is going to plant alongside Main Street, then how could
> compelling a radio station to report the news from the local
> City Council if that's all that was discusssed at the local
> city council meeting be considered "serving the public
> interest"?

First, no one is being compelled to report the city council news. Public service/interest may be served in any number of ways, including the news reports on the city council meeting.

Second, again, public service/interest does not mean any percentage of the public. Public service is not rated like share, cume, TSL, or rank. Public service is (in its essence) an inherent part of broadcasting. It's only when stations and their owners go out of their way to avoid it that situations occur.

Again, I'm not saying that Keymarket definitely should have broadcast the Duquesne HS football game. If they have other, adequate public service then that makes up for it. But I do believe that if a station is going to launch a protracted move-in campaign to an area that is allegedly without local service, there's a heightened obligation to provide public service to that area.

Unless the move-in reason really is all a ruse. In which case, the argument changes to something more non-family friendly.
 
Re: The Local Community's commitment to KEYMARKET

The laws for having an "unserved" city of license are what they are,ridiculous as they may be. It might be better to just let them be licensed to the metro, we all pretty much all know that you can't onl;y broadcast to Asheville, Ohio with a 50,000 watt signal. I know of several past and pending move-ins, such as WMRN-FM< Marion, OH's move to Dublin, OH; WIFE in Connersville, IN moving into Norwood (Cincinnati), OH and a possible move of WHIZ, Zanesville, OH into the Columbus market. For all the hand-wringing about "local service" it's the folks in the towns who don't care. The WMRN move has been widely publicized and hasn't generated the first letter to the editor or outraged citiozen appearing before city council. When small AM stations still doing the "local content" thing are struggling as the audience listens to what it likes, I'm not so sure that the so-caled "public interest" requirements..vague as they are...actually make sense. This is a world of on-demand content..the lunch menus are on the internet, and many stations are doing away with half-hour long lists of snow cancellations which list every Bingo game and dance school with 10 students within a 50-mile radius. When I read calls for "more public service progarmming" or "live and local content" on these bards it sometimes comes off as "government, make them let me be a DJ". <P ID="signature">______________
..from the Ball Park Franks sponsored gr8oldies keyboard...</P>
 
Re: The Local Community's commitment to KEYMARKET

> First, no one is being compelled to report the city council
> news. Public service/interest may be served in any number
> of ways, including the news reports on the city council
> meeting.
>
> Second, again, public service/interest does not mean any
> percentage of the public. Public service is not rated like
> share, cume, TSL, or rank. Public service is (in its
> essence) an inherent part of broadcasting. It's only when
> stations and their owners go out of their way to avoid it
> that situations occur.

OK, then please enumerate SPECIFICALLY what a station should be broadcasting on a regular basis that will satisfy the FCC's requirements for public interest programming. Please enumerate what such programming should be in a manner that those of us who aren't lawyers can grasp what you're talking about?

In thirty years of observing the mentions of these requirements, and on discussions dating back to the days of FIDO and RIME before there even was a World Wide Web, I've read people making the same kind of vague and ambiguous statements that you're making about the obligation of stations to serve their City of License.

I realize that lawyers have a vested interest in preserving vague and ambiguous laws, since lawyers make their living by attempting to prove and/or disprove just what those vague laws actually mean. But those of us who aren't lawyers need a little more precision.

So what are you talking about? Just what, specifically, do you interpret the requirements for "public interest" programming to call for? What must a broadcaster put on the air in order to be in compliance with those requirements?
 
Re: The Local Community's commitment to KEYMARKET

> > First, no one is being compelled to report the city
> council
> > news. Public service/interest may be served in any number
>
> > of ways, including the news reports on the city council
> > meeting.
> >
> > Second, again, public service/interest does not mean any
> > percentage of the public. Public service is not rated
> like
> > share, cume, TSL, or rank. Public service is (in its
> > essence) an inherent part of broadcasting. It's only when
>
> > stations and their owners go out of their way to avoid it
> > that situations occur.
>
> OK, then please enumerate SPECIFICALLY what a station should
> be broadcasting on a regular basis that will satisfy the
> FCC's requirements for public interest programming. Please
> enumerate what such programming should be in a manner that
> those of us who aren't lawyers can grasp what you're talking
> about?
>
> In thirty years of observing the mentions of these
> requirements, and on discussions dating back to the days of
> FIDO and RIME before there even was a World Wide Web, I've
> read people making the same kind of vague and ambiguous
> statements that you're making about the obligation of
> stations to serve their City of License.
>
> I realize that lawyers have a vested interest in preserving
> vague and ambiguous laws, since lawyers make their living by
> attempting to prove and/or disprove just what those vague
> laws actually mean. But those of us who aren't lawyers need
> a little more precision.
>
> So what are you talking about? Just what, specifically, do
> you interpret the requirements for "public interest"
> programming to call for? What must a broadcaster put on the
> air in order to be in compliance with those requirements?

Ah ha. Now you're getting it.

It's the same thing with indecency. Judged according to "contemporary community standards" with the "national" audience considered the community (even for a Washington, PA show). These are nice legal terms that allow guys like me to make a living fighting about the meaning of same.

But in everyday parlance, they don't have any definition. And Congress and the FCC have been really straining themselves NOT to define them. But what does that do for stations and owners who have to comply with these rules, regulations, and standards?

The best they can do is look at what's been done before by other owners, and take some good sense of their own, to do some public good and not step over the indecency line. And, honestly, it's been that way for 70 years with relatively few issues.

But since you asked me to give my interpretation of public interest requirements, here goes:

A substantial contribution to the community, and specifically the COL, above and beyond providing a normal programming outlet for "popoular music" or talk or sports. Providing a genuine service to the community--using the airwaves to provide something that is otherwise missing. Plus, make a concerted effort to have a pervasive presence in the civic consciousness. That could be by on-air work, or by remotes/community events.

It's looked at as a whole, not each individual part. As I said, WOGI may be serving Duquesne particularly in a way we don't know about. It's just that given the almost no-brainer of carrying the football game when no one else was, it went out of its way to be contrary.
 
Re: The Local Community's commitment to KEYMARKET

> Agreed. But the public interest obligations of broadcasters
> ARE written into law. So this argument--valid though it may
> be--is inapposite. Again, what "should be" and what "is"
> are two separate things.

Indeed they are.

So: kindly cite, if you would, both the law you speak of and the regulatory precedent by which the FCC could enforce said law?

See, I spend a good amount of my time reading pretty much every regulatory decision the FCC's Media Bureau hands down, and here's how it looks to me:

The operative laws are in the Communications Act of 1934 (as amended, especially in 1996), which says broadcasters are to serve the "public interest, convenience and necessity" and which, in section 307(b), obligates the Commission to ensure the "fair and equitable distribution" of broadcast service among various communities.

Pretty much everything beyond that is established not in federal law but in decades of Commission precedent. (There are exceptions; the Fairness Doctrine, now obsolete, was written into law by Congress a decade after the FCC began enforcing it.)

The problem right now - and it is a problem, as just about anyone in the business will tell you (even if not always on the record) - is that the FCC's interpretation of "public interest, convenience and necessity," or "PICAN" (as it reads the tea leaves of Congress) has changed dramatically in the last decade or so, while the interpretation of "fair and equitable distribution" hasn't changed to keep pace.

It would take a lengthy essay to enumerate the dozens of regulatory changes that transformed the interpretation of PICAN, but the key ones included streamlined renewals with no opportunity for public challenges, the use of auctions instead of hearings to decide among competing applicants, the weakening of the main-studio rule and the elimination of any substantive requirements for public service programming.

In other words, while you may argue that the spirit of the law still requires all those things, the interpretation of the Commission, now enshrined in years of precedent, says otherwise - and Congress appears, at least tacitly, to agree with the FCC.

And at the same time, that bit about "fair and equitable distribution" hasn't changed, which means that once the FCC has decided that it's more equitable to have a license in Duquesne and a license in Charleroi than to have none in Duquesne and two in Charleroi, there's nothing left that requires the new "Duquesne" station to have any real connection with Duquesne, beyond the initial showing that had to be made to demonstrate that Duquesne is a community entitled to broadcast service and sufficiently independent from Pittsburgh to qualify.

After that, all that's required is a 70 dBu signal over substantially all of Duquesne, a main studio within 25 miles of Duquesne or within the 60 dBu contour, a phone number that's toll-free from Duquesne, and a public file that includes quarterly reports that list what topics of public interest were discussed on the air. (These need not be specific to Duquesne; a 5 AM Sunday interview with the western PA Red Cross would meet the current standards.)

Oh, and you have to say "Duquesne" once an hour.

Makes no sense? True - but because broadcasters have, for the most part, learned how to manipulate the city-of-license rules to their advantage, there's been no real pressure on the FCC to change them.

I'm not saying it's right. I'm not saying it even makes any sense. I am saying that it's the way the FCC works right now, and if you want to persuade me that there's some additional public interest obligation that's written "into law" that 98.3's not meeting, I'd like to see the chapter and verse. <P ID="signature">______________
Tower Site Calendar 2006 JUST RELEASED! - <a target="_blank" href=http://www.fybush.com/nerw.html#calendar>www.fybush.com</a></P>
 
Re: The Local Community's commitment to KEYMARKET

> > Agreed. But the public interest obligations of
> broadcasters
> > ARE written into law. So this argument--valid though it
> may
> > be--is inapposite. Again, what "should be" and what "is"
> > are two separate things.
>
> Indeed they are.
>
> So: kindly cite, if you would, both the law you speak of and
> the regulatory precedent by which the FCC could enforce said
> law?
>
> I'm not saying it's right. I'm not saying it even makes any
> sense. I am saying that it's the way the FCC works right
> now, and if you want to persuade me that there's some
> additional public interest obligation that's written "into
> law" that 98.3's not meeting, I'd like to see the chapter
> and verse.

Well, you've already cited it--public interest, convenience, and necessity is the law, from the 1934 Act. After that, each and every FCC regulatory decision (including rules and regulations promulgated under the authority of the 1934 Act, as well as FCC statements and applications) IS the law. So, the FCC's holdings in proceedings from, essentially 1928 (the Radio Act) and affirmatively 1934, constitute "the law". Not everything is written in stone in books bearing the "FCC Law" label. That's the beauty of our common law system.

Each and every FCC precedent has the effect of being a "law" upon which others can rely. (That is, unless the Commission says otherwise--think indecency, where past FCC decisions give a sort of guide as to what is and what isn't indecent, but each incident is judged individually "in context".) The great body of FCC precedent relating to public interest, convenience, and necessity has been altered within the past decade. So, while all the previous FCC law still exists, the Commission has seen fit to adopt its own precedent of late. Both have the same effect, but the FCC has decided to follow Path A (say, since 1990 or so) instead of Path B (which dates older).

Now, Congress may tacitly approve the FCC's decisions of late--but they have not done so explicitly. Congress has made no decision one way or the other about the FCC PICAN interpretations of the past 10-15 years. But, it need not do so. AS long as the FCC interpretation is still within what Congress intended in the 1934 Act by "public interest, convenience, and necessity," the Chevron requirements are met (Chevron is the seminal case on administrative interpretation.) The FCC's current PICAN interpretation, though wildly opposite its previous incarnation, is nonetheless valid. Only Congress can come along and say "No, that's wrong" to affirmatively cause the FCC to reverse it. Otherwise, the FCC must make its way back to sanity on its own.

That's all I've been arguing--that under the 60 years of FCC precedent predating 1990, this sort of stuff with WOGI and Duquesne would be given a closer eye. And that's how it should be, especially in regards to move-in frauds like this.
 
Re: The Local Community's commitment to KEYMARKET

> That's all I've been arguing--that under the 60 years of FCC
> precedent predating 1990, this sort of stuff with WOGI and
> Duquesne would be given a closer eye. And that's how it
> should be, especially in regards to move-in frauds like
> this.

Hmmm...

Isn't that just another way of saying that a few lawyers should have been hired? After all, nothing gets a legal "closer eye" unless a couple of lawyers are involved, right?

And isn't "fraud" a rather harsh description for what is currently standard industry practice?
 
Re: The Local Community's commitment to KEYMARKET

> > That's all I've been arguing--that under the 60 years of
> FCC
> > precedent predating 1990, this sort of stuff with WOGI and
>
> > Duquesne would be given a closer eye. And that's how it
> > should be, especially in regards to move-in frauds like
> > this.
>
> Hmmm...
>
> Isn't that just another way of saying that a few lawyers
> should have been hired? After all, nothing gets a legal
> "closer eye" unless a couple of lawyers are involved, right?

I'm sure there's a jab at the legal profession in there. I'll leave that alone. But, I don't go blasting business professionals, do I?

Anyway, the FCC is hiring more lawyers (attorney-advisors, they're called) than anything else now. And the body who should be taking a closer look at such applications is the FCC. They're given the statutory mandate to review and approve such moves. If they're going to just stamp and pass along, that's placing the enforcement of the law on precarious footing.

> And isn't "fraud" a rather harsh description for what is
> currently standard industry practice?

Standard practice doesn't mean it's not a fraud.

Regardless, though, fraud was probably a bad word to use there, since it has a legal definition. Perhaps "move-in crap" would have sufficed.
 
Re: The Local Community's commitment to KEYMARKET

> > Isn't that just another way of saying that a few lawyers
> > should have been hired? After all, nothing gets a legal
> > "closer eye" unless a couple of lawyers are involved,
> right?
>
> I'm sure there's a jab at the legal profession in there.
> I'll leave that alone. But, I don't go blasting business
> professionals, do I?

There's a gentle jab, but certainly nothing approaching a blast. I tend to think that any member of any profession who can't handle a gentle jab needs to lighten up.

I also don't think anyone in here is above advocating things that would benefit them or their profession. Those who work as live disc jockeys tend to oppose voice-tracking. I advocate the use of marketing research to enhance advertising effectiveness, which certainly butters my bread. It's hardly an insult to make the observation that someone is supporting something that would benefit those who share the same profession. Putting opinions into context shouldn't make someone feel insulted. A barber shouldn't be insulted if someone points out the he is advocating short, well-trimmed haircuts.

> Anyway, the FCC is hiring more lawyers (attorney-advisors,
> they're called) than anything else now. And the body who
> should be taking a closer look at such applications is the
> FCC. They're given the statutory mandate to review and
> approve such moves. If they're going to just stamp and pass
> along, that's placing the enforcement of the law on
> precarious footing.

But enforcement of those rules is already pretty haphazard and precarious. Isn't it a situation where nothing is ever done unless some person or group files a challenge to a license renewal application?
 
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