I never said that loopholes weren't legal and in my way of thinking, if it doesn't apply to everyone, it's a loophole but apparently, that's not correct terminology. Let's try this tact: Are there local employees at any of their stations? Here's another: How do they justify operating in places with established commercial CCM stations?
1: Yes. Promotions in particular. They actually have a few job openings for local promotions right now.
2: CCM tends to work better in non commercial environments for some reason. Since they are not competing for ad revenue, they will put K-LOVE on in markets with commercial CCM station. If there is a non commercial CCM in a market they get a station in, Air1 goes on. They try to avoid competing directly with other non profit CCM stations. Air1 fills that purpose because of the slight age difference.