jd said:
I think the underlying question, to some posting here, is whether the owner (and in particular, the director) of the station is truly benevolent. Moreover, there seems to be some suspicion that there may be a hidden agenda since they also operate commercial radio stations.
And as for a "gray area" the fact that the station has local sponsors is great, so long as they adhere to the rather stringent policies governing "underwriting." Our fellow poster Chuck, who runs an LPFM near Longview (KZQX) with a chain of translators in East Texas, can provide more details about how announcements need to be worded. Quoting from the FCC policy at
www.fcc.gov/mb/audio/nature.html#ANNOUNCEMENTS :
Several examples of announcements that would clearly violate the rule may be helpful:
* A. Announcements containing price information are not permissible. This would include any announcement of interest rate information or other indication of savings or value associated with the product. An example of such an announcement is:
o -- "7.7% interest rate available now."
* B. Announcements containing a call to action are not permissible. Examples of such announcements are:
o -- "Stop by our showroom to see a model";
o -- "Try product X next time you buy oil."
* C. Announcements containing an inducement to buy, sell, rent, or lease are not permissible.
Examples of such announcements are:
o -- "Six months' free service";
o -- "A bonus available this week";
o -- "Special gift for the first 50 visitors."
Read on and you'll see that the FCC mainly acts on a complaint basis (like they do in most other situations) but they can and have levied hefty fines in the past for violators.
Most non-commercial stations are supported through underwriting, donations or both. A few even qualify for an occasional grant from a philanthropic organization. The information about underwriting restrictions posted above is quite accurate. The real shade of gray in all this is when the underwriting becomes promotional, rather than informative. That can be hard to determine, and quite subjective. Most noncommercial broadcasters with a conscience struggle with this on a regular basis.
To get a license in the first place, the applicant is required by the FCC to state their educational purpose. The easiest way to do this is to submit a copy of your charter (which is usually on file with your Secretary of State). Basically it defines what the organization is, what it does and why it does it. You may also have a Mission Statement that should included with your application. It is helpful (but not required) that the IRS has granted you 501(c)(3) not for profit status. The FCC tends to believe the judgment of the IRS on this, since the IRS actually audits the organization at the end of their first three years of operation.
The word "education" is a very broad ranging term. It is not limited to somebody reading dry textbook material, or teaching high school physics. Just look at some of the programming on PBS or NPR. It is quite possible to be educational as well as entertaining.
Many stations hang their hat on music education. Classical and Jazz formats are fairly common as well as Christian Contemporary, Gospel and other religious music formats. Of course, the most popular "educational purpose" is religion. That one is pretty hard to argue with no matter how off the wall it actually is. It is probably the most abused as well.
Keeping your listeners informed about what is happening in your community is also a well-recognized "educational purpose." In the case of LPFM stations, they were intended to serve communities of the un-served and bring diversity to broadcasting. That's why you'll find a lot of them running niche formats that have little or no commercial appeal to full power stations.
Our stations' stated goal is to serve people over 50, who are largely left behind in commercial broadcasting. Advertisers simply aren't interested in them. As a result, we have a fairly large audience of very nice elderly people. These people don't usually show up in Arbitron ratings, but that doesn't make much difference to us. When these folks call up just to wish you a Merry Christmas, or a Happy New Year, and they tell you how much they appreciate what you are doing, then financial concerns seem less important. We get those calls and emails every day.
