Chuck said:
There is a dangerous possibility that the FCC may hold LPFMs to a higher standard than full power stations. It depends on how they define this new ruling and who gets to interpret it.
Agreed!
In my opinion, this might be the time for LPFM operators (and possibly Part 15ers to show nay sayers that they are doing things in the community other stations are not) to begin the pain in the butt process of paper-trailing every local event aired. This opinion stems from an email I received from a very good friend who is launching his LPFM this coming month in Illinois (WXRJ). We were discussing the new FCC Rules to Promote Growth of LPFMs and my friend stated, "
After reading it seems that the FCC is looking for Low Power station to provide public affairs programming more so than just providing automated music outlet. That seem understandable. What about the change of ownership and the interference clauses. I do think that local originating programs are going to be harder to verify in the future; especially for LPFM". I thought about that for a moment and replied that it probably won't be that hard. Here's why.
#1. Requiring on-line quarterly public affairs reports. These would replace the paper documents (quarterly reports) that have went into the Public File. By requiring LPFMs to maintain an active electronic public file...anyone and any shows they claim to do can be verified...i.e. mayor of blank city was interviewed from x time to x time on x date...etc. The public would have easy access to these and lets face it...there are those who would turn someone in without giving it any thought. Even if the electronic public file (quarterly report) is not adopted soon (I believe it will show its ugly head in the not so distant future) it will mean that LPFMs better have their hard copy public files updated and stacked with reports of local show/interviews/psas with contact numbers on a quarterly report basis. Remember...the Public File is to be available to the general public during regular business hours. The P-File is the one thing stations usually fail to keep updated and the first thing they usually get a forfeiture/fine on. The P-file is a pain in the butt...I know...for I have set them up in the past and maintained them...but they can be like a cross to a vampire when it comes to FCC complaints and or spot inspections.
#2. The FCC will have a built in police force and that will be the NAB and local commercial stations that will turn in anyone in a heartbeat :-(
I guess it is time to possibly be ahead of the curve and do a cyber public file...keep a hard copy...but duplicate everything into the electronic file (I am going to do this for my Part15 even though a P-file is not required, I document everything).