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My issue with the LPAM rulemaking petition

I'm sure some will find flaws in this, but I'm not so sure the latest proposal from LPAM advocates is such a great idea, in part. While I support the general tone of the proposal, I take issue with the nationwide cap of 12 radio stations that could be owned by one entity should the FCC accept the provisions put forth.

Whether we agree or not, Clear Channel can own as many stations as they want, providing they follow market limits. With 290+ rated markets and a nearly infinite amount of others, they could theoretically own thousands of stations in the U.S. alone (and a lot of CPs come next filing window). The issue with LPAM and community broadcasting should be community. If one entity could program fifty stations with music that fits the local demographics, regional programming for multiple LPAMs in a market, etc., from one location, why not allow them to do so if they meet stringent service requirements?

By service requirements, I mean providing actual service to a community, not just having a name on a license. That could mean having a local team broadcast high school sports events on Friday nights, city council meetings, local PSAs, a talk show with the Mayor, etc. If there is local support, I don't see why not. Have limits that mandate a certain amount of local advertising so huge operators can't swoop in a throw national buys on 2,000 LPAMs.

My qualm with the proposal is that, for example, in the large metro where I live, I can see opportunities for several communities with distinct identities that could benefit from having the aforementioned services on the radio. But the proposed rulemaking would limit ownership to one station per market. What would be so wrong with having a central facility to feed content to low-power transmitters around the market (say, within 20 miles), provided each station had a small staff of volunteers or paid employees to run audio for each community-specific station? I realize this may open up the argument that community radio could become as mundane and overresearched as full-power AM/FM, but with limits the set more reasonable ownership caps and kept conglomerates out, I don't see why this couldn't be done.

Is the problem with CC, Infinity, Entercom, etc. that they own hundreds upon hundreds of stations, or that they pump out the same crap and severed all tied with their communities? When a CC morning show host spends his breaks reading traffic for four other markets, that becomes bothersome. But for any market where a large conglomerate has actually maintained local air talent, promotions staff, community involvement, high school sports, etc., what gripe can be laid against corporate radio? In the end, it's about what's delivered to the listener and not what we in the business nit pick about. Many of our community newspapers are merely one of twenty, one for each town in a greater metro area. Have a few receptionists had to find other jobs, sure. But are we being cheated out of a newspaper? No. Why a local group of radio experts with a proven commitment to serving community radio well shouldn't be allowed to do so is beyond me.
 
I agree with you, the only way such community stations could survive is to have some central programming & support group. the local signals should be required to produce X amount of local programming per a week. The local signal should be able to broadcast live if the local power grid fails. Our part 15 AM stations provide quality programming and local news produced by local schools etc. They use the network for programs that are of interest for the region.
The Radio Brandy broadcast store will offer quality equipment new and used, our goal is that any community group or individual will be able to set up a part 15 AM radio station for less than $2000 including basic studio equipment, audio processor, transmitter and antenna.
Where the real news comes first!
www.radiobrandy.com

Steve
Radio Brandy
The store for broadcasters

> I'm sure some will find flaws in this, but I'm not so sure
> the latest proposal from LPAM advocates is such a great
> idea, in part. While I support the general tone of the
> proposal, I take issue with the nationwide cap of 12 radio
> stations that could be owned by one entity should the FCC
> accept the provisions put forth.
>
 
LPAM is going to be 10 times worse than LPFM. Many LPFM's are unlistenable because of co-channel and 1st adjacent interference. This is especially true in the crowded northeast, where many LPFM's are shoehorned in.

Now take LPAM stations with how much power? 10 watts? 50 watts? Loaded into some short tower? How do you think that is going to sound, especially at night?

I also read a lot about community radio and broadcasting council meetings and blah blah blah. Put aside the appeal of such programming for a moment, and lets just focus on the man-hours and equipment needed to produce such programming. How can a community radio station fill even part of it's program day with programming that requires significant man-hours and expertise to produce?

Maybe some educational operations like Radio Brandy can pull it off if they have dedicated students and good management overseeing things, but I think those types of operations are few and far between. I'm sorry to say that I think many community radio proponents are more pie-in-the-sky than anything.

PTR

> I'm sure some will find flaws in this, but I'm not so sure
> the latest proposal from LPAM advocates is such a great
> idea, in part. While I support the general tone of the
> proposal, I take issue with the nationwide cap of 12 radio
> stations that could be owned by one entity should the FCC
> accept the provisions put forth.
>
> Whether we agree or not, Clear Channel can own as many
> stations as they want, providing they follow market limits.
> With 290+ rated markets and a nearly infinite amount of
> others, they could theoretically own thousands of stations
> in the U.S. alone (and a lot of CPs come next filing
> window). The issue with LPAM and community broadcasting
> should be community. If one entity could program fifty
> stations with music that fits the local demographics,
> regional programming for multiple LPAMs in a market, etc.,
> from one location, why not allow them to do so if they meet
> stringent service requirements?
>
> By service requirements, I mean providing actual service to
> a community, not just having a name on a license. That could
> mean having a local team broadcast high school sports events
> on Friday nights, city council meetings, local PSAs, a talk
> show with the Mayor, etc. If there is local support, I don't
> see why not. Have limits that mandate a certain amount of
> local advertising so huge operators can't swoop in a throw
> national buys on 2,000 LPAMs.
>
> My qualm with the proposal is that, for example, in the
> large metro where I live, I can see opportunities for
> several communities with distinct identities that could
> benefit from having the aforementioned services on the
> radio. But the proposed rulemaking would limit ownership to
> one station per market. What would be so wrong with having a
> central facility to feed content to low-power transmitters
> around the market (say, within 20 miles), provided each
> station had a small staff of volunteers or paid employees to
> run audio for each community-specific station? I realize
> this may open up the argument that community radio could
> become as mundane and overresearched as full-power AM/FM,
> but with limits the set more reasonable ownership caps and
> kept conglomerates out, I don't see why this couldn't be
> done.
>
> Is the problem with CC, Infinity, Entercom, etc. that they
> own hundreds upon hundreds of stations, or that they pump
> out the same crap and severed all tied with their
> communities? When a CC morning show host spends his breaks
> reading traffic for four other markets, that becomes
> bothersome. But for any market where a large conglomerate
> has actually maintained local air talent, promotions staff,
> community involvement, high school sports, etc., what gripe
> can be laid against corporate radio? In the end, it's about
> what's delivered to the listener and not what we in the
> business nit pick about. Many of our community newspapers
> are merely one of twenty, one for each town in a greater
> metro area. Have a few receptionists had to find other jobs,
> sure. But are we being cheated out of a newspaper? No. Why a
> local group of radio experts with a proven commitment to
> serving community radio well shouldn't be allowed to do so
> is beyond me.
>
 
My feelings are very mixed on an LPAM service. I support the concept of an LPAM service, especially in areas like Phoenix where LP-100 channels are not available, even if the RBPA gets repealed.

The Phoenix metro area has no local X-band full power stations and virtually no TIS activity in the X band. Therefore, this is a good place for LPAM and Part 15 AM stations.

One of the things that made the LPFM proposals go through pretty well was that it was a service that is very easy to determine available channels through the distance spacing methodology. Some in the LPFM community are now looking at a prohibited overlap model, especially in light of the Great Translator Invasion of 2003.

In order for LPAM to be successful, it must have a similar type of distance spacing model. The Baumgartner proposal did give numbers with substantial overprotection of full power station with a 30 ground conductivity. The FCC has even used distance spacing in the X-band for determining the original allotments back in the 80's. Distance separations also are used in the USA/Mexico agreement on the use of the X-band. Part 90 includes distance separation rules for TIS to TIS spacing.

The nice thing about the X-band is that a large majority of the stations in this band fall under one of two categories:
- 10kW Day/1kW Night non-directional (I know there's a couple of directional stations)
- 10 watt non-directional TIS stations

LPAM should remain in the X-band, specifically 1620-1700 kHz. 1610 kHz should not be used due to the high number of TIS stations on that channel as well as second adjacent channel issues with 1590 kHz. (We will have second adjacent channel issues with 1600 kHz but there are not that many stations with daytime facilities superior to a typical X-band (10/1-ND) station.

LPAM will be pretty much a crap shoot at night. Stations should be allowed to but not required to run at night, especially if their channel gets clobbered.

Then of course, the big legal question that will cause all kinds of debate, should LPAM be allowed to be commercial operations? I agree with the person posting concerned about the proposed national limit. I don't agree with the national limit of LPFM stations either. The number should be much lower.

Of course, one of the major things you need to consider if LPAM is made a commercial operation is that those who are well intended in seeing an opportunity for a small business (LPAM station) to bring something back to their community may get shot in the foot by someone who is able to land a singleton LPAM license to just run a continuous loop tape for the local Buick dealer on a 30 watt transmitter. Since the tape was recorded in town, it is local origination. There's a lot of issues that need to be discussed on the creation of an LPAM service. Not only do we need to look at the Amherst, et al petition but also the undocketed Baumgartner petition. Both petitions have many pros and cons. Let's take the best of both of them. While we are at it, let's get Part 15 amended to extend the 1705 kHz frequency limit to 1715 kHz to allow for Part 15 operation on 1710 kHz (I have noticed that the rules currently allow transmitting below 530 kHz)

Some things to think about here.

ec
WWW.LPFM.WS
WWW.LPAM.WS




> I agree with you, the only way such community stations could
> survive is to have some central programming & support group.
> the local signals should be required to produce X amount of
> local programming per a week. The local signal should be
> able to broadcast live if the local power grid fails. Our
> part 15 AM stations provide quality programming and local
> news produced by local schools etc. They use the network for
> programs that are of interest for the region.
> The Radio Brandy broadcast store will offer quality
> equipment new and used, our goal is that any community group
> or individual will be able to set up a part 15 AM radio
> station for less than $2000 including basic studio
> equipment, audio processor, transmitter and antenna.
> Where the real news comes first!
> www.radiobrandy.com
>
> Steve
> Radio Brandy
> The store for broadcasters
>
> > I'm sure some will find flaws in this, but I'm not so sure
>
> > the latest proposal from LPAM advocates is such a great
> > idea, in part. While I support the general tone of the
> > proposal, I take issue with the nationwide cap of 12 radio
>
> > stations that could be owned by one entity should the FCC
> > accept the provisions put forth.
> >
>
 
> My feelings are very mixed on an LPAM service. I support
> the concept of an LPAM service, especially in areas like
> Phoenix where LP-100 channels are not available, even if the
> RBPA gets repealed.
>
I'd say that the LPAM service should be closely wedded to the LPFM service.
LPAM shouldn't be available to an applicant unless there's no LPFM channel
(100 watts)available in a given area. I'd agree, 1620-1700 would be
the best home for LPAM. Ground wave coverage should extend no more than 5
miles for a 1 millivolt signal. Otherwise, the rules should be exactly the
same as LPFM, since LPAM should only be an extension of the LPFM service,
not a new service with new rules.

It should hopefully limit LPAM to the top 50 markets, meaning fewer nighttime
interference generators. Hopefully, the 3rd channel restriction will be
repealed for LPFM, which should keep LPAM numbers even lower.
 
AM and FM are two different animals and should not be "melded" together.

For starters it will mean, once again, private individuals will be shut out of the process. LPFM was a joke from the start and abuses by non profit organizations has led to numerous applications being dismissed for a variety of reasons including apparent multiple ownership of LPFM broadcast outlets.

If non commercial broadcasting was popular on existing AM radio then I might buy into the theory it will work for LPAM. In reality it won't. Check your arbitron rankings and you'll find that approximately 20% of the radio market at any given time (average) is tuned into an AM station. The other 80% are tuned into the FM dial. AM is more costly to develop and maintain than FM (according to my broadcast engineering friends) and this will require a real revenue stream to keep most stations afloat.

Do you remember what happened to Allston Brighton Free Radio in Boston? They failed. Steve Provizer started and ran a professional non profit radio station in a decent part of Boston's west end. They simply could not keep up with the costs associated with keeping even a part 15 AM station on the air despite the fact it's broadcast radius (through engineering techniques) was pretty close to what a 10 watt TIS would be in that area. It's a shame really because it was a fine station that really provided unique and valuable programming to that part of Boston.

Your idea to limit LPAM to only the top 50 markets wreaks of class warfare. Why should small metro areas and urban markets as well as rural areas be left out in the cold? More often than not, those markets are much more in need of a real local radio service than most major metro markets, most of which offer a variety of non commercial FM outlets to provide local programming.

Another factor that needs to be addressed is power levels. Very low wattage LPAM will be wiped out by IBOC at night and will, in addition wipe out part 15 AM channels that are presently occupied by some of the people on this message board. Between IBOC on AM at night (still a real possibility) and a ton of 1 to 10 watt LPAM in urban areas and you can kiss part 15 AM GOODBYE in every metro area of the country. Gone for good!

The bottom line is this, AM is not FM and has a totally different audience it serves. Power levels should be in line with the original Baumgartner Petition with current X band channel spacing allowances to insure that Part 15 AM outlets still have a shot at finding an available space on the dial in their respective cities and to provide enough power to get a usable signal out through all that IBOC hash when it starts to operate at night.





> > My feelings are very mixed on an LPAM service. I support
> > the concept of an LPAM service, especially in areas like
> > Phoenix where LP-100 channels are not available, even if
> the
> > RBPA gets repealed.
> >
> I'd say that the LPAM service should be closely wedded to
> the LPFM service.
> LPAM shouldn't be available to an applicant unless there's
> no LPFM channel
> (100 watts)available in a given area. I'd agree, 1620-1700
> would be
> the best home for LPAM. Ground wave coverage should extend
> no more than 5
> miles for a 1 millivolt signal. Otherwise, the rules should
> be exactly the
> same as LPFM, since LPAM should only be an extension of the
> LPFM service,
> not a new service with new rules.
>
> It should hopefully limit LPAM to the top 50 markets,
> meaning fewer nighttime
> interference generators. Hopefully, the 3rd channel
> restriction will be
> repealed for LPFM, which should keep LPAM numbers even
> lower.
>
 
> Of course, one of the major things you need to consider if
> LPAM is made a commercial operation is that those who are
> well intended in seeing an opportunity for a small business
> (LPAM station) to bring something back to their community
> may get shot in the foot by someone who is able to land a
> singleton LPAM license to just run a continuous loop tape
> for the local Buick dealer on a 30 watt transmitter. Since
> the tape was recorded in town, it is local origination.

Hmm, and there are just enough slimeballs out there (like that RAM bunch) who will sniff out a loophole like that and misuse it. Those are all good points.

Where I live, in the Los Angeles County area, the AM band is fairly full overall with a high amount of TIS stations littering the X-band (unlike Phoenix). But even with that, when doing a Rec-Net search, it does show that many cities within the county has at least one open channel on the X-band. So all is not lost here. But there should be more and I'd still like to see the issue of TIS stations addressed in this petition.

Something else that I feel should be looked at, especially with LPFM Expansion Bill coming up for discussion, is who among Congressmen stands to lose if the LPFM bill passes. Who has ties to media companies. And along with that, I would like to know who, among Congressmen, has been approached by the NAB.

I think we, as citizens, have a right to know that.

db
 
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