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radiomike
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WestsideBulldog said:Some good points but .....Still I disagree you are pointing things out from a distance. It comes across as your second guessing that they do not know what they are doing or that they do not know non-comm rules and regs. I'm sure many in the non-comm biz has seen the DEI site. Anytime a non-comm is not NPR based it brings out the ney sayers. DEI is a HUGE NPR supporter. Sure there are rules ALL non-comms must follow but not all on the DEI site are FCC regs. NPR and PRI do not make the rules they simply follow the rules set forth by the FCC (how poor they are written or not). The rules are clear but to say a non-comm station must sound like a typical non-comm because CC or others will be listening is crazy. If they follow the non-comm regs and FCC guides for underwriting then no problem.
As to any kind of remotes I have not seen much in the way of FCC writings or guidlines saying what you can and can not do. Do you have a refrence? I have heard many non-comms do them at sporting events, fairs and festivals but not sure about businesses. I have read about the restrictions but never seen the rules in writing.
As of late ClassX has been getting better every day.
Ok, Let's take this one step at a time. I do not live in the Cincinatti metro. I visit there, due to relatives or business from time to time, so it is at a distance.
Seond, DEI is made up of many different stations. Large, Small, NPR members, non-members, community stations. They are a membership organization to help non-commercial stations fundraise, in both traditional "public radio methods" such as funddrives and underwriting, to non-traditional ways such as internet, long term gifts, foundations, etc. Thus, they are not supporters of NPR. Take a look at this page, which lists some information on FCC based guildelines for underwriting credit language at the national level, to keep conistant and legal content. http://www.deiworksite.org/index.asp?Type=B_LIST&SEC={29835A56-1B98-49D8-8A6B-16E934158206}
Third, there is nothing in my post or anything else to say that your station has to sound a certain way. The caution was that if your station in its on air copy sounds like a commercial station, meaning the underwriting copy, then it will gather attention. This is even more so if the annoucements are highly produced. The FCC has stated this in the links below, which carries all kinds of information to violations and other restrictions non-commercial stations have to live with compared to their commercial cousins. The problem is that either stations don't know the rules or they do, and try to stretch or get away with it, until caught. Many feel they have to do this to get the money. Sadly, all they have to do is educate the business owner on the power of underwriting on their station, and they don't have to use language that is illegal.
The FCC has cited stations and mentions in some of the links below that unless their is some overwhelming public interest aspect, non-commercial stations are limited in what they can do in terms of remote broadcasts at commercial establishments.For example, In most cases, the station is given space to broadcast, electricity, a phone line. All this is consideration, and thus now falls under underwriting rules. Thus, the station can not tell people to come see them, or come on in (The FCC has also ruled in cases where the station is at a business with no relationship, inviting the people to come in to see the station, is a call to action to come into the business). Underwriting acknowledgements can only identify the underwriter. No call to action, no compartive or qualitative languange, no price or incentatives. Even "free" is price.
A public place, such as a park, the middle of a shopping Mall (with some restrictions), at festivals, country fairs, outside of sporting events, etc. are fine, as long as the nature of the broadcast does not have a commercial interest.
As for on air fundraising, non-commercial stations are only allowed to raise money for the station itself. Outside of PSA's, all on-air fundraising has to go to the station. Thus, radiothons or other fundraisers are not permitted. There is an exception: You can request a waiver from the FCC. To date, the FCC has only granted 5 waivers: the recent was for disaster relief in the wake of Katrina.
Some may think all of this is too restrictive. However, non-commercial stations do not pay regulatory fees, application fees, taxes, and get other benefits their commercial cousins do not.
Here are two links that may be helpful:
http://www.fcc.gov/mb/audio/nature.html This is a collection of FCC docuements, papers, texts, and notices involving years of FCC staff and case law.
http://www.gsblaw.com/resource/pub_result.asp?ID=1820437272006 This is a presentation made by attorney John Crigler at the recent Development Conference that will be quite enlightening in terms of what you can and can not say in underwriting.