OK, I gotta share this listener's note

[davideduardo]

Did you miss my "It would probably be best NOT to post a letter that didn't make it into the PIF" comment? A few examples you noted, might not. Anonymous rants being about the only letter that probably wouldn't. But everything else, including song requests, does. The FCC rules state that every communication goes in, except deflamatory(sic) material. I would suspect SPAM letters don't go in either. But eveerything else does. I'm not going to debate this.

Of course you are not going to debate it, which is your reaction to any subject you have been proven wrong on, such as the recent erroneous comments you made on modulation rules. Remember, the one where you tried to nail FMs with 110% modulation for overmodulating, even when they had SCA's running?

The FCC rule requires only the filing of comments and suggestions. Most FCC attornies, the "mock inspection" experts from state broadcaster associations and the NAB legal handbook state that this means 1) specific remarks regarding programming 2) specific suggestions on programming improvements. It is considered, by case law, to exclude letters that are unsigned, those using profanity or threats or similar, and communications that are simply song requests, contest participations, fan letters to specific DJs or talents without suggestions or comments on the station itself, etc. The FCC's intent is to have filed those letters that specifically address the licensee's respnsiveness to audience needs.

Read the rule again, and look for case law based on fines for incomplete Public Files. Only "comments and suggestions" which are related to the operation of a statin are to be included.

The FCC wants these letters separated from the ordinary listener mail so it can be seen clearly. Using an example of an LA FM I am familiar with, were every request, contest entry or jock fan mail piece to be printed and filed, there would be thousands a week, maybe 100 thousand or more a year. It would be impossible to separate the ones with suggestions and comments from the "can you play a song for my wife" ones. That is not the FCC's intent, and you know it.

 

[radi0chik]

lots of stations include ALL correspondence, whether its REQUIRED by the FCC or not; they just figure it's better to be safe than sorry. I've never heard of the FCC fine someone for including a "can you play this song for my sweetheart" letter in the Public File.

 

[davideduardo]

lots of stations include ALL correspondence, whether its REQUIRED by the FCC or not; they just figure it's better to be safe than sorry. I've never heard of the FCC fine someone for including a "can you play this song for my sweetheart" letter in the Public File.

Of course they are not going to fine you for overdoing it. But the spirit of the rule is in having just the comments and suggestions on programming issues in the file. A station that might get hundreds if not thousands of e mails, text messages, faxes, letters, etc., per week and which filed all of these would be seen as obstructing the viewing of those with some content.

 

[Robert Bass]

I stand behind my findings on both the Modulation levels and the Letters from listeners rule. If I had a CONsultant working for me that suggested my conerns were invalid, I'd terminate the contract. The reason I don't debate the so called challenges, is because those are more often OPINIONS.

CONsultants spin everything....

R

 

[davideduardo]

I stand behind my findings on both the Modulation levels and the Letters from listeners rule. If I had a CONsultant working for me that suggested my conerns were invalid, I'd terminate the contract. The reason I don't debate the so called challenges, is because those are more often OPINIONS.

On modulation, you said that a variety of DFW stations were overmodulatiing, while the FCC rules specify up to 100% modulation is permissable if a station has its SCAs operating. So 110% in this case is NOT overmodulating. You also misunderstood and mis-stated the miniimum peak level for excursions of frequent recurrence, and totally botched the average modulation issue.

Similarly, you are missing the intent of the Public File rules on comments regarding programming. The FCC obviously wants letters and communications of substance, not e-mails with requests. To populate a file with tens of thousands of requests and contest entries actually could be considered an attempt to hide or obfuscate any letters of substance, since nobody would ever wade through thousands of contest entries and jock fan mail to find a significant and important letter with comments and / or suggestions.

The FCC expects reasonable standards to be set based on its rules. For example, a daytimer can run fulltime in an emergency and a station with a better day signal can keep on the day operation at night in such a case. The FCC has not defined an emergency nor has it created a list of acceptable emergencies. It expects licensees to understand the events that affect their service areas and not to consider the area high school baseball series an emergency, while probably finding that a Force 3 hurricane is such an event.

The set of standards for each rule often comes fromm addministrative law, where fines and notices of apparentl liability are contested and license renewals are put in question. If you have ever been in ahearing before an ALJ, you know that rules are just as subjective as laws, and circumstances often weigh on each situation.

If you think being called a "consultant" with your silly and infantile capitalization is an insult, you are wrong. I am proud to have been involved with a large number of successful staitons, and have benefited from the variety of experiences this has brought me, including a very significant license renewal case in the 80's where I was qualified as an expert witness before the FCC.

 

[Robert Bass]

I stand behind my findings on both the Modulation levels and the Letters from listeners rule. If I had a CONsultant working for me that suggested my conerns were invalid, I'd terminate the contract. The reason I don't debate the so called challenges, is because those are more often OPINIONS.

On modulation, you said that a variety of DFW stations were overmodulatiing, while the FCC rules specify up to 100% modulation is permissable if a station has its SCAs operating. So 110% in this case is NOT overmodulating. You also misunderstood and mis-stated the miniimum peak level for excursions of frequent recurrence, and totally botched the average modulation issue.

No you misunderstood what I said... I said 110+% I noted one of them was hitting close to 135%. I also did not mention whether the stations I tested were running SCA or not.

See what I mean about spinning? You're proving my point.

If you think being called a "consultant" with your silly and infantile capitalization is an insult, you are wrong. I am proud to have been involved with a large number of successful staitons, and have benefited from the variety of experiences this has brought me, including a very significant license renewal case in the 80's where I was qualified as an expert witness before the FCC.

Film at 11:00

R

 

[davideduardo]

No you misunderstood what I said... I said 110+% I noted one of them was hitting close to 135%. I also did not mention whether the stations I tested were running SCA or not.

See what I mean about spinning? You're proving my point.
[/quote]

You were the one who said that you could measure modulation in Adobe Audition; FM modulation is measured by frequency deviation and is an artificial construct where */- 75 kHz is 100%. You can not measure deviation in frequency in Audition... it is not a frequency monitor.

 

[Robert Bass]

No you misunderstood what I said... I said 110+% I noted one of them was hitting close to 135%. I also did not mention whether the stations I tested were running SCA or not.

See what I mean about spinning? You're proving my point.


You were the one who said that you could measure modulation in Adobe Audition; FM modulation is measured by frequency deviation and is an artificial construct where */- 75 kHz is 100%. You can not measure deviation in frequency in Audition... it is not a frequency monitor.

When did I make such a claim? I used a Belar mod monitor connected to a Belar tuner. I did run some additional comparrisons with Audition, but this was after I ran the tests on the mod monitor. The percentages I listed were from the Belar mod monitor.

R

 

[TheRover]

David & Robert.... this is interesting....

I think we need to consider having a stickyed thread Titled:

"Bass & Eduardo"​

8)​

 

[Robert Bass]

David & Robert.... this is interesting....

I think we need to consider having a stickyed thread Titled:

"Bass & Eduardo"​

8)​

Ummm.... NO! ;D

R

 

[MikeShannon914]

That'd be right up there with Martin and Lewis, Hannity and Colmes, McGarry and Campos, Tinsley and McCarthy, Shannon and Martin... ;D

 

[muzzled]

Abbott and Costello, Hope and Crosby,The Captain and Tenille, ...walton and Johnson?

 

[CW]

David & Robert.... this is interesting....

I think we need to consider having a stickyed thread Titled:

"Bass & Eduardo"​

8)​

Even better,
put them on FM talk stereo...one in one channel and the other in the other channel.....and in different studios and delay each other's reply to the other...OH talk about ratings =