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Why do certain radio stations air their legal ID in the middle of the hour?

I have noticed that a number of radio stations air their legal ID somewhere in the middle of the hour instead of at the top of the hour. It seems that all of these radio stations are consistent with what time they choose to air their legal ID throughout the day. Most commonly, I have seen radio stations air their legal ID somewhere within a commercial break near the :40 minute mark.

Is there a reason for this?
 
Some stations "sweep" the top hour with music....NO breaks, save perhaps a liner like:"Now....another 30 minutes of today's BEST Rock.....!!"
Me...I'm "old school"...I STILL say the LEGAL ID should run at TOP HOUR, with only a few exceptions....Breaking news, continuous coverage of a major event (school shooting, tornado, etc.), live concert
music...Even here, a quick fade-down for a voice-over ID could be accomplished without "destroying" the program content, IMHO........
 
I have noticed that a number of radio stations air their legal ID somewhere in the middle of the hour instead of at the top of the hour. It seems that all of these radio stations are consistent with what time they choose to air their legal ID throughout the day. Most commonly, I have seen radio stations air their legal ID somewhere within a commercial break near the :40 minute mark.

Is there a reason for this?

Yes. For most stations, the ID is irrelevant. It's truly an anachronism for stations that don't call themselves by their call letters. For KFI or WCBS (AM) the calls are important, and given incessantly in the hour. The calls are the station name.

For B-101 or Y-100 or The Coast or Z-100, calls are a distraction because these stations decided to use names, not the calls. In fact, in most of the world, calls are not used at all. I have owned stations whose calls I can't remember. I have programmed stations where nobody on the staff knew them and on one occasion, to buy some equipment from the US, we had to provide them; it took a call to the government licensing authority to find out what they were.

Most programmers know that stations with names only confuse listeners by being too obvious with the calls. So they place them where they are least noticeable and least distracting. The FCC requires call letter IDs. Hopefully, they will see fit to allow the calls to be encoded as they do with translators and the like...it's 2019. Does Pandora have call letters? Does Spotify or Apple Music?
 
Some stations "sweep" the top hour with music....NO breaks, save perhaps a liner like:"Now....another 30 minutes of today's BEST Rock.....!!"
Me...I'm "old school"...I STILL say the LEGAL ID should run at TOP HOUR, with only a few exceptions....Breaking news, continuous coverage of a major event (school shooting, tornado, etc.), live concert
music...Even here, a quick fade-down for a voice-over ID could be accomplished without "destroying" the program content, IMHO........

and stations sitll do, as close to the top of hour as possible.... alot do it in the 50/52 stop set.. which im completely ok with. the only people who care about the legal id is the fcc and old radio guys and radi ogeeks.

My station does the le gal id at 05 after going into ABC or local news, as thats when we take our first commercial break of the hour
 
Does Pandora have call letters? Does Spotify or Apple Music?

Are they licensed by the federal government? Is payola on Spotify or Apple a federal crime?

There are differences and distinctions, maybe not to consumers, but in the legal world.

Spotify and Apple are digital platforms, while AM & FM are not. Spotify & Apple are interactive, while AM & FM are not.
 
Call letters go all the way back to the days before voice transmission, when International Morse Code was sent out by spark-gap transmitters. One can see why they'd be useful in such non-broadcast uses. It allowed the Titanic to send "CQD DE MGY CQD DE MGY" (and "SOS DE MGY SOS DE MGY" after one radio op reminded the other of the new distress call) instead of "SEND ASSISTANCE. THIS IS RMS TITANIC. SEND ASSISTANCE. THIS IS RMS TITANIC," decreasing the possibility of miskeying and misunderstanding and allowing more distress calls to be sent. There really is no reason they should still be used in voice mode on commercial radio but for the fact that the first American broadcasters used them rather than station nicknames or slogans, and that the FCC refuses to get rid of the legal ID requirement for broadcast stations.
 
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Are they licensed by the federal government? Is payola on Spotify or Apple a federal crime?

There are differences and distinctions, maybe not to consumers, but in the legal world.

Spotify and Apple are digital platforms, while AM & FM are not. Spotify & Apple are interactive, while AM & FM are not.

My point is that, were call letters a positive, all the new media services would have letter names just as in the past we had ones like IBM, RCA and AT&T to identify major corporations. We've moved away from corporate branding with initials to using easier to remember names.

So radio stations that name their product don't want to confuse listeners with the legal identification code.

I don't say "Hi, I'm 367-89-1234" when introducing myself. I say, "Hi, I'm David".
 
My point is that, were call letters a positive, all the new media services would have letter names just as in the past

They would if they were required. But because they're unregulated media, they don't have to follow that pattern.

However, I find it curious that Pandora and Spotify are trying to create identifiable "stations" within their platform, just like radio.
 


Yes. For most stations, the ID is irrelevant. It's truly an anachronism for stations that don't call themselves by their call letters. For KFI or WCBS (AM) the calls are important, and given incessantly in the hour. The calls are the station name.

For B-101 or Y-100 or The Coast or Z-100, calls are a distraction because these stations decided to use names, not the calls. In fact, in most of the world, calls are not used at all. I have owned stations whose calls I can't remember. I have programmed stations where nobody on the staff knew them and on one occasion, to buy some equipment from the US, we had to provide them; it took a call to the government licensing authority to find out what they were.

Most programmers know that stations with names only confuse listeners by being too obvious with the calls. So they place them where they are least noticeable and least distracting. The FCC requires call letter IDs. Hopefully, they will see fit to allow the calls to be encoded as they do with translators and the like...it's 2019. Does Pandora have call letters? Does Spotify or Apple Music?
I'm surprised by your response! Isn't it still an FCC requirement, meaning a fine for one infraction and loss of license for many? Are we just assuming that because they're woefully understaffed, you aren't likely to be caught?
 
I'm surprised by your response! Isn't it still an FCC requirement, meaning a fine for one infraction and loss of license for many? Are we just assuming that because they're woefully understaffed, you aren't likely to be caught?

The rule says "in a natural break in programming".

Stations have been putting the ID at the end of the hour's last stopset for decades. The FCC has not objected.

I am not suggesting that stations not identify per the rules. I am just observing that stations like to put the ID where it does not interrupt a music sweep, and that is legal.

Back when the ID had to be within +/- 2 minutes of the hour, I once got an FCC notice because the ID was 3 minutes off; it was summer and WWV had no signal into Puerto Rico most days, so getting the clocks set was sometimes hard. We explained this, and put up a better antenna and one of those $500 ESE radio clocks (about $3000 in today's dollars) and generally were OK except when there was no signal at all.

Many colleagues got similar notices, some as many as 5 or 6 times in a year for the same reason. The FCC never fined anyone. Fines are for willful and repeated violations of this type. When WWV was not available, there was always an excuse.

Now, the rule is much more flexible and, save technical errors, stations run IDs at a "natural break".

Many, if not most, FCC notices of violation have no fines. They simply demand corrective action and a response.
 
Technically though, if you're sneaking in a "wxxxwestpodunkbigcity" at :50 and doing a produced psuedo ID "The big station for the big hits, the all-new Q108", you'd think the "natural break closest to the top of the hour" would be the pseudo-ID. They aren't just sweeping the top.






The rule says "in a natural break in programming".

Stations have been putting the ID at the end of the hour's last stopset for decades. The FCC has not objected.

I am not suggesting that stations not identify per the rules. I am just observing that stations like to put the ID where it does not interrupt a music sweep, and that is legal.

Back when the ID had to be within +/- 2 minutes of the hour, I once got an FCC notice because the ID was 3 minutes off; it was summer and WWV had no signal into Puerto Rico most days, so getting the clocks set was sometimes hard. We explained this, and put up a better antenna and one of those $500 ESE radio clocks (about $3000 in today's dollars) and generally were OK except when there was no signal at all.

Many colleagues got similar notices, some as many as 5 or 6 times in a year for the same reason. The FCC never fined anyone. Fines are for willful and repeated violations of this type. When WWV was not available, there was always an excuse.

Now, the rule is much more flexible and, save technical errors, stations run IDs at a "natural break".

Many, if not most, FCC notices of violation have no fines. They simply demand corrective action and a response.
 
The only time I heard of fines from Legal IDs was when it was done incorrectly consistently. That was decades ago. I doubt stations ave been fined for around 40 years or more unless it was really bad. I worked an FM that insisted on adding "FM Stereo" between the call letters and city of license. And the only ID I heard on San Antonio's KLLS during the few years it was in the format was "San Antonio spells class K-L-L-S." Nothing buried in a stop set. In both examples we are talking 2 to about 4 years of this and no fine. That was the 1980s for both stations.

I did work a station that had a local newscast at 7:45 with a morning devotional from 7:50 to 8:05. The station owner insisted on doing a legal ID at 7:50 and 8:05 just in case. That was the 1980s.
 
When I worked at a station in Florida, I'd "hide" the legal id in a news and weather break.. because i was a radi ogeek that could.

".. and that's your Brevard County traffic and weather together.. its currently 87 in vero beach, 84 in titusville and the current WTIR Cocoa Beach temperature is 86 degrees"

Completely legal.

And fast forward to 11 minutes into this recording I made of KLAA 830 Los Angeles from my home in Laramie, WY.. you'll hear how they do their id . Is it legal? BArely, but it's legal

https://drive.google.com/file/d/18Gr6_Icxb9UwwChx2jwYvDpulyBAkhPB/view?usp=sharing
 
Technically though, if you're sneaking in a "wxxxwestpodunkbigcity" at :50 and doing a produced psuedo ID "The big station for the big hits, the all-new Q108", you'd think the "natural break closest to the top of the hour" would be the pseudo-ID. They aren't just sweeping the top.


The real issues are two: First, the FCC changed the window from a finite period at the top of the office. Second, the new wording is purposely vague in requiring the ID at a natural break in programming. That leaves it to the station to determine when a natural break happens.

Since there is no evidence of FCC violation notices related to this over the last 30 years, we can assume that those IDs at the end of a stopset or even buried inside the stopset are considered to be a proper fulfillment of the legal requirement.
 


The real issues are two: First, the FCC changed the window from a finite period at the top of the office. Second, the new wording is purposely vague in requiring the ID at a natural break in programming. That leaves it to the station to determine when a natural break happens.

Since there is no evidence of FCC violation notices related to this over the last 30 years, we can assume that those IDs at the end of a stopset or even buried inside the stopset are considered to be a proper fulfillment of the legal requirement.


years ago, I used to hear 101.5 providence do their id as "wwbbprovidence" slammed in-between two commercials at 50 after
 
WHCN-FM 105.9 of Hartford, a.k.a. The River 105.9, squeezes in "This is WHCN Hartford" at roughly :50 on the hour, give or take a minute.

WDRC-FM 102.9 of Hartford, a.k.a. 102.9 The Whale - Connecticut's Classic Rock, has their ID as "WDRC, WDRC HD1 Hartford". That's wrong, since there's also WDRC-AM 1360 of Hartford, too.

As a side note, WTIC-FM 96.5 of Hartford, a.k.a. 96.5-TIC, runs the classic American Top 40 show on Sunday evenings. They start each hour with a classic TOH ID from Casey. It's quite likely from the days of them carrying one of his non-AT 40 countdown shows. He said the legal as "WTIC-FM Hartford", which was correct at the time he voiced it. Obviously, he can't do a 2019 version, since now it would have to say "WTIC-FM, WTIC-FM HD1 Hartford". :(
 
When I worked at a station in Florida, I'd "hide" the legal id in a news and weather break.. because i was a radi ogeek that could.

".. and that's your Brevard County traffic and weather together.. its currently 87 in vero beach, 84 in titusville and the current WTIR Cocoa Beach temperature is 86 degrees"

Completely legal.

And fast forward to 11 minutes into this recording I made of KLAA 830 Los Angeles from my home in Laramie, WY.. you'll hear how they do their id . Is it legal? BArely, but it's legal

https://drive.google.com/file/d/18Gr6_Icxb9UwwChx2jwYvDpulyBAkhPB/view?usp=sharing
Does the recording say, "Orange County-Los Angeles"? If so, it seems like the only way that can be legal is if the station is licensed to Los Angeles and "Orange County" is the name of the parent company.



The rule says "in a natural break in programming".

Stations have been putting the ID at the end of the hour's last stopset for decades. The FCC has not objected.

I am not suggesting that stations not identify per the rules. I am just observing that stations like to put the ID where it does not interrupt a music sweep, and that is legal.

Back when the ID had to be within +/- 2 minutes of the hour, I once got an FCC notice because the ID was 3 minutes off; it was summer and WWV had no signal into Puerto Rico most days, so getting the clocks set was sometimes hard. We explained this, and put up a better antenna and one of those $500 ESE radio clocks (about $3000 in today's dollars) and generally were OK except when there was no signal at all.

Many colleagues got similar notices, some as many as 5 or 6 times in a year for the same reason. The FCC never fined anyone. Fines are for willful and repeated violations of this type. When WWV was not available, there was always an excuse.

Now, the rule is much more flexible and, save technical errors, stations run IDs at a "natural break".

Many, if not most, FCC notices of violation have no fines. They simply demand corrective action and a response.
I inferred a natural break in programing to refer to after the time a legal ID should be scheduled.
 
Does the recording say, "Orange County-Los Angeles"? If so, it seems like the only way that can be legal is if the station is licensed to Los Angeles and "Orange County" is the name of the parent company.

It's perfectly legal. KLAA is licensed to "Orange". So "KLAA, Orange" is a proper legal ID. They could say "KLAA, Orange Juice, Los Angles" or "KLAA, Orange President, Los Angeles" or "KLAA, Orange Soda, Los Angeles". As long as they say the calls, any optional accepted info like the owner, and the Community of License, anything that follows is irrelevant. "KIIS, Los Angeles Weather..." is also a legal ID.

I inferred a natural break in programing to refer to after the time a legal ID should be scheduled.

A "natural break" is any point where, in the reasoned opinion of the licensee, the ID does not interrupt the flow of the station's programming. One can, and it has long been accepted, not ID between movements of a symphony despite the thinking of some that "they are separate cuts on the album". To a classical programmer, the movements are intended to be heard sequentially, without anything else between them.

I think a well programmed music sweep is no different. The ID goes before or after it.
 
As a side note, WTIC-FM 96.5 of Hartford, a.k.a. 96.5-TIC, runs the classic American Top 40 show on Sunday evenings. They start each hour with a classic TOH ID from Casey. It's quite likely from the days of them carrying one of his non-AT 40 countdown shows. He said the legal as "WTIC-FM Hartford", which was correct at the time he voiced it. Obviously, he can't do a 2019 version, since now it would have to say "WTIC-FM, WTIC-FM HD1 Hartford". :(

There is some indication that the HD1, which must be a simulcast of the analog station, may identify by RBDS. This thinking parallels the allowance of translators to insert the ID in coded form that is not audible but detectable should interference complaints originate.

Of course, the original purpose of IDs was mostly to be able to control interference.
 
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