I can’t resist following up on K.M. Richards’ amusing tale of ingeniously “bending the rules” by incorporating his station’s legal ID into a top o’ the hour temperature check (Readers Forum, Aug. 4).
As a Washington lawyer representing AM and FM stations around the country, I was often presented with clever promotional and marketing ideas, to assure they would not run afoul of any FCC rule or policy.
Back in the Reagan era and the days of the old Emergency Broadcast System, when the weekly EBS test was locally originated and announced, a radio client of mine had a voice impressionist record the script of the announcement in the president’s voice. The usual formal and somber intonation, “This is a test of the Emergency Broadcast System,” was heard instead in Reagan’s informal, tale-telling, aw-shucks style. As the station’s attorney, I was asked whether this was permissible under the FCC rules.
The tickler was that the announcement ended with the “president” saying, “This concludes this test of the Emergency Broadcast System. (Pause.) Now, if you’ll all pass your papers to the left, we’ll see how you did.”
It was a simpler time. I gave the message a thumbs-up.
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