Low-power proponent Christian Community Broadcasters says the FCC should evaluate data provided by LPFMs themselves, rather than from existing full-service FMs, as the agency reviews the economic impact LPFMs have had on commercial FMs.
In comments to the FCC in preparation for the agency’s report to Congress, CCB says all stations want to be monetarily successful, serve the public interest and have a positive impact on their listeners.
“[N]either the IRS nor the FCC expects or wants non-profit organizations to hurt businesses economically. No LPFM operator or advocate, including CCB, believes that LPFM has had [or will have] significant impact on commercial broadcasters,” states CCB. If correct, it added, the FCC has an impossible task: proving a negative.
CCB is a consultancy founded by John and Henri Broomall in 2000.
It says there are too many economic and other variables at play to predict how adding more LPFMs to the FM band might affect full-service stations. There are 852 licensed LPFMs, according to CCB. While Congress is only interested in FM, CCB said, AM radio, translators and full-power non-com broadcasters “are all important variables that are not being considered” in the big picture.
It’s not clear to CCB whether Congress mandated that the FCC consider the effect of all LPFMs, or only possible future ones, on commercial FMs. CCB asks whether it should evaluate both new low-power stations made possible by the Act and those on available frequencies under current regulations.
Changes in advertising revenue could be important, said CCB, and it suggests the FCC look first to comparing the economic impact of different classes of stations with comparable power. Most LPFMs do not pay rent and rely on volunteer workers and operate on under $1,000 monthly, CCB estimates.
It considers the relevance of audience ratings “secondary” and said audience levels should have no “significant role” in the report because there’s no clear protocol that directly correlates ratings to revenue.
The relationship between LPFMs and FM translators is important to review as well, CCB wrote, and spectrum use in the future should be considered, especially if LPFMs were to possibly begin sharing TV Channels 5 or 6 someday.
CCB noted that according to the LCRA text: “Nothing in this section shall affect the licensing of new low-power FM stations.” It interprets that as good news for low-power stations, no matter what the report to Congress says.
— Leslie Stimson