A current Radio World ebook explores the state of low-power FM in the United States as more stations prepare to come onto the dial as a result of the recent application window. This story is an excerpt.
REC Networks is a national regulatory advocacy firm that focuses on small broadcast stations including commercial, noncommercial and LPFM; it provides professional services to stations across the disciplines of FM radio.
It was launched in 1984 by Michelle Bradley as a telephone service called California Comments. REC would eventually start running interactive phone services that included features found in today’s social media sites.
Her involvement in LPFM dates to the original petitions for rulemaking. Bradley also runs websites including FCC.today and FCCdata.org, and she is president of Riverton Radio Project Association, which holds a CP for a new LPFM station, WVWA in Riverton on the Eastern Shore of Maryland.
Radio World: How significant is this expansion of the LPFM service?
Michelle Bradley: The third window was overdue. We saw more than 1,300 applications, though 213 were wiped off the top because of the whole Weather Alert Radio Network debacle. By contrast, in 2013 we had around 3,000 applications, but we had all the fanfare then around the Local Community Radio Act, and the FCC was holding back on translator grants because of the LCRA. In 2013 we also had a lot more spectrum to work with, and there were more urban opportunities.
Since then we’ve had the 2016 major-move opportunity for AM revitalization. Then we had Auction 99 and Auction 100 in 2018 and 2019. That pretty much wiped out most urban opportunities that were left for LPFMs.
I’m not against translators rebroadcasting AMs as long as they remain a secondary service. We need to preserve as much of the AM infrastructure as we can. AM still is still a vital service.
RW: So there are relatively few substantial urban opportunities?
Bradley: Yes, by comparison with the 2013 window, when for example we had 101.5 in Los Angeles. That was the largest mutually exclusive group of applicants ever for LPFM, it started with 32 of them.
In this window our two biggest MX groups both had seven applicants, one in Springfield, Mass., and the other covering a wide area of Puerto Rico.
RW: For someone who finds themselves with a CP, what first words of wisdom would you share?
Bradley: The minute your grant comes up, go out and get a call sign so you have your identity in order. If you don’t like it when you’re ready to build two years from now, you can change it to something else.
Start your equipment shopping. For a lot of applicants, especially those who don’t need a second-adjacent waiver, the application process was easy and didn’t cost much. Then suddenly they come to the realization that it’s going to cost them $4,000 to $5,000 for a new transmitter, another $3,000 to $4,000 for an EAS decoder, and sticker shock starts to kick in. They might be tempted to buy a transmitter from a company from China that they see on eBay or Amazon or even the Walmart website; but LPFM has a specific certification requirement for transmitters. And inspectors are looking for those labels.
RW: LPFMs need to be able at least to decode EAS?
Bradley: Yes, they’re like other secondary program originating services such as Class D FMs and LPTV stations.
But I cannot stress enough that they also need to keep in touch with what’s going on with EAS, such as when the next national periodic test is.
The numbers for LPFM participation in the NPTs have been horrible. But emergency alerting — keeping the public informed — is one of the few “big boy” responsibilities LPFMs have. They don’t have ownership reports, they don’t have EEO reports, they don’t have public files.
If they need help finding their EAS monitoring assignments, we can help them locate their state plan or put them in touch with their SECC or their state broadcast association.
RW: What other problems have you seen that could trigger FCC actions?
Bradley: The biggest is an administrative issue: underwriting acknowledgments. So many LPFMs — and full-service NCEs too — are pushing the envelope on this without legal resources to back them up in case something goes wrong. They might think, “No one will ever complain.” Then a little station in Colorado Springs gets a $15,000 forfeiture because they were running full-blown commercials.
Some stations think they just need to avoid a call to action in their underwriting announcements. Some think that as long as something is factual, they can say it, but that’s not necessarily true.
Underwriting acknowledgement announcements can identify the business but they cannot promote the business. The late Donna DiBianco recommended that stations start with a business-card approach. There’s a compliance guide on the REC website, I explain it there.
While anyone can get caught for such violations, the stations that are the most vulnerable are in smaller markets, where there are more owners who really give a damn about their local stations. They’re listening. And they see the threat to their bottom line if a little LPFM station that doesn’t pay any money to the government for the privilege of running a station is suddenly profiting off of commercials. We can’t have that.
The biggest technical error is not informing the FCC before they make a change. Some stations feel that they can just get up and move, like it’s CB radio; but operating from an unauthorized location is no better than silence. You do that for more than 365 days and you could lose the license.
Sometimes we hear about stations running overpowered. Also, not informing the FCC when you go silent — I get reports of stations that have been silent for several years but no one has filed a silent with the FCC. We need to know who’s on the air and who isn’t. Those who aren’t on the air can’t be on the warehousing spectrum; that’s not fair to LPFM and it’s not fair to translators.
Some people in LPFM see translators as the mortal enemy. No. I see us all sharing the dial.
I’ve had a good dialogue on this with the National Association of Broadcasters. NAB and I don’t agree on the LP-250 power proposal but there are a lot of things we do agree on, such as geotargeted boosters, multilingual EAS and the recent changes with CAP polling, which led to the first-ever joint filing by REC Networks and the NAB, which asked for an extension for users of Sage Alerting equipment.
I wrote in an op-ed a few years ago in Radio World that the threat to radio is not LPFM, it’s non-radio. And look how much it’s grown since — the streaming services and all the alternative media. Look what’s happened in the dashboard, where radio is five levels down on the menus, it’s outrageous. And carmakers are trying to kill AM completely off the dashboard.
We’ve got to do everything that we can to save radio, which is one of the oldest and greatest apps ever made for listening to audio. And you don’t need a cellphone subscription for it.
RW: How well do you think the service has met its original promise?
Bradley: What we have is different in a lot of ways from what we originally envisioned: that national, well-funded nonprofits with local chapters would apply for licenses, especially in urban communities, and construct the stations with money from the national organization flowing down into the local. That never really happened.
Today we’ve got a lot of smaller organizations, or just people who get together and form a little corporation because they just want to run a radio station, they want to be their own DJ. But many of them don’t have financial backing, they come into this with shoestring budgets, which is why a lot of them are not able to build before their construction permits lapse.
When the LPFM service was originally created in 2000, there was a national ownership cap of 10 stations.
The first LPFM filing window series limited each organization to only one application and only local applicants. In 2007, at the urging of Prometheus and others, the national ownership cap was reduced to one station and the local ownership requirements were made permanent.
RW: Can you name a couple of stations that demonstrate good LPFM?
Bradley: WHCP right up the road from me in Cambridge, Md., started as an LPFM, then participated in the 2021 NCE filing window and has graduated to full-service. They’re very local, very community involved; and they had good underwriters. People wanted to be associated with that station. There also wasn’t a political agenda like you find on some stations. I think that’s a good approach. It was a mix of music and talk.
KBUU in Malibu is an excellent example of a local station. Hans Laetz is there in the morning doing local news. He’s going to city council meetings. They stayed on the air in the aftermath of the Woolsey Fire in southern California carrying local information and operating on a generator for months.
The folks at Prometheus and Common Frequency will have their own “poster children” stations. Those are two of mine, and they provide compelling service to their communities.
RW: What should a new LPFM station avoid?
Bradley: Don’t try to compete with commercial stations. You want to be unique. And that’s also going to keep the commercial stations off your back.
Be there. Be positive. Do something good for your community and they will come.
Don’t hire former radio salespeople to go out looking for underwriting, which we see happen quite a bit. You should see the wild copy that I get because folks don’t understand the NCE requirements.
Also, avoid having your on-air talent do underwriting announcements live. Instead, they should be pre-
approved by station management, pre-recorded and run during programming breaks. And do not be tempted by certain programming trends done in commercial radio such as naming rights for the studio, unless it is executed within the noncommercial guidelines.
Know the rules and play by the rules. And reach out to the LPFM community! We exist. There is a community out here that can provide moral support. There are several useful groups on Facebook. I operate a couple, and there is one for community-learning stations called LPFM Solidarity. But find a tether to stay connected and informed, whether that’s through REC or Prometheus or John Broomall of Christian Community Broadcasters.
An informed station is the best station.
