North Cascades Broadcasting
KOMW AM 680 FM 92.7
700 Emery Street
P.O. Box 151
Omak, WA 98841
Business: (509) 826-0100 - (800) 725-5669
email: ncbi@northcascades.net
Fax: (509) 826-3929
www.ncbi.net

April 24, 1998

Federal Communications Commission
Room 222
1919 M. Street NW
Washington D.C. 20554

Re: File #RM-9208 & RM 9242.

FCC Comments:

I am writing today to express my extreme concern regarding the commission's proposed action to allow more low power stations. I own and operate 2 FM stations and 1 AM station in rural communities in Washington State.

I seriously challenge the concept that low power stations are necessary to better serve communities. I know of a half dozen stations (KOMW AM & FM, KOZI AM & FM, KVLR FM, KCVL....) in my area alone that work very hard to provide the kind of coverage that communities need. These stations and many others provide great coverage of local events, hours of free air time on local shows on local issues, free air time in interviews for local and regional political candidates, live election night coverage, local sports events, local issues forums and local call in shows for buy sell and trade of personal items and discussions of important or interesting topics. These stations count on the wisdom and representation of FCC commissioners to help them be able to operate in an already VERYcompetitive marketplace.

This action will result in very uneven competitive pressures on existing stations unless these new stations are required to follow the same very expensive engineeeing and licensing regulations that impact other broadcasters. We operate in much the same markets as these low power stations (I have at least 4 unlicensed pirates in my coverage area). ANY inequity in regulation will create unfair advantages for the lower power operators. I know of numerous stations that will be impacted very negatively by low power if it does not carry the same expensive requirements as conventional broadcasting because many stations operate in very small markets. Small markets mean small advertising budgets that dictate low radio advertising rates for broadcasters. If low power is going to mean cheaper regulatory requirements then that amounts to an uneven playing field in the market place in which we must make our living. More to the point:
 

  1. No translators should be allowed period, for low power broadcasters. If translators are allowed, the lower stations will be able to chain them together to produce a coverage area similar to higher power, very expensive conventional stations.
  2. EAS compliance should be required. If these low power stations are in reality going to better serve their communities then they should be required to serve them with emergency information as well.
  3. All spectrum use fees, licensing fees, monitoring requirements etc should apply to low power as it does under existing licenses.
  4. Any new station must meet the same rigid interference requirements in place now.
My experience with pirate broadcasters has been a very negative one. These illegal broadcasters have attacked me on the air personally and professionally. I have no belief that their actions should have earned them the opportunity to occupy the airwaves. If I chose to operate in the same manner, I am sure my license(s) would be in jeopardy. For the reasons I have stated here I strenuously oppose the FCC's proposed action in regard to low power broadcasters.
 

Sincerely,

John P. Andrist
Owner
North Cascades Broadcasting, Inc.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 

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