LPFM Reply Comments
Harold Hallikainen - Argues that should
the Commission not find the petitions acceptable, the Commission should
institute a rulemaking on its own motion. The "need for service"
should be determined by the market, not by a government study. Argues
that "diversity of voices" is more than "diversity of music formats," and
that this diversity is desirable to society, and that this diversity can
only be achieved through diversity of ownership. Recognizes
potential for interference with existing stations and suggests use of existing
FM translator interference criteria along with setting aside a band for
license-free operation. Recommends use of FCC approved equipment.
Suggests that point of origin of programming on FM translators is not likely
to vastly increase FCC workload. FCC oversight of unlicensed stations
(in dedicated band) would be similar to FCC oversight of cordless telephone
operators. Argues that failing to authorize LPFM results in inefficient
use of the spectrum, as "gaps" between existing full power stations could
be utilized to serve local audiences. Suggests use of auction of
spectrum leases to award licenses. Suggests ownership limit of one
station per licensee. Recommends against preferences for existing
licensees (such as AM or LPTV). Suggests EAS equipment be required
at licensed stations (translators authorized for local origination).
D. Hicks - In response to comments by NAB, claims that if existing
stations were adequately serving their communities, there would not be
the interest in LPFM. While various stations are playing various
music formats, the formats tend to be repetitive, rarely introducing new
C. Kirsch & Hugh L. Gilderson - Requests amnesty for existing unlicensed
stations. One watt is not enough for community stations. Owners
should live within 25 miles of station. There should only be one
station per owner. LPFM should not be restricted to nonprofit.
LPFM stations should be required to have local content.
Koskinen - Supports LPFM. Is tired of "big corporate radio stations
who are accountable only to their stockholders and not to the public."
Agrees with Americans for Radio Diversity that 1 watt is insufficient,
that owners should live near the stations, that there should be a limit
on the number of stations one can own, and that LPFM stations should be
required to have local content. The FCC should respect the first
amendment rights of existing unlicensed community broadcasters.
Langdell Creative Broadcast Services - Supports the LPFM proposals
for listed reasons: 1. It's "doable". Interference problems
can be resolved. 2. Helps "establish community" and provides
advertising opportunities for neighborhood businesses. 3. Balances
the control of broadcasting between large and small owners. 4.
Allows the rich and non-rich to own stations, improving their individual
life as well as the community. 5. Allows communities to recover
lost local radio service as existing stations program to larger nearby
communities. 6. Low power stations can be licensed to serve
the public interest. 7. The addition of low power stations
will reinvigorate local radio. Gives details of the Yuba City (California)
Majic - "One watt is not enough for community stations. Owners
should be required to live near their stations. There should be a
limit to the number of stations any one person can own. These stations
should be required to provide local content."
McCord - "It has become dramatically apparent that a distinctively
local radio service is needed." "During the firestorm [Southern California
fires of 1993] the stations from L.A. were here in helicopters, but the
coverage was focused on the fire's sensational value rather than the dissemination
of critical information the people of Laguna Beach needed." "We learn
nothing in this community on an 'instant' basis." "... we are too
small in the overall scheme to swing ratings for more diligent coverage
by these broadcasting monoliths. Now with the potential advent of
Low Power FM the large radio voices are screaming infringement on their
territory?" Diversity is not "diversity of music formats",
but rather "diversity of ownership", giving "... Americans the opportunity
to the widest possible range of opinions."
Painter - Supports RM-9242 proposals. America needs the diversity
of voices LPFM would offer and the existing large owners do not provide.
NAB and other industry groups that have filed opposing comments speak to
extend their members' exclusive use of the spectrum. They do not
speak for the majority of the population. Use of second and third
adjacent channels by LPFM stations would not cause any more interference
than the existing 460 grandfathered short-spaced full-power stations.
In addition, there will be no interference from future IBOC digital broadcasting.
LPFM stations should have coverage comparable to LPTV stations, covering
a 15 mile radius. Supports the proposed three tier power proposal
with a maximum of 3,000 watts. Supports the local residency proposal.
C. Pike - Airwaves are currently dominated by large corporations.
These stations lack in diversity and representation of the communities
they serve. It is currently too expensive for most people to start
a radio station. Agrees with Americans for Radio Diversity position
that 1 watt for LPFM is insufficient. Supports ownership limits and
local content requirements. The FCC should grant amnesty to existing
pirate broadcasters for their civil disobedience.
Port - Supports the establishment of a noncommercial LPFM service as
proposed in comments on RM-9208 filed by the National Lawyers Guild's Committee
on Democratic Communications. Those commenting in favor of LPFM are
writing for love, while those opposing LPFM are writing for money.
It does not matter if an LPFM service causes financial harm to existing
stations. They were not guaranteed a profit. Creation of an
LPFM service should not be looked upon as "rewarding the pirates."
Instead, "pirates" have broken unjust laws, as has been done throughout
history. It is ironic that as other media become more democratic
(especially the "everyone's a publisher" aspect of the Internet), that
broadcast ownership has become restricted to the rich.
Santos - Expresses support for the establishment of LPFM. The
airwaves belong to "We the people." Stations are to serve their community's
needs and interests. Having a station license is a great responsibility,
and owners are mere stewards. Those with limited financial resources
are precluded from access to radio. Wonders if the Commission will
be able to approve RM-9242 with all the pressure from politicians and big
station lawyers. Radio cannot become a Wall Street commodity.