[grc] LPFM Community Learner’s Permit

[Michi Bradley]

Greetings from California.  I meant to respond to this last night but 
since I am still on Eastern Time when I got back to my base, I was tired 
and immediately crashed.

In the late 90s, there were several driving forces that made LPFM a 
reality.  While the Prometheus Radio Project of the time (Pete Tridish, 
et al) and other aligned organizations can be credited for urging the 
Commission and lawmakers to fill in the void of local radio that was 
created by the passage of the Telecom Act, there were other driving 
sources working behind the scenes on the actual petitions for 
rulemaking.  Its important to remember that for regulatory purposes, the 
LPFM service was originally petitioned by an LPTV speculator and a group 
of hobbyists.

RM-9208 was written by Nickolaus Leggett and Don Schellhardt, which 
originally suggested a "cellular" type service where one channel could 
be used at multiple locations.  They would later update the proposal to 
be something similar to what we had with LP-10 and LP-100 stations.

RM-9242 was written by Rodger Skinner, who envisioned LPFM to be like 
LPTV (including being commercial) and would have consisted of up to a 
3kW primary service and a 50 watt secondary service as well as temporary 
special event stations.

At the time, REC was aligned with the RM-9208 camp and was involved in 
pushing Leggett and Schellhardt to move away from the cellular concept 
to the small station concept.

While there were about 1,000 construction permits issued in the first 
LPFM (2001/2002) filing window, there was an increased interest in the 
service for the second window since the passage of the Local Community 
Radio Act and the opening of the third adjacent channel as well as other 
changes unrelated to the LCRA (such as eliminating the IF separation 
requirement).

When there was a suggestion made awhile back for a "national 
organization for LPFM stations", REC did research on the organizations 
that are operating LPFM stations and developed the "6 segments of LPFM", 
a system that defines the type of organization that is the licensee of 
the station.  The primary segments are (1) cause-based organizations 
[existing orgs that were not originally in mass media], (2) community 
media [existing orgs that were previously involved in mass-media as 
their primary function], (3) microradio [orgs that were established for 
the sole purpose of operating the station], (4) faith-based [including 
educational institutions], (5) secular educational [K through 
university] and (6) government/public safety.  Within those segments, 
the station/licensee type is further broken down into subsegments.

REC's conclusions at the time was that those who are involved in the 
"grassroots" efforts of LPFM mainly come from cause-based and community 
media segments.  These segments represent about 25% of all LPFM licensed 
LPFM stations.  The segment with the largest number of stations is the 
faith-based segment with about 50+% of all LPFM stations with microradio 
also taking a large claim of LPFM licenses.

With that said, what about this "learner's permit" process?  All LPFM 
stakeholders are responsible for learning about the rules, statutes and 
processes involved with the service.  This means that stations are 
responsible for assuring that they are following the news items that 
come out of the Media Bureau and the Public Safety/Homeland Security 
Bureau (for EAS).

In other broadcast services, there are "service organizations" such as 
state broadcasters associations and national organizations such as the 
NAB, NRB and NFCB that keep stations informed of activities at the FCC 
and other agencies that could impact them. Despite what some think, 
there is no single organization that does this for full-service 
stations.  This is because not every station is an NAB member (I know 
some small commercial stations that refuse to join NAB).   LPFM stations 
cannot necessarily rely on these service organizations for information 
because of the distinctive aspects of Subpart G (the LPFM rules).  Only 
NFCB comes close to providing LPFM-centric information from a national 
membership organization.     Large stations also have legal firms on 
retainer to further demystify the information received by the FCC and 
other agencies and organizations.

LPFM stations are on their own.  Many have a "staff" of only one.  These 
folks have a station to manage, programming to put on the air, etc. They 
sometimes need information spoon-fed to them, just out of necessity.  
This is one way that the information provided by REC, Prometheus, Common 
Frequency, CCB and others come into play.  REC uses channels such as the 
websites and social media to get information, including breaking news to 
as many LPFM stations as possible.  I take many calls and e-mail 
inquiries for advice and clarifications under the "the advice is free 
but if you feel that its worth more than that then please donate" 
policy. Unlike many others here, I do not have a station to run on a 
daily basis, so I live and breathe policy and other issues in all of the 
radio services.  I am funded by donations and by those needing services 
utilizing tools and skill sets that are well outside what others possess.

REC's policy approach is based on a citizen's access to the airwaves 
with the common good in mind taking into consideration the impacts to 
other services as well as compliance with statutes.  REC also supports 
maintaining the integrity of the entire LPFM service and does not give 
preference to any segment, however we will favor stations that operate 
within the spirit of the LPFM service which calls for locally-based 
organizations where profit is not a motivation.

I invite stations to learn about the application processes and I do 
publish information on how to make filings themselves such as the recent 
video I put out on renewals.  REC is also involved in tracking renewal 
response to ensure that LPFM stations are reminded of their obligations 
in order to maintain their licenses.

REC touches LPFM stations in all 6 segments, REC also touches the FCC in 
the Media Bureau, PSHSB and offices of the Commissioners.

While I encourage LPFM stations to "learn" more, REC is not going away.  
I have been involved with LPFM for 20+ years now.  There are potential 
changes coming down the pipe and possible filing windows coming up.  We 
need service organizations like Prometheus and REC more than ever.   
Even though Prometheus and REC have different "agendas" and don't always 
align on issues, we both have a common goal and that is to preserve a 
level of non-corporate access to the airwaves.

The "learner's permit" concept and the service organizations can co-exist.

For now, this conversation should move to the grc or nceorg lists as not 
everyone uses Facebook.

Michelle Bradley, CBT
Founder
REC Networks



On 6/6/2019 2:02 PM, Paul Bame via grc wrote:
> LPFM Community Learner’s Permit
>
> (cross posted to LPFM Solidarity FB group and GRC mailing list)
>
> Renewals have begun and everyone saw it coming. Everyone can guess that
> some stations will need contract help, some just a how-to guide, and others
> can do it all; and that stations who succeed have the know-how to help
> others. There are a whole lot of LPFM stations and it doesn’t make any
> sense for each one to take this on from scratch. But where was the
> organizing together to make it happen?
>
> Luckily, Prometheus, REC, and other service providers looked ahead, and
> developed renewal guides and other resources, prepared to do contract work,
> and to answer questions on line and elsewhere – in this case also
> investigating some last-minute twists and turns in the LPFM renewal rules.
> That’s the way things have been working for a long time. [and there are
> additional folks who’ve stepped in on the policy side, and… FYI ETRS/NPT is
> coming]
>
> But stations aren’t driving their own collective bus – we providers are
> still doing that.
>
> Maybe its time for stations to get a collective learner’s permit.
>
> Could that start out as simple as this? Instead of assuming the providers
> are going to step up to the next common need or issue, might a responsible
> driver might ask those providers up front what they’re planning, and get
> the word out?
>
> Even that implies a lot… like who has the role to reach out? Who has the
> role to communicate and how? How will the institutional memory be kept –
> for example I pledge to write a renewal guide and then don’t deliver? Who
> will know what the outreach person is doing, and to whom are they
> accountable? Who decides that something’s important enough to do outreach
> in the first place? Is this an organization? Collective? Hierarchy? Is it
> as simple as a communication checklist someone promises to initiate every
> month?
>
> I don’t think service providers are likely to drive the LPFM bus into a
> ditch, and I do want to inject some realism… I’m doing most of the service
> work at Prometheus right now as a volunteer who sometimes receives
> sub-contract consulting fees. My gross last year was less than the poverty
> line, and will be worse this year, so my love of radio and savings account
> are funding pro-bono LPFM services, and I’m not getting any younger. That
> doesn’t scream sustainable to me… Occasional public comments by REC lead me
> to believe that passion is making up for low funding there too.
>
> There are strong currencies besides money in our community too – don’t get
> me wrong. But I ask the LPFM community of stations, is it time to get a
> learner’s permit?
>
> (I mean no disrespect by not mentioning other groups in this space)
>
> Paul (pablito) Bame
> Prometheus Radio Project <http://prometheusradio.org/>, Engineering Director
> 215.727.9620 x505
> N0KCL/3
> _______________________________________________
> grc mailing list
> grc at maillist.peak.org
> http://maillist.peak.org/mailman/listinfo/grc