Better Process and Information

I realize that the Southern Development Foundation is one of a very lucky few groups right now.  Dozens of other schools, churches, workers' groups and 4-H clubs all across the south are caught somewhere in the Commission's licensing process for our type of station.  As hard as the FCC staff are working on low power radio, some of their significant effort is misdirected because the general procedures are geared toward larger commercial stations.  In particular, low power radio applicants need information directly from the FCC about the status of their applications.  It is impossible to motivate volunteers in the absence of information.  The FCC may now be processing the applications of potential stations that have given up and moved on to other projects because they have no idea when their application will be processed.  The FCC routinely issues notices with 30 days of lead time, for organizations that often must await a monthly board meeting to make decisions, 30 days are meaningless.

We have a very, very short time to get a station on the air once a construction permit is granted.  While 18 months might seem like a long time to a well-funded organization, it takes my organization [fill in the blank – one month to hold a meeting, two months to organize a bake sale, etc.].  This is especially impossible if the applicant is starting at zero because they forgot or lost interest in a LPFM station, which they applied for three years ago in May 2000.  This lack of information is causing a waste of time for applicants, FCC staff, and the spectrum that could be put toward good use. 

Freeze Translators

         There are several things the FCC could do to help LPFM that it has not yet done.  First, it could put an immediate freeze on processing translator applications.  For those of you who don't know, a translator is a radio station that an existing broadcaster gets when he wants to expand its coverage -- to get into a valley that his signal can't reach, for

example.  Translators, or repeaters, run at two-and-a-half times the power of a LPFM, but are otherwise technically identical to a station like KOCZ, except they don’t create original programming.  But technically, they fill similar holes on the FM dial.

Last year the FCC accepted a huge flood of translator applications.  This is a situation in which the FCC was acting in good faith, but did not consider adequately the impact on low power radio.  Virtually all expansion of low power radio will be eliminated if the current pending translator applications are granted.  It is important to analyze the impact of translators, which do not originate new service, on LPFM before moving ahead.  Leave those spaces for the localism you are here to promote.   This is a very serious matter, and the localism task force should ensure that LPFM is not damaged unthinkingly.

Stop Fraud

         By tradition the FCC does not closely examine each application except on technical grounds, it relies on the public to challenge applications that do not comply with the Commission’s rules.  Through the National Lawyers Guild, the legitimate low power radio community has tried, with extremely limited resources, to challenge fraudulent applications.  But there are two problems.  First, despite our efforts, there are applicants on the air with licenses that do not seem to meet the FCC’s criteria.  Second, in many cases our attempts to uncover problems were hampered by limited time and resources, but this does not mean the FCC is free to disregard them.  At a minimum, a few high profile rejections would go a long way to stopping fraudulent applications.

Expand the Service

I'd really like to invite the FCC down to KOCZ.  Now that the FCC is covering the cost of its own travel, the Chairman should allocate its travel more evenly among commercial and noncommercial media.  We can show you the excellent impact on our community that KOCZ is having.  As to competition, you can look up the one other minority-owned station left on the dial in my town, give them a call, and -ask them- if they are losing money because of us!  [NOTE FROM CHERYL: DO WE KNOW THEY SUPPORT KOCZ?  IF SO, WE SHOULD GET THEM TO WRITE A LETTER.]

As you know, Chairman Powell, my station and all LPFM stations cause absolutely no interference with any of the other stations around me.  The FCC’s engineers proved it first, and now Congress has funded a very expensive study which confirms the same thing.  The low power radio community has been waiting for three years for the report Congress directed the FCC to submit.  The FCC should recommend to Congress that it lift the third adjacent channel limitation and allow LPFM to expand into less rural areas.  Let Low Power FM back into cities like San Antonio!

NOTES from PETE TRIDISH on the testimony written by CHERYL LEANZA, which is ABOVE.

hi- this looks good.

i drafted an earlier version of this sentence which is not necessarily accurate- i do not know how many minority owned stations there are in opelousas. probably none... john, you understand the sentiment... i might re-write it as below...

(((As to competition, you can look up the one other minority-owned station
left on the dial in my town, give them a call, and -ask them- if they are
losing money because of us!)))

(forgive my attempt at swamp humor- I'm sure, John, you can come up with
something)!

also, SDF did not raise the money for the station with bake sales. many
groups do, and i think itcould work for John to say something like: "my
group has an established position in our community for 25 years, ever
since we started to support the civil rights movement and co-operative
economic ventures in our town. Even with all our support from our friends
and neighbors, it was still tough for us to build within the alloted 18
months. I can only imagine how hard it might be for a smaller start-up
organization to raise the necessary funds and volunteer assistance in that
short time period. "

good work everyone
pete tridish