October 13th 2004 

Comments of the Prometheus Radio Project:

Introduction:

The Prometheus Radio Project is a Philadelphia-based national organization that helped to advocate for and implement the Low Power FM Radio Service. We work with hundreds of Low Power FM (LPFM) stations across the United States. We also served as the lead plaintiff in this year's historic suit against the consolidation of media ownership in  this country -- Prometheus vs. the FCC. Our victory in this case put a definitive halt to Bush administration plans aimed at spurring a massive wave of media mergers. Today, over 300 Low Power stations are on the air, and close to a thousand have permits to build. Low Power station licenses are held by schools, churches, community organizations, city governments and others. Prometheus only represents secular radio stations.

The CPB Funding Criteria And Their Unintended Consequences For Emerging Radio

As longtime advocates for community radio in all its forms, Prometheus organizers and allies greatly appreciate that the Corporation for Public Broadcasting (CPB) provides funding to National Public Radio (NPR), and to a variety of full-power public stations. However, most small community stations are not eligible for CPB funding – these stations are made ineligible by funding criteria designed long ago to keep educational, 'hobby-type' stations out of CPB's portfolio.

CPB has traditionally used a number of criteria to favor 'traditional public radio-style' stations over volunteer-driven community stations. For example, for certain types of funding, stations are not eligible for support unless they employ at least five full time staff people. For other funding streams, stations must achieve a certain percentage of a market's listeners in the Arbitron ratings. CPB makes other funds available for 'first-service' stations, or for stations owned and operated by minority groups.

We are fully in support of the preference for minority stations in the community service grants. The provisions that give preference for minority stations are helpful in diversifying the world of public radio, but the existing mechanism misses the opportunities for diversity in community radio. Community stations provide a middle ground between the two types of stations that CPB funds- the predominantly affluent and comfortable world of public radio, and stations such as Radio Bilingue that are entirely minority focused. But community stations are passed over for funding.

Many volunteer driven stations are dramatically more diverse in the audiences they seek to serve than the typical "public" station, public stations which carry mostly nationally based "well-off boomer- oriented" programming. Even if the boards of these community stations are not 50% or more minority, these stations often make much more effort to do locally oriented, diverse programming than many large public stations do. Perhaps it can be argued that the national shows are more valuable because of their larger audiences and high production values. And perhaps support for the minority controlled stations can be said to have more social value than support for community stations that are not completely minority controlled. But we would argue that small volunteer based community stations certainly have significant value to the public, and yet they get close to zero funding from CPB. This funding scheme is out of balance.

What is missing in the CPB funding scheme is funding for small, community based, projects driven by volunteers. "Localism" is one of the strongest tenets underlying our nation's media law, but this cherished value is almost entirely absent from CPB goals. It does not take large amounts of money to encourage this part of the field. In the current context, large established stations and networks are doing well while no money is given to small, start-up innovative radio. National Public Radio recently received the largest one time private gift in history, of $200 million dollars. NPR has proven itself to be a worthy competitor in the marketplace of radio, and receives support from the member stations by way of program fees, underwriting, CPB subsidy and other modes of support. National Public Radio has found its’ niche market of those comfortable enough to make substantive personal donations. NPR and its’ ilk remains worthy of CPB support...but do they at this juncture in history need every available dollar, while emerging LPFMs are ineligible for even a nickel of CPB funding? Numerous low power construction permits are going unbuilt, because these small groups receive no funding of any kind. While the PTFP has started giving some equipment funding, the process is sufficiently complicated that the application is beyond the fiscal sophistication of many start-up LPFMs.

It is well known that many of the national institutions of public radio have cut their training programs over recent years, and that there are relatively few paths for aspiring radio producers today. Many people who are now well established in radio could not "get in the doors" of radio stations today. Community radio of the 1970s was the training ground from which many established producers sprang. Low Power FM can provide entry level opportunities for the many people who want to get involved in radio but can not get enough experience to be seriously considered in the professionalized world of public radio today. A thoughtful, longterm funding strategy for the field would not only give large grants to organizations that have already proven themselves-- it would also include numerous small grants to encourage new entrants, some of whom will eventually become leaders.

Another Set of Criteria is Possible:

We believe it is time to reconsider the policies that aim resources solely at those elements in public radio that are actually quite capable of supporting themselves due to the way they have positioned their format. Many public radio stations have moved away from their missions of serving underserved audiences towards serving audiences that can afford to contribute to pay for the programming that they so enjoy.

In low power radio, there are hundreds of innovative new stations that are being started by small civil society groups. These stations are dramatically local- they do not aspire to run state wide networks. Many are starting small youth radio programs, talk shows, music. They are out there at public hearings, gathering audio on minidisc recorders and pulling together the best local news they can manage in an all volunteer effort. These stations are much closer in their aspirations to the initial mission of CPB than many public radio stations are today.

We'd encourage CPB to divert just a small fraction of the funding it would have given to public radio to help these new stations get off the ground. We propose that the CPB to give out 100 one time grants from $2000-5000 this year to low power stations to see what sorts of innovation are going on in the field. The CPB should also allocate resources to study the new stations and come up with simple criteria by which to judge smaller, non-commercial community stations for small amounts of support ( LPFM and full power). Based on their findings from grant reporting and independent auditing, CPB should consider a larger granting strategy. The applications should be simple- they should not be a barrier to entry for groups with low literacy or for whom English is a second language. These small grants can make the difference between the success and failure of a small grassroots effort at this crucial early stage of their development.

We understand that from a fund manager’s perspective, these small grants are time consuming and staff intensive. It may appear more efficient to find a few outstanding public radio projects and give them lots of money to take the next steps. But we believe that it is the responsibility of CPB to do some of both. We are happy to work with the CPB to develop volunteer peer review panels, simple criteria, and other means to minimize the need to overuse staff resources in distributing small grants to stations. 'Broadcasting" of many small grants can be done in an efficient, responsible way.

Low power stations are, by the definitions in the regulations, non-commercial, and are operated by small non-profits. We support the policies that separate church and state and do not grant CPB funds to stations that are primarily devoted to promoting religion. We also support policies that make sure that CPB funds are going to bonafide organizations with an educational mission. We are happy to help CPB design criteria that can make sure that the most interesting of the new initiatives get funded, and that can measure the success of these stations in invigorating civic participation, educating youth, and serving underserved audiences.

Conclusion:

In conclusion, Prometheus Radio Project believes that in order to keep public support for the Corporation for Public Broadcasting, CPB needs to look beyond the "typical" public radio consumer and support stations that are in an exciting moment of growth and volunteer energy. It will not take much of the resources of CPB to engage this new movement in radio, and a small a mount of money will make a far more dramatic difference in the performance of a small community radio station than it does for one of the typical full power stations that CPB supports. We hope you will not ignore this historic opportunity of hundreds of new community radio licensees in favor of more "public radio as usual."

Attached are URLS for several articles about low power radio stations, and the radio barnraisings that the community radio movement has put together to get these stations on the air. We hope that upon reading them you will get the sense that community radio is being reinvigorated at the grassroots through LPFM. We know about all of the "lessons learned" from some of the veterans of community radio in the seventies (Mixed format stations don't work. Volunteers are more trouble than they are worth, unless they are answering the phone during pledge drive. Community radio stations are ungovernable and unlistenable. People at community stations are just setting up "radio clubs" and are not serious about serving the public). We think that these articles will show you that there has been new thinking and passion injected into community radio that prove that some of those "lessons learned" may not be as universal as some may think, and serious, thoughtful people are giving the ideals of community radio a new effort today.

 Columbia Journalism review Article

http://www.prometheusradio.org/press_churchton.shtml

http://www.prometheusradio.org/pierce_article.shtml

http://www.seacoastonline.com/news/09122004/news/37112.htm

http://www.seacoastonline.com/news/09132004/news/37302.htm

http://www.prometheusradio.org/story_westword_sept03.shtml

For more information, please contact Pete Tridish, Technical Director of the Prometheus Radio Project 215-727-9620, This e-mail address is being protected from spam bots, you need JavaScript enabled to view it