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The Road to New LPFM<br />

It seemed an impossible task: Battling<br />

mega-media companies and the FCC in order<br />

to give communities a voice via Low Power FM<br />

radio stations amid the clamor of dollar-driven,<br />

spectrum-grabbing pros. Who would play David<br />

to the broadcast Goliaths? Since we’re talking<br />

myths and legends, why not Prometheus?<br />

Like the Prometheus of legend, who brought<br />

fire to mortals, today’s Prometheus Radio Project,<br />

as indicated by the organization’s logo, seeks<br />

to bring radio (at least LPFM) to mortals (well,<br />

non-commercial broadcasters, anyway).<br />

Begun in 1998 as a small group of Philadelphia-based,<br />

local-radio activists, Prometheus has<br />

had a huge impact on America’s FM band. Thanks<br />

to their relentless efforts battling commercial<br />

broadcast interests and the FCC, in court and<br />

out of court, this small organization managed to<br />

slip a wedge into the microscopic crack between<br />

big-time broadcast lobbyists and the FCC.<br />

Finding a Frequency<br />

To apply for an LPFM license, you must<br />

specify the frequency and location your station<br />

will use. This is more complicated in urban<br />

areas, w<strong>here</strong> the radio dial is more crowded,<br />

and you will likely need to hire an engineer to<br />

produce an exhibit demonstrating the availability<br />

of your channel. Unfortunately, even an engineer<br />

may not be able to find a frequency in some of<br />

the nation’s most crowded markets, such as New<br />

York City and Los Angeles. However, most rural<br />

areas will have many more open frequencies,<br />

and in some cases you can specify the channel<br />

without paying an engineer.<br />

The availability of any given frequency<br />

cannot be guaranteed until the FCC issues its<br />

final set of rules and procedures for LPFM. Still,<br />

t<strong>here</strong> are a few ways to gauge your chances of<br />

finding a frequency in your area. You can do a<br />

quick check for channel availability in your zip<br />

code at http://prometheusradio.org/zipcodecheck.<br />

For a more thorough search, check the<br />

REC Networks LPFM channel search tool at<br />

http://cdbs.recnet.com/lpfm.php.<br />

The results of this search will designate<br />

your proposed location for an antenna as green<br />

if a channel is easily available, red if a channel<br />

is definitely not available, and yellow if one may<br />

be found with an engineer’s help or a second<br />

adjacency waiver. If the REC Networks search<br />

tool cannot find a frequency for you, you can<br />

also employ a radio engineer to perform a study<br />

to look more closely for any open frequencies,<br />

which you’ll need to do in most cases anyway to<br />

produce the engineering study required in your<br />

application. The cost of one of these surveys<br />

varies from $500 to as much as $3,000 for more<br />

complex studies (often in urban areas) that must<br />

navigate interference or geographic obstacles<br />

with directional antennas.<br />

The rules on finding an available frequency<br />

are among the most important and unresolved<br />

issues the FCC must handle before accepting<br />

new applications. Flexible rules, similar to those<br />

already used by translator stations, could allow<br />

thousands of new LPFM stations nationwide.<br />

That wedge was<br />

the Local Community<br />

Radio Act which had<br />

originally been introduced<br />

as legislation<br />

in 2005 and 2007.<br />

The big break came in<br />

October 2009 when the Act was passed out of<br />

the House Subcommittee on Communications,<br />

Technology and the Internet by a 15-1 margin.<br />

One week later it passed the House Energy and<br />

Commerce Committee by a voice vote. Less<br />

than one month after that it was passed by the<br />

Senate Committee on Commerce, Science and<br />

Transportation. And, by December 16, 2009 it<br />

passed the full House by voice vote. But, it would<br />

take another full year to be passed by the full<br />

Senate. The payoff came when the Act was<br />

signed into law, January 7, 2011. -- Ken Reitz<br />

KS4ZR<br />

The most crucial (and likely most contested)<br />

issue has to do with granting LPFM stations<br />

waivers of the FCC’s minimum distance spacing<br />

on the second adjacent frequency.<br />

These waivers would open up the dial by<br />

permitting LPFMs to use frequencies that are<br />

two <strong>click</strong>s away from other stations on the radio<br />

dial, instead of the current requirement of three.<br />

The Local Community Radio Act authorized<br />

second adjacent frequency waivers in cases<br />

w<strong>here</strong> LPFMs are not predicted to cause interference,<br />

but the FCC must decide how and when<br />

such waivers will be granted, and what sort of<br />

showings applicants will need to make in order<br />

to receive a waiver.<br />

A flexible waiver standard would free up<br />

channels in more crowded markets that might<br />

otherwise have no room for community radio.<br />

In many of the larger markets, second adjacency<br />

waivers could double or triple the number of<br />

open channels, giving local groups a much better<br />

chance to get on the air.<br />

Crafting an Application<br />

Though t<strong>here</strong> is no fee for applying for a<br />

noncommercial license, the FCC will only accept<br />

applications when the LPFM filing window<br />

is open. Since the FCC is currently formulating<br />

new rules (and new applications) for LPFMs,<br />

station hopefuls will have to wait for that process<br />

to conclude and new applications to be released.<br />

However, an Internet search of the term<br />

“FCC Form 318” will produce the instructions<br />

form for the old LPFM application, which may<br />

give you a sense of the process. An important<br />

part of the procedure is the point system by<br />

which the FCC selects among multiple applicants<br />

vying for the same channel, whose applications<br />

are considered “mutually exclusive.”<br />

According to this system of “preference<br />

points,” competing applicants could increase<br />

their chances of being awarded a license on the<br />

basis of three possible points: pledging to broadcast<br />

at least 12 hours every day, committing to<br />

broadcast at least eight hours daily of locally<br />

originated programming, and having established<br />

local presence of at least two years.<br />

As a result, if you are still planning to<br />

incorporate as a non-profit or have just recently<br />

registered, you may want to consider supporting<br />

a more established group to serve as the station’s<br />

licensee. Also, keep in mind that these preference<br />

points may change for new LPFM stations.<br />

The FCC has released proposed rules that<br />

suggest placing additional emphasis on local<br />

presence (perhaps increasing the duration from<br />

two years to four). The proposed rules also suggest<br />

placing additional emphasis on localism, by<br />

adding a second point for stations who pledge<br />

to produce local programming or even making<br />

local programming an eligibility requirement.<br />

Building a Station<br />

Even after you’ve submitted your application<br />

and (hopefully) received an LPFM license,<br />

t<strong>here</strong> isn’t much time to celebrate. Once you’ve<br />

obtained your license, you have a lot of equipment<br />

to buy and only 18 months to get your<br />

station on the air. The cost of this shopping<br />

spree can vary widely, based on w<strong>here</strong> you look<br />

for your equipment. Starting a studio with new,<br />

state-of-the-art technology could easily cost over<br />

$50,000. On the other hand, a studio filled with<br />

consumer grade equipment could be built on a<br />

budget of under $10,000.<br />

People from all walks of life in Rockland, Maine, volunteer at WRFR-LP 93.3 and 99.3 MHz<br />

FM, the only local radio station in Knox County. (Credit: Johanna Lindsay)<br />

August 2012 MONITORING TIMES 17

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