"Studying" the Implicatons of LPFM's Expansion

As part of the compromises made to pass the Local Community Radio Act through Congress, a provision was inserted which requires the Federal Communications Commission to examine the “economic impact” LPFM stations have on full-power FM stations.
Comments on the proposed ground-rules of the “study” are due to the FCC in a month, and the study itself is supposed to be tendered to Congress early next year.
The FCC must probe two questions: what effects will an LPFM expansion have on the advertising revenue and audience-share of full-power radio stations?
On its face, the “study” is nothing more than a make-work exercise for the FCC, arguably designed to slow down the expansion of the LPFM service. Its primary questions are absurd – and pretty simply answered.
What effect will LPFM stations have on the advertising revenue of full-power radio stations? Little to none. Since LPFM is a purely noncommercial broadcast service, it’s prohibited by law from soliciting commercials as a funding source. The FCC already acknowledges this; that’s half the question right there.
Underwriting and station-sponsored fundraising announcements are allowed, but it’s quite a stretch to legitimately argue that the amount of money those draw from any local community materially affects the revenue-pie of the local radio market.
You can operate an LPFM station for a year on the amount of money a few weeks’ worth of spots would buy you on any commercial radio station. If an LPFM is “taking” money from a commercial broadcaster, it’s hardly enough for them to notice, much less be able to document.
Unless the LPFM station is so awesome and its commercial “competitors” are so sh*tty that audiences mass-defect to the newcomer. Which leads to the next question.
What effect will LPFM stations have on the audience ratings of full-power radio stations? Because LPFM stations are severely restricted in their coverage areas, it’s silly to try and suggest that any diminution of a full-power station’s audience can be directly attributed to a new LPFM outlet. Like the first question, the necessary data simply doesn’t exist from which to build this sand-castle.
Furthermore, why is this even an appropriate question to ask? The addition of extra radio signals in a market increases choice among radio listeners, and some of them may very well drop an incumbent station from their radio presets in favor of the LPFM. That’s the “free market” at work, and the FCC’s all about the “free market” these days. Slam-dunk this question simply by invoking the controlling neoliberal ideology of communications policy more generally.
The irony of it all lies in the fact that these questions were asked and answered in an LPFM “study” Congress forced the FCC complete following the service’s legislative evisceration more than ten years ago. The “MITRE Report,” as it has become known, was much wider-ranging than than what Congress has required this go-round.
Publicly released in 2003, the MITRE Report primarily focused on the potential of LPFM stations to interfere with their full-power neighbors (finding: extremely unrealistic). In fact, it determined that the idea of studying the economic implications of the LPFM service on the larger world of radio broadcasting was superfluous; the subject did not “warrant the additional expense that [it] would entail.”
Eight years later, here we are: politics is the art of the compromise.
In that regard, the LCRA also explicitly states that the FCC’s “study” of these issues does not inhibit the agency’s ability to open filing windows for new LPFM station applications. That hasn’t happened yet, and it’s becoming increasingly difficult for the FCC to justify further delay.
To that end, the Prometheus Radio Project is gearing up for “Radio Summer,” a loose tour of the country designed to teach interested applicants the skills to file for an LPFM station license and how to build and operate one. Having participated in one of the first of these tours back in 2000, I highly recommend it as a fast way to get schooled on the possibilities that lie ahead.
For those less inclined to wait for the FCC, Free Radio Berkeley is hosting a series of four-day Summer Radio Camps during which participants will build their own unlicensed FM transmitters. Either way you slice it, it’s way past due for an expansion of microradio in this country.