A national organization for LPFMs? (2018 edition)

Editorial of Michelle Bradley, founder of REC Networks.

I know this topic comes up every year and I would not be surprised if its brought up again at this year's GRC.  Why doesn't LPFM have a national association?  It’s simple, LPFM is an FCC defined radio service for a type of station that has a service contour of 5.6 km and has reduced regulations in an effort to bring more established non-profit organizations that would not otherwise be in broadcasting into the medium. 

Within LPFM, we do have community radio stations where there is a local governance board, community programming, national programming (i.e. Pacifica), etc.  In other words, the type of radio that attracts a majority of the stakeholders who visit the REC website as well as participate in the Facebook groups like LPFM .  We must also take notice that in addition to community radio, we have those who run LPFM stations just to run a station (the so-called "micro broadcasters").  We also have stations operated by government agencies as FM versions of the road signs on 1610 AM, stations operated by city governments and school districts and of course, the faith-based segment which represents more than half of the licensed LPFM stations on the air.   Between the community media (established organizations that were involved in a non-broadcast form of media before LPFM) and cause-based segments (established organizations that had no form of media before LPFM), this accounts for about 30-35% of all LPFM stations.

Now, let's look at the full-power world.  There are many out there who equate the NAB as this powerhouse overlord that represents the overall interests of all full-service commercial stations.   Anything can be further from the truth.  The NAB, in fact, represents mainly the powerhouse owners (iHeart, Beasley, Hubbard, Cumulus, etc.) and not necessarily the smaller group owners.  Recently, I spent some time with the CEO of a group owner of several medium/small market clusters including here in Maryland and Delaware. This group, as well as others like them are not members of NAB and many other of these groups are not because they felt that NAB abandoned them in their policy in favor of the larger corporate owners.

Like LPFM, these small/medium market owners are also not represented by a national organization like NAB.  Look at the recent proceeding, MB Docket 18-184, the notice of inquiry looking at the potential for a new Class C4 and the major change to §73.215.   Without reading the actual petition, you would think this is something that the NAB could have dreamed up. Its not.  Its a "grassroots" campaign between smaller owners to improve field strengths for medium and small market stations.  The original petition (RM-11727) included a change to a full-service rule that in the opinion of many, the FCC misinterpreted to apply to the entire nation, not just the smaller subset of Class A stations.  If you read the comments, you will see that NAB and the "big boys" are against the concepts (in all fairness, REC is against what the FCC had proposed because of the massive potential of short spacing of LPFM stations because of wholesale class upgrades). 

Other organizations that represent subsets of stations within their respective services like National Religious Broadcasters and CBI rarely get into FCC policy.  NRB is more interested in evangelical politics and CBI is focused on supporting their station's every day needs.

In order for an organization to be effective in the policy section, they must have a DC presence. They must be willing to participate in proceedings with a grasp of statute, policy, case law and decorum.  They must be able to make ex-parte presentations with Media Bureau staff and Commissioner staff and know how to properly conduct themselves including providing notices of the presentation. 

There was funding for this back in the days leading up to the enactment of the LCRA.  Prometheus Radio Project did have DC coverage and being in Philly, they had "roadtrip" access to DC.  I currently have "roadtrip" access to DC (I am actually closer to DC than Philly).  

In order to get an organization going, you need members and members need to pay to sustain the organization.  NFCB is such an organization however for many, their $500 minimum annual membership is out of reach.  Some LPFMs that I work with are members of their state broadcaster associations.  Actually, probably with the exception of New Jersey, you will find the state associations to be accommodating.   

When I ask LPFM stations what kind of membership dues they are willing to pay, I get answers around $50 to $100 per year.  Some have equated joining an LPFM organization to joining ARRL or the NRA.   Just to give you some ideas here.  The annual ARRL membership dues is $49 per year and the NRA is $40 per year.  Seeing how I just turned 50, I recently received a solicitation from AARP to join at $16 per year.  In 2015, there were over 700,000 amateur radio operators, the ARRL claims to have over 170,000 members as of 2016.  The Pew Research Center has made a showing that nearly one-third of all Americans own a firearm, that's about 108 million persons (note: there was a later study that suggests that 30% own a firearm).  The NRA claims they have 5 million members, but research by Pew suggests they have 14 million.  AARP has nearly 38 million members.  AARP puts the number of Americans over 50 at 108 million. NAB does not publish their membership count which would include both radio and television.

We all know that the ARRL, NRA and AARP are very powerful organizations and looking at the math, you can see why.

* - These figures are not scientific in any way and are high-ball as they do not take into consideration various membership options such as spousal, family, multi-year, blind or life memberships at a discounted annual rate.  Does not include any funding received through underwriting and conventional fundraising.

Let’s look at LPFM’s numbers.  According to today’s Scoreboard, we currently have 2,176 licensed LPFM stations across all 6 segments.  If every LPFM station was to join a membership organization (including a membership for each of the Colorado TIS stations) and we charged ARRL’s membership dues, that is only $106,624 per year, $8,885 per month.  That is barely enough for a full-time employee with benefits working from home. 

We must also take into consideration the shadow ownership in LPFM, which we must come to terms to the fact that it exists.  Between EWTN, 3ABN, Radio74, GBN, LifeTalk and New Tang Dynasty; that accounts for about 218 stations or about 10% of all LPFMs.  All except the 7 licensed NTD stations are part of the faith-based segment.   That brings the potential number down below 2,000. 

As of March 31, 2016, there were 4,096 licensed FM non-commercial educational broadcast stations according to the FCC’s quarterly station total report.  The National Federation of Community Broadcasters’ 2016 annual report claims to have “nearly 200” member stations.  Like LPFM, NCE is segmented but with fewer segments.  NFCB currently comprises less than 5% of all NCE FM broadcast stations (there are some NFCB members that are LPFMs that would not be in that 4,096 count thus bringing the percentage even lower).  That 5 percent take rate would mean about 108 potential members of an LPFM organization and at ARRL rates, that’s not even enough to pay the electric bill.

Now, if we look at those who are supporting LPFM from a policy perspective, we can see which segments that they are targeting. 

• Prometheus and Common Frequency place a lot of focus on the community broadcaster, the type of station that these groups vigorously fought for in the fight to get the LCRA passed.  Both of these organizations have a lot of interface with LPFM stations and prospective applicant organizations and definitely bring a lot of good insight to the table.
• Dave Solomon (LPFM-AG) sees LPFM policy from the real-world first-hand perspective.  He is one who truly feels the day to day struggles that his and other LPFM stations face, especially where it comes to those stations in the micro-radio segment that do not have the big non-profit seeding them throughout the process resulting in many more “out of pocket” expenses.  LPFM-AG brings an interesting perspective to the table, even if some of what is being proposed can’t be done at this time due to statute or for other reasons.  Its better to bring an idea out into the open and discuss it.  This is what diversity is all about, even if in the end we disagree with the overall idea, it was discussed and considered.
• REC touches stations across both the secular and faith-based communities and sees regulation from an analytical perspective relying on data, case-law and interpretation of statute.  REC is about diversity in access to the airwaves through various broadcast and non-broadcast methods including support of small stations (LPFM, NCE and rural commercial).  REC considers a small AM commercial station just as much “community radio” as an LPFM in Portland, OR.  Like Prometheus and Common Frequency, REC’s advocacy for small radio and other FCC issues pre-dates LPFM.

I do believe there is strength in numbers but strength costs money.  Let’s say that there are about 630 LPFM stations nationwide that are in the Community Media and Cause-Based segments that are not already NFCB members.  Even if only half of those stations joined NFCB, that would double their membership and make them a stronger organization.  That will make them an organization more capable of coming to DC and representing LPFM (as well as non-NPR secular full-service FM).  I know I have spoke highly of NFCB in the past and I have not found any “dealbreakers” on my part to change my opinion of the great work that Sally and Ernesto are doing there. 

I still feel that for community-based LPFM stations, building the strength of NFCB instead of creating a new competitive organization would be in the best interest of the service.  NFCB can also work with the Prometheus, Common Frequencys, LPFM-AGs and RECs of the world to better build a good strong unified policy.  We will always have our differences. Even when REC, Common Frequency and Prometheus were working side by side in 2011 to form the “trifecta” that worked on the handling of Auction 83 translators and developed some of the post-LCRA policy that is a part of today’s rules, we still were not in 100% alignment of issues, but we had significant common ground. 

I know some in community radio have had some past issues with previous leadership at the NFCB.  This has been discussed and I am pretty sure the NFCB leadership hears those concerns and I am more confident that today’s NFCB would be more accommodating to today’s LPFM needs.    At the same time, I would also call on NFCB’s board of directors to figure out a way that we can “meet somewhere around the middle” where it comes to LPFM stations, many of which may not even deal with half of the budget limit for the lowest tier of membership dues.  I understand this can be difficult but anything to help LPFM strengthen their bonds with their community resulting in increased underwriting will help bring their budgets up and make them more able to pay a standard $500 minimum annual membership.  In return, they need assurances that the organization will be there to protect LPFM’s interest before the FCC and Congress. 

Bottom line. People want an organization to represent LPFM stations in a similar way the NAB represents full-service broadcasters.  Well, it already exists.