[NFCB] FW: File Localism Comments by 4-28-08

[al davis]

On Thursday 24 April 2008, Carol Pierson wrote:
> 4. If you have a Main Studio Waiver, what would it mean if
> that went away?

Main studio waivers are a major threat to true community radio, 
and should be granted only in rare situations, but there are 
some circumstances where there is a true need.

I am proposing an alternative approach, the "composite station", 
that I believe meets the true need now met by main studio 
waivers, but does not allow the abuse that is so prevalent now.

In the conference call, the situation was brought up regarding a 
network of stations that cover an area that could not be 
covered effectively otherwise, such as a mountainous region 
with several small population centers.

In this case, there does need to be a way to consolidate, but a 
simple main studio waiver is not the answer.  Main studio 
waivers as we have now often marginalize the community 
being served by the satellite station.  Many of them could 
support a main studio except they are blocked by the bigger 
station serving them.

I propose the concept of a "composite station", where several 
stations are effectively treated as one.  Instead of 
considering their individual coverage areas, consider the 
combined coverage area as a unit.  Then the composite can have a 
single main studio, and most regulations regarding localism can 
treat the composite as a single station.

To qualify as a composite station, the areas being combined must 
be similar in culture and geographically located in a region 
that is thought of as a single region, and have a relatively low 
population.  An urban center outside of the region specifically 
does not qualify as part of a rural composite.

To apply, all stations that want to be members of the composite 
would so indicate on their application, or apply like they do 
for a main studio waiver.  Instead of having one main station, 
several satellites, and several repeaters, all would be 
considered to be members of the composite, as equals.  Adding 
or removing a station would require a single application, but 
would apply to all members of the composite.

As an example, consider the Adirondack region of New York.  It 
is consistent with this proposal to consider Saranac Lake, Lake 
Placid, Tupper Lake, Speculator, Old Forge, Keene, and several 
others to be a single region.  Because of the mountains, each 
needs its own transmitter.  A single main studio at the center 
would meet the local main studio requirement for all of them.  
The local programming requirement would apply to the composite, 
not to each individually.

A main studio in a nearby city such as Albany, Watertown, or 
Plattsburgh would not qualify.  This is important.  The rural 
areas do not identify with the nearby cities.  Sometimes they 
resent the intervention.

Actually, each of those villages in the Adirondack region 
could support its own studio, a single room at a community 
center, but not full time. They would have trouble individually 
meeting a local programming requirement, but as a group they 
could do it easily, and have a "station" that is uniquely 
Adirondack.

To relate to our phone meeting, I see the Colorado caller as 
being in a similar situation.  KVNF's web site specifically 
mentions Paonia, Crawford, Ridgway, Ouray, Lake City, Montrose, 
and Delta.  Large cities in surrounding areas such as Denver 
and Colorado Springs are not part of the group.  This is a 
perfect example of a composite station that needs to be 
protected.  KMUN, also present in the conference call, is 
another good candidate for a composite station.

Another place the composite station concept could apply is in an 
urban situation where it is impossible to find a large opening 
that covers the entire metropolitan area, so they use two 
stations or repeaters.  Like the rural composite, it is a 
region with a distinct single identity and culture.

Comments?