Expand FCC rules to allow more student-operated radio stations
REC considers student-operated college radio to be vitally important to not just provide our next generation with real-world skills but to bring a diverse voice to the student body and the local community surrounding the college.
Over the past decade, we have seen a substantial decline of student-operated over-the-air radio stations, such as KUSF in San Francisco. Many college stations are operating over internet streaming and/or they may be operating a radio station using carrier current AM or over the school's cable TV system.
REC views LPFM as a low cost method for universities and student government to restore over the air broadcasting and hopefully revitalize their broadcasting, journalism and communications programs for the future.
The FCC rules (73.860(b)) allows a university that has a full power radio broadcast station that is not student run to also have a LPFM station that will be managed and operated by students on a day-to-day basis.
The only provision of the rule is that applicants proposing a student operated LPFM station at a university that already has a full power radio station must not be facing competing applications that would be "mutually exclusive" (where the grant of the other applications would cause the stations to interfere with each other).
The overall university exception was put in place by the FCC in September, 2000 by stating that the exception would:
"...promote our goals of maximizing diversity of ownership in a community and providing a medium for new speakers, including students, to gain experience in the broadcast field." (First MO&O at 84)
In justifying making student LPFM applications only proceed if unchallenged, the FCC states:
"We believe this exception properly balances the interests of local groups in acquiring a first broadcast facility and of university licenses that desire to provide a distinct media outlet for students." (First MO&O at 84)
For those of us who have been following the state of college radio, we know how much things have substantially changed since 2000. Also, with the Local Community Radio Act of 2010 and the Auction 83 FM translator processes being put in place, we are seeing a substantial number of openings for new LPFM stations nationwide in urban, suburban and rural areas.
REC feels that the rule (73.860(b)(4)) is outdated and with the substantial number of channels available now, is less of an issue. We also feel that student LPFM applicants should be able to enter into settlement agreements (where they and the competing applicant(s) amend their application to propose an engineering solution that works for everyone) or enter into a time-share agreement (where the student station is on the radio at certain times of the day with the other applicant(s) using the channel at other times).
REC is asking those of you who care about the future of student-run college radio to allow it to have every opportunity possible.
The FCC is currently accepting comments on proposed changes to the LPFM service until May 7, 2012. While the FCC is not specifically proposing to change this rule, they are soliciting comments on the selection process if there are multiple applications for the same channel. We feel that this is an excellent opportunity to support the removal of 73.860(b)(4) and allow student stations a full opportunity for a radio future.
