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FCC Shares EAS Test Results
During the latest national test of the Emergency Alert System, more than 84% of radio broadcasters successfully received the National Periodic Test alert, and then 82.5% of those retransmitted the code, averaging slightly better than all of the EAS participants combined.
That’s according to initial results of the 2019 Nationwide Test of Emergency Alert System released Dec. 9. This public notice includes “aggregated, anonymized data” derived from the Form Three filings submitted by EAS participants.
This annual test is intended to assess whether the EAS would perform as designed, an increasingly important question as some debate whether the current system is the best way to keep citizens informed in the smartphone age.
[Broadcasters Need to Keep Eye on Latest EAS Updates]A total of 19,607 EAS participants spanning radio and television broadcasters, cable systems, Internet Protocol Television providers, wireline video systems and others reported they received the alert, and 15,986 then retransmitted it. Radio broadcasters make up the majority of EAS participants at 13,940, followed by the 2,717 television broadcasters and the 2,626 cable system providers.
Interesting, the Public Safety and Homeland Security Bureau noted that nearly half of those who reported receiving the alert said that they were monitoring three or more over-the-air sources at the time. Almost 70% of participants who filed Form Three indicated that there were “no complications” in receiving the test, but about 12% said there were issues with the test’s audio quality. Also, nearly 75% indicated there were no complications during the retransmission, although a small minority said they encountered “other” difficulties.
Read the public notice (DA 19-1244) online here.
The post FCC Shares EAS Test Results appeared first on Radio World.
Community Radio Seeks More Engagement
As 2020 approaches, community stations face many vexing yet familiar challenges. Most want to grow their volunteer base as well their audiences/donors, across generations as well as across socio-economic groups, at a time when the role and relevance of radio itself is being challenged or rethought.
Nina SimonNina Simon, author of “The Art of Relevance,” says managers might ask themselves, “How do I get young people to volunteer or listen to my station?” She feels this is the wrong question because it takes the onus off the station.
Instead, she challenges organizations to focus on ways to make a station more welcoming to a plethora of audiences.
The nonprofit that she founded is OF/BY/FOR ALL. It articulates this vision by stating, “Putting up a ‘Welcome’ sign is not enough. To involve people in meaningful, sustainable ways, you can’t just make programs FOR them. You have to involve them in their creation. And that means becoming OF and BY them too.”
Simon, speaking at the Community Media Conference of the National Federation of Community Broadcasters earlier this year, said she has learned that while most people believe their organizations are welcoming to all, they will also say that their current audience doesn’t reflect the diversity of their community.
This is a disconnect with which many community stations grapple.
WHAT IS “INCLUSION”?NFCB CEO Sally Kane has a deep understanding of the community radio landscape and agrees that there’s work to be done.
“Lots of community radio folks say they are ‘inclusive,’ but in fact [their stations] are insider clubs that aren’t seeing or understanding the fullness of their communities. And I think that is perilous,” she said.
“For example, lots of rural stations are actually embedded in a dominant culture that is highly conservative, and [yet] they are more progressive. It’s important for the stations to at least acknowledge that and not pretend that they represent the community as a whole.”
Although it can be challenging for stations to connect with everyone, “community” is obviously the focus of community radio, for both its workforce of volunteers and for its audience of listeners and donors.
“Community radio is, by design, intended to be of, by and for the people,” Simon said. “Especially today, when many community radio stations have been politicized or marginalized into perceived niches, I believe it’s critical and meaningful to recommit to involving everyone.”
[Facebook Needs Community Radio]Kane believes these conversations about engaging with audiences are imperative in the current hyper-connected media landscape.
“The digital space is highly interactive, so a one-way pipeline of delivering content is no longer adequate, and stations need to integrate that into the way they approach communication and content and organizational culture.”
Young people are identified time and again as a vital component of radio’s future; yet many a community radio station has an aging crew of volunteers and minimal involvement by new, young team members.
Simon suggests that stations get specific: “Identify a specific community of young people who you want to involve, whether that be high school band nerds or young professionals starting their first full-time job and looking for creative outlets. Then talk with them about what they are looking for from a volunteer or engagement experience. Base your offerings on their goals and interests, not yours.”
CALLS FROM HOMEWays that community stations are seeking to engage and evolve are reflected by others who participated in that NFCB conference.
WMMT airs “Calls From Home,” promoted here on its website. The station in rural Kentucky works with listeners incarcerated in at least six nearby prisons.WMMT General Manager Elizabeth Sanders says the rural Whitesburg, Ky., station works with its listeners who are incarcerated in at least six nearby prisons. WMMT has for many years communicated with prisoners and their families through its “Calls From Home” and “Restorative Radio” programs and more recently through a Prison Justice Assembly.
Sanders shares letters that the station has received from prisoners. She said WMMT is trying to represent those who are “the most marginalized” and also wants to bring a “multitude of voices” to the airwaves.
Collaborating with organizations that are enmeshed in specific communities is another way that stations are touching new audiences.
Kerry Semrad, general manager of KZUM in Lincoln, Neb., says the station has an innovative Podcast Partner Program that offers podcast training in order to broaden its public affairs programming. Through partnerships, the station was able to work with some of Lincoln’s refugee communities and learned more about how KZUM could address their needs.
As a result, content is being developed in listeners’ native languages. Semrad says the “only way to remain relevant is to learn from each other constantly.”
[Community Broadcaster: Acting on Equity]Similarly, WERU Community Radio in Maine has been increasing the number and depth of partnerships with community organizations in part to help make the station relevant to a broader audience, especially younger listeners.
Development Director Heather Andrews says that through conversations and surveys, the station learned about specific programming needs. As a result, the station is looking more closely at local programming and on-demand and mobile access for listeners. Andrews said that it was critical to “break down barriers” and “change things up” in order to attract new audiences.
As at KZUM, podcasting is an entry point for new participants and listeners at many community radio stations. Station Manager Ursula Ruedenberg of KHOI in Ames, Iowa, said its entry into podcasting was unexpected. In response to the lack of audio production training at the nearby Iowa State University, KHOI created an audio lab in order to work with the school newspaper. Ruedenberg said the program has expanded and now provides training as the required audio production class in the school’s journalism program.
In a moment in history when so many people are racing to get involved with podcasting, KHOI realized that it could provide a needed service while simultaneously engaging with new audiences to spread the word about KHOI. This type of collaboration also has helped to bridge the traditional “town and gown” divide in Ames, by bringing the student and non-student communities together in order to create audio.
The author is co-founder of Radio Survivor and co-chairs the College, Community & Educational Radio Caucus on the Library of Congress’ Radio Preservation Task Force.
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America’s Broadcasters Should Look Like America
FCC Commissioner Geoffrey Starks spoke in November at the Media Institute “Free Speech America” Gala. He addressed issues involving freedom of speech as well as diversity in broadcast ownership and hiring. His text:
THE FIRST AMENDMENTThe need has always been clear: for free men and women to commit to the ideals of liberty and self-determination, they must be well-informed. A free press is the sentinel of our democracy. On this score, perhaps the greatest observer, and the greatest account, is Alexis de Tocqueville in “Democracy in America.” He writes: “The sovereignty of the people and the liberty of the press may therefore be looked upon as correlative institutions; just as the censorship of the press and universal suffrage are two things which are irreconcilably opposed, and which cannot long be retained among the institutions of the same people.”
In our current moment, perhaps more than ever, the need for a robust, independent free press has never been more critical.
Today, there is an overload of information. It can be difficult to discern what is true, what is not; what are facts, and what are not; what is worthy to be called news, and what is not. And just as the promise of the First Amendment supported the free exchange of ideas in the age of typewriters and telegraphs, it continues to do so in today’s era of broadband and network broadcasting. Social media, deep fakes and the barrage of information that comes to each of us through the internet are potent new influences upon our democracy that admonish us to develop new responsive interpretive muscles.
But part of this hearkens back to the era of our nation’s founding. In the 1830s, Tocqueville wrote that “[t]he number of periodical and occasional publications in the United States actually surpasses belief.” The American people have a deeply ingrained urge to seek out and wade through what the Supreme Court has called a “multiplicity of information.”
That’s a good thing because it is essential to our democracy that the American people go through the process of hearing from a wide range of sources, ideologies and viewpoints. The fabric of our shared culture has long understood how to make decisions in the midst of this fog. Democracy is inherently curious and competitive, which is why we often speak of our culture as the product of a marketplace of ideas.
Like all markets, the one of ideas rises and falls upon the quality and depth of information. As they say, “Garbage in, garbage out.” What we need, then, is a press that pursues unvarnished facts and, above all else, truth.
MEDIA DIVERSITYThe rights enshrined in the First Amendment, including freedom of speech and freedom of the press, guide the Federal Communications Commission’s public interest standard, which must inform everything that we do. But the fact that those celebrated words were written into the Bill of Rights does not, in and of itself, guarantee that it will work as intended. The First Amendment is not self-executing. Preserving its guarantees requires the vigilance of regulators, the media, and the public alike.
Ida B. Wells once said: “The people must know before they can act, and there is no educator to compare with the press.” For its part, the FCC has an incredibly important role to play in supporting the First Amendment and preserving the freedoms it affirms.
Namely, the FCC, by statute, is tasked with facilitating greater diversity in our national discourse. As the Supreme Court has stated, when considering the First Amendment, “the widest possible dissemination of information from diverse and antagonistic sources is essential to the welfare of the public.”
Those in the media are both the beneficiaries and the guarantors of our First Amendment rights. They have the power to inform, to educate and to impact the way we view ourselves and the world. Where we strengthen our media, we strengthen our national conversation and reaffirm our freedom of speech at the same time.
The FCC, which governs our communications networks, has a critical role to play in securing and protecting public access to information. One of the many roles the law assigns to the commission is licensing broadcasters to use our public airwaves. In doing so, our controlling statute demands that we distribute these licenses in a way that prevents too many from winding up in the same hands and promotes ownership by women and people of color.
[Starks Criticizes FCC Record on Media Diversity]This is important. The capacity of broadcast media to empower and inform is indisputable, and it is critical that those exercising this power represent all of us, not a mere privileged or anointed few. Eighty-six percent of Americans get their local news from local TV stations, while only 23% get their local news from sources that are exclusively online. And numerous studies suggest that most of the news consumed online is originated by traditional sources, like broadcasters or newspapers.
Of particular concern to me, then, is the persistent lack of diversity in broadcast media ownership, and among its rank and file.
America’s broadcasters should look like America. Ownership sets the tone for a media outlet, and employees manage its day-to-day operations and provide its public face. Given the crucial role our media plays in informing the public, it is critical that it reflect the nation at large, both behind and in front of the camera, and that our local media also be reflective of the local communities it is bound to serve. These institutions should mirror the richness of our population and give expression to its diverse voices.
The need for a greater focus on diversity and inclusion has never been more apparent, and the commission has, largely and over many decades, failed in meeting its statutory goals and obligations in this regard.
This isn’t conjecture or political posturing. It isn’t even an opinion. It is a fact borne out by our data.
The FCC’s numbers on broadcast ownership are collected every two years. The latest dataset was released in 2017. According to our most recent data, there are more than 1,300 full-power television stations licensed across the country, with only 12 owned by African Americans. If you were rounding, that would be closer to zero percent than 1% — and this has been so for a long, long time.
OPPORTUNITYHowever, now we may finally have a chance to get this right.
The FCC has been given a golden opportunity to succeed where it has previously fallen flat. As the Third Circuit Court of Appeals observed in its most recent media ownership decision, Prometheus v. FCC, the commission can and must do better in addressing the impact of its regulatory efforts on the ability of women and people of color to own stations. No longer can it rely on bad data and analysis while ignoring its obligations. The court sent back the FCC’s latest deregulatory efforts and demanded that we get the data and perform the analysis necessary to ensure that we are fully meeting our statutory requirements. [In November, the FCC, led by Chairman Ajit Pai, filed an appeal of the decision vacating the FCC’s media ownership rules. — Ed.]
Beyond ownership, the commission must redouble its Equal Employment Opportunity efforts to ensure that broadcasters are seeking diverse employees. For 15 years, the commission has had an open rulemaking proposing to continue a decades old data collection on the diversity of the broadcast workforce. And for 15 years, while we’ve been stuck in neutral, we’ve elicited zero visibility on whether station management and news teams reflect our communities. We cannot fully engage on this issue when our ability to understand the problem is compromised.
On both counts, when it comes to ownership and employment, there are those that would argue that collecting data or adopting meaningful policies to promote diversity would be unconstitutional. I couldn’t disagree more.
First, collecting and analyzing data is a core function of an expert agency, and having a better understanding of the industries that we regulate is also just common sense.
Second, when it comes to designing programs that would help improve our stagnant and declining ownership numbers, we can target our efforts based on race, ethnicity and gender, so long as we are careful and provide a well-supported reason for doing so. The Third Circuit Court has instructed us to do so. Given the historic problems we’ve had with broadcast diversity, new research like disparity studies identifying past discrimination in licensing, could be critical to both addressing the concerns of the Third Circuit and finally making good policy in this space.
So, we must get this right. We must do better in fulfilling our statutory obligation to promote diversity in broadcasting. And we must support the inclusion of marginalized voices in the national conversation. Only then can we claim to have upheld our responsibilities under our statute and secured the guarantees of First Amendment in the field of broadcasting.
Geoffrey Starks, a Democrat, was nominated by President Trump to the FCC seat formerly held by Mignon Clyburn. He was sworn in in January 2019.
The post America’s Broadcasters Should Look Like America appeared first on Radio World.
Inside the Dec. 4 Issue of Radio World
We are proud to announce the 16th recipient of the Radio World Excellence in Engineering Award. Also: Radio places a bet on gambling; best practices in RF safety; keeping mice out of a transmitter; and Paul Rotella sounds off about the latest attempt in Congress to pass a “performance tax.”
EXCELLENCEHe Sees the Promise in All-Digital AM
Our honoree Dave Kolesar of Hubbard Radio is an innovator and disruptor. Hear about his career and what he sees coming next for AM.
SAFETYStaying Safe Around RF
James O’Neal shares lessons learned at a seminar tailored to assist transmitter/tower workers.
ALSO IN THIS ISSUE:- NABA Urges North American Radio to Look Ahead
- Don’t Let Mice Kill Your Transmitter
- America’s Broadcasters Should Look Like America
The post Inside the Dec. 4 Issue of Radio World appeared first on Radio World.
Are Digital Radio Coverage Maps Useful?
The author is chairman of Digital Radio Mondiale.
A picture is worth a thousand words and a digital radio coverage map might be worth a million dollars or more in business.
Ruxandra ObrejaWe might stress in documents and presentations the undeniable benefits of digital radio: Better audio, extra data, more choice, emergency warning capability and less spectrum. For DRM specifically the list also includes, the capacity to offer improved audio and data for large or local coverage very often using the existing basic infrastructure.
This can be illustrated with audio and can be doubled by screen grabs showing data, like names, colorful pictures of singers and albums, stock exchange values, etc. This is often impressive but not as easily understood as a map.
CORRECT REPRESENTATION
To many of those interested, a big global map showing the progress of one or another digital audio broadcasting standard is unbeatable. It is also immediately understandable and appreciated, especially by regulators, cost-conscious receiver manufacturers, the car industry and even listeners.
Seeing your [digital radio] standard represented by deep (actual transmissions) or faint colors (trials and demos that might lead to rollout or nothing at all) over large swathes of Europe, India, China, the Middle East or Asia, certainly gives confidence and creates the image of unstoppable progress.
But are clever marketers just using these maps as a fictional tool to impress the right audience?
Firstly, several standards claim the same territory on their respective maps. Is China a DRM, a CDR or a DAB country? DRM in shortwave (pumped 80 hours a day) giving actual and huge domestic coverage is the latest digital radio project in China.
So, maybe, the previous DAB broadcasts are no longer of great significance? Is South Africa a DRM or a DAB+ territory? For the time being, neither, since the country has tried or rather is trying both standards but the Pretoria government has not announced a policy. And the decision might go both ways, which would be good for the country, the standards and the maps.
Photo Credit: Radu ObrejaThen, does a short workshop, a much-touted future trial, a feeble transmission on a low-power and unloved transmitter or a favorable meeting at a ministry turn a country into a colored spot on the global map? And how many transmitters and broadcasts and receivers qualify a country as a truly digital radio territory?
BLURRED LINES
The purists might say the only truly undeniable deep color patches on anyone’s map represent the following: DRM in India, DAB in Norway and the United Kingdom (though FM continues to function in the country), and HD Radio in the United States.
And there is also the question of actual coverage. We might say DRM is covering the whole of Western Europe in shortwave but this is mainly for a short time and for the BBC World Service and digital pioneers. We could also say that a DAB transmission in a capital city, sometimes of a small Central European country, does not represent coverage of a whole country.
Is HD Radio really taking hold of Mexico when just some border stations are using the standard? There is no right or wrong answer, just the realization that generalization can often lead to distortion. We might even have to agree with what a famous politician was glossing on the famous saying: “One picture is worth a thousand denials.”
Rather than using the map argument, proponents of the various digital broadcasting systems need to give a true picture of what is really happening, while admitting that true coverage without false extrapolations is important but so is engagement and extending listening time, especially for the younger generation, Generation Z and the Millennials.
Radio is doing well everywhere but the big brands like Disney+ and now Amazon HD Music are muscling in. Streaming is everywhere and soon we’ll see the unthinkable, a Podcast Radio station (announced recently for London) using the radio platform to attract young listeners to a format they know and have grown up with, the podcast, whose roots were in radio in the first place.
PROMOTE THE FACTS
It is against these developments that digital radio needs to hold its own and do much better. Internet is not a threat; it is just an accompaniment. In the U.K., according to Rajar, 23% more audio hours have been consumed in the last four years. But many broadcasters are looking at how audio is being consumed by the younger generation and a more realistic picture of how audio is being enjoyed is shaping their thinking and strategies.
Instead of playing with maps, which become often obsolete and inaccurate the moment they are included in the slide pack, digital radio proponents could show that digital radio can deliver all that’s needed to attract the younger listeners: Better audio and larger coverage (DRM), greener broadcasting, news, emergency warnings, pictures and even podcasts.
Maps are flat and inaccurate, often a blunt instrument used to persuade the industry that there is only one standard or one version of the digital radio world. Digital radio is many-layered and very relevant in all parts of the world, in all countries developed or developing. It is also still gatekeeper-free and protective of the listener’s identity.
So maybe a picture is worth a thousand words but be sure to use only those that illustrate the picture accurately. This way the picture will provide encouragement and good vibes for the future of radio.
The post Are Digital Radio Coverage Maps Useful? appeared first on Radio World.
Initial Allocation for FM Stations from TV Broadcaster Relocation Fund and Report on the Status of the Post-Incentive-Auction Transition, the Reimbursement Program, and the Consumer Education Program
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FCC Seeks Input on Analog Radio as Digital TV Service
The FCC’s Media Bureau is seeking comment on whether analog LPTV stations should be able to continue to program an analog radio service after the deadline to switch to digital.
While full power stations were required to go all digital in 2009, the FCC allowed LPTVs to continue to broadcast in analog until 12 months after the completion of the post-incentive auction repack, currently on track to meet its July 3, 2020 deadline, which means LPTVs would have to make the digital switch by July 3, 2021.
[Read: Is There an Afterlife for “Franken FMs”?]
Some analog LPTVs (operating on Channel 6) use their spectrum to program an ancillary audio service available on the FM dial (87.76 MHz) and want to continue to be able to continue to deliver that analog signal after the mandatory transition to digital.
The commission has sought comment on the issue before, but citing the approaching deadline and “recent developments,” said this month it wanted to refresh the record.
The FCC wants to know if its supplementary service rules mean that the ancillary analog service is OK even after the deadline, and whether, in that case, the FCC could limit the number of such services — say, applying only to existing services — whether such rights could be transferred, or whether, alternatively, an analog service is not consistent with the designation of digital as being for the provision of “advanced television services.”
Finally, if an analog audio service is consistent with that digital mandate, can the FCC subject it to the fee of 5% revenue currently levied on ancillary services.
The FCC is providing commenters 45 days to weigh in, with 30 days for initial comments and another 15 for replies.
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FCC Allocates $17.2 Million to FM Stations Hit by Repack
The FCC is starting to allocate the reimbursement money for FM stations affected by the TV repack, beginning with $17.2 million to be disbursed to 87 radio stations that met its qualifications.
The FM spectrum in the United States was not subject to the television spectrum repacking process; but as we have reported, some FMs with antennas on or near a tower supporting a repacked TV antenna may be affected if, for example, the FM antenna must be moved, temporarily or permanently.
[Read: FCC: The Time to Request Repack Reimbursements Starts Now]
Congress provided $2.75 billion for the Reimbursement Fund, with up to $50 million to reimburse FM radio stations. Now this initial allocation step enables the Media Bureau to start reimbursing FMs that submitted approved invoices.
The commission says it has received 93 submissions from FM stations, of which 87 met the requirements. The FCC said each will receive an email communication describing the results of its review, and that the approved stations may now begin submitting documentation of actual expenses incurred for approval to be drawn down against their allocations. Those stations will upload invoices or receipts and resubmit a reimbursement form using a Media Bureau’s online data system.
The FCC added that it is holding back a percentage of total estimated costs to ensure that eligible entities don’t face an undue financial burden but also with an eye on reducing the likelihood of the FCC having to “claw-back” payments later. “We will monitor closely the drawdown of the fund as well as revisions to initial cost estimates to determine if additional allocations are warranted. It is therefore important that eligible FM stations seeking reimbursement timely submit invoices after incurring costs.”
The FM stations seeking this funding muse certify that they meet the required eligibility criteria and provide documentation or other evidence to support their certification. They also must report estimates of the types and amounts of repack-related costs that they expect to incur, relying on a range of costs set out in an FCC Cost Catalog or on their own estimates or actual expenditures. The FCC then reviews the eligibility and estimate submissions and issues an initial allocation from that $50 million.
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Severe Weather Knocks Down Eagle Tower
When a nearly 40-year-old Nebraska radio tower was felled by ice and high winds in late November, it was immediately clear that KQSK(FM) would require an interim solution to get back on the air, according to the Panhandle Post.
(The Panhandle Post is the online presence for Eagle Communications’ radio stations in the region.)
General Manager Olivia Hasenauer told the Panhandle Post, Eagle Radio now has “a temporary antenna and transmitter for KQSK” in Chadron, Neb., but the broadcaster intends to rebuild the tower at its current site in 2020.
Eagle Radio Chief Engineer Kevin Wagner said this has enabled “the majority population of Dawes County” to hear the country music-formatted station again.
Prior to the incident, the nearly 500-ft tower also provided leased space for National Weather Service’s NOAA weather, as well as other agencies and organizations. Until the permanent solution is constructed, the National Weather Service is attempting coverage with help from sister stations, but NWS’ Bill Mokry also told the Panhandle Post that residents should turn to other sources of weather information for now.
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Failing to Notify FCC of Primary Station Change Proves Costly
It’s important for a licensee to notify the Federal Communications Commission of certain licensing changes. Otherwise it can turn into a costly mistake.
In this case, Carolina Radio Group applied for a construction permit for a translator in Raleigh, N.C. and specified WQDR(FM) as the translator’s primary station. After the Media Bureau granted the permit application and then the license application, a Petition for Reconsideration was filed by Triangle Access Broadcasting who said that not only was there was no technical need for the translator but that the translator was not being operated as authorized. Specifically, Triangle’s said that the CRG translator was broadcasting an unauthorized station.
[Read: FCC to Two AM Licensees: Pay Fees or Nixed Licenses Could Be Next]
In response, CRG said that no “technical need” showing was required and that the translator was currently rebroadcasting the signal of WQDR. However, CRG did not respond to Triangle’s claim that the translator had previously rebroadcast the signal of a different station.
Upon investigation, the Media Bureau found that when the translator commenced operations, it was rebroadcasting WPLW(AM) rather than WQDR. For about a month, CRG’s translator had been broadcasting a station other than its approved station, which is a violation of failure-to-file rules and the unauthorized broadcasting rule book.
The Media Bureau also found that CRG did not properly notify the commission of this change.
As a result, the bureau proposed a forfeiture for CRG of $2,000. Although the commission had the authority to establish a base forfeiture of up to $7,000 (for two violations: failure to file and unauthorized broadcasting) the Media Bureau said a reduced forfeiture was appropriate in this case. “We reach this conclusion based on the fact that CRG’s violations were not prolonged and the fact that CRG has no history of prior offenses,” the bureau said in its ruling.
The Media Bureau also moved to dismiss Triangle’s request that it reconsider the licensing of CRG’s translator. Under FCC rules, a permittee “is entitled to a high degree of protection” and presumption that public interest is being served during the construction permit process — unless circumstances arise that would make operation of the station against the public interest. That’s not the case here, the bureau said.
As a result, the Media Bureau proposed a $2,000 forfeiture for CRG. The licensee has 30 days to pay the full amount or file a written statement explaining why it deserves reduction or cancellation of the forfeiture.
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