The FCC describes the "incubator" program as "an important step in helping to promote ownership diversity in the broadcasting industry.  Such a program would seek to encourage new and diverse broadcast station owners by drawing on the technical expertise and/or financial assitance of existing broadcasters." 

The Incubator Program could provide an ownership rule waiver for a certain class of prospective or existing station owners. For example, in exchange for a defined benefit such as a broadcast ownership rule, an established company could assist a new onwer by providing mangement or technical assistance, loan guarantees, direct financial assistance through loans or equity investments, training or business planning assistance.  In the NPRM, the FCC is seeking comments on defining the entities eligible for participation in the Incubator Program such as new entrants, revenue-based eligible entities, socially and economically disadvantaged businesses and "overcoming disadvantages preference".  The Commission is seeking comments on what kind of activities would qualify for incubation such as the activities already mentioned or other activities such as donating stations to certain organizations or allowing others to sell advertising under an LMA and what benefits should be given to stations that are incubating such as waivers of ownership rules.  

REC can't see how this proposal is going to help female, minority and LGBT-owned entities as well as non-profit organizations and other community-based organizations are going to obtain stations to serve their communities and add diversity to the airwaves in both the local and national perspective.  From what we can see in the NPRM, this proposal is nothing more than a way for large owners to skirt the local ownership rules by running an "incubating" station as a "training ground" which will bring up issues of whether the entities they are "training" are really disinterested (from a financial perspective).  The only true way to bring additional broadcast diversity is to strengthen ownership limits and force the breakup of clusters in favor of more local voices.  In her vociferous dessent, Commissioner Mignon L. Clyburn suggests that this policy would harm localism, diversity and competition.  REC agrees with Commissioner Clyburn.  This is yet another loophole that benefits iHeart and Cumulus and does nothing for the diversity of voices, especially for female, minority and LGBT-owned locally-based entities.  To Clyburn, with this NPRM, the FCC has abdicated its repsonsibility to uphold the core values of localism, competition and diversity in broadcasting and hopes that if passed, it's reversed in the courts.  REC agrees with Clyburn's assessment of this NPRM.  It's a meal ticket to the NAB and big broadcasters in the disguise of a training program.