Low Power FM (LPFM) Micro Radio Resources Guide

Founded in 1986 to fight for a democratic media system, CDC considers the radio frequency spectrum to be among our country's greatest natural resources. We believe that democracy flourishes when citizens have affordable and unfettered access to the airwaves. We agree with a unanimous Supreme Court which declared in 1969 that "it is the purpose of the First Amendment to preserve an uninhibited marketplace of ideas in which truth will ultimately prevail, rather than to countenance monopolization of the market."

LPFM is part of the 200-year struggle in our country to democratize society by making information accessible to the disenfranchised. Two hundred years ago, only wealthy men could read, publish and vote. Thanks to universal education, access to the printing plant, and universal suffrage, we were blessed with the labor movement, the women's movement, the civil rights movement, the widespread dissemination of scientific knowledge, the control of. In this tradition, by placing broadcast technology in the hands of low and middle income Americans, LPFM can do its part to help Americans secure the full benefits of democracy.

On January 20, 2000, the FCC voted 3-2 to create the LPFM service. The FCC's decision was (finally) a reaffirmation that "the airwaves belong to the people."

This booklet contains a Q&A about LPFM. It is not intended as legal or engineering advice, and you should consult with an attorney and a consulting engineer who are familiar with this process to determine your specific rights and responsibilities with respect to low power FM radio.

We don't expect the LPFM application process to be very expensive. But diligence is key. These may will be the last FM stations available before the band is saturated.

I. THE BASICS OF LOW POWER FM RADIO

1. WHAT IS LOW POWER RADIO (LPFM) SERVICE?

Low power FM radio (LPFM) refers to over a thousand 10 watt or 100 watt stations the FCC expects to license in the coming year and a half. The 10 watt stations will reach a 1-2 mile radius, and the 100 watt stations should reach a radius of at least 3.5 miles. By comparison, full power FM stations usually have between 6,000 to 100,000 watts of power, and broadcast over an 18-60 mile radius. LPFM stations would be located throughout the FM band. Initially, they will be licensed only to local, community-based and nonprofit entities.

2. WHAT CAN WE DO WITH AN LPFM STATION?

LPFM stations will be noncommercial and inexpensive, with signals best suited for narrow casting to neighborhoods or small cities. The potential uses of LPFM are so numerous we can't possibly list them all; they're limited only by the ingenuity of LPFM applicants. Here are a few:

• providing local radio service to small cities, large and small towns, and neighborhoods
• providing information to union members at a large plant o discussing controversial issues
• Presenting music and culture not heard on "top 40" or NPR
• broadcasting in languages not heard on full power stations
• training students or community residents in radio broadcast techniques o providing church services to shut-ins o offering nontraditional formats, such as political talk, poetry, blues, jazz, classical, polka, reggae, soca, hip-hop or old school LPFM is intended to provide an alternative to the often homogeneous, non-controversial, non-local programming that dominates the airwaves today.

3. WHAT CAN'T WE DO WITH AN LPFM STATION?

Make money. These stations will be operated non-commercial; however, unlike full power noncommercial stations, they will be located throughout the FM band. As an LPFM operator, you must meet the FCC's definition of a "noncommercial educational broadcast station." However, you need not be a school; you can be a community organization, a union, a broadcasting club, a civil rights organization, a theater troupe, a tenants association or a church. LPFM is not a "license to print money." LPFMs will be a labor of love for those who love broadcasting and love their communities. If you are blessed with perseverance, drive and time, you can pursue this opportunity.

4. WHY COULDN'T WE JUST STREAM AUDIO OVER THE INTERNET INSTEAD?

You can certainly do that -- in fact, there's no reason you can't put your LPFM station on the net. But bear in mind that 190,000,000 Americans don't have access to the net at home, including most poor people and minorities. Almost no one has access to the net on a walkman, on a bicycle or in an automobile. There will never be a substitute for the immediacy, interactivity, culture and local sensitivity of radio.

Back to the Top

II. THE FCC AND LPFM

5. WHAT IS THE FCC's DECISION CREATING LPFM SERVICE?

It is the January 20, 2000 "Report and Order in the Low Power FM rulemaking docket (MM Docket 99-25), document number FCC 00-19." It's available on the FCC's website, http://www.fcc.gov/. You should download and read this decision.

6. WHAT DOES THE FCC DO?

The Federal Communications Commission, founded in 1934 as the successor to the Federal Radio Commission, is an independent regulatory agency created by the Communications Act of 1934 (substantially amended by the Telecommunications Act of 1996). It regulates the broadcast, cable, telephone, wireless and satellite industries. The FCC is an independent agency. It is run by five commissioners who are nominated by the President and confirmed by the Senate.

The FCC's Mass Media Bureau will administer LPFM service, and its Enforcement Bureau will ensure that LPFM licensees adhere to the FCC's rules.

7. WHERE IS THE FCC?

The FCC is located at 445 12th Street S.W., Washington, D.C. 20554. It has field offices throughout the country; however, these offices' functions are limited to performing technical monitoring. The FCC's website is http://www.fcc.gov/.

8. DO WE NEED AN FCC LICENSE TO OPERATE AN LPFM STATION?

A number of unlicensed broadcasters have operated without FCC licenses, on the theory that the FCC cannot artificially restrict access to the spectrum if new entrants can operate without significantly interfering with stations already on the air. These broadcasters (called "pirates" by incumbents, and sometimes by each other) often provided urgently needed services, such as information in languages not heard on licensed stations. Many "pirates" stayed on the air at great personal risk as an act of civil disobedience. Now that the FCC has authorized some LPFM and thus removed some restrictions on FM spectrum access, the FCC's argument that one must have a license in order to broadcast is more likely to be credited in the courts.

Back to the Top

III. THE TECHNOLOGY OF LPFM

9. WHAT IS "FM"?

FM stands for "frequency modulation" -- meaning that the information (speech, music) encoded in an FM signal takes the form of very slight fluctuations in signal frequency. FM radio began in the United States in 1941; presently, it occupies a band of spectrum running from 88 to 108 megahertz (MHz). The "center frequency" of each FM channel is 200kHz (0.2 MHz) from the next channel. The 100 FM channels have center frequencies from 88.1 MHz through 107.9 MHz. Of these 100 channels, twenty channels (88.1 MHz through 91.9 MHz) are reserved for noncommercial service. The 80 channels from 92.1 MHz through 107.9 MHz accommodate commercial stations and a few noncommercial ones. There are about 12,500 full power AM or FM radio stations, including about 2,000 noncommercial and 5,700 commercial full power FM stations.

10. WHAT ARE THE ADVANTAGES OF FM OVER AM?

FM is relatively free of static. An FM signal received on a reasonably good radio receiver (such as one in a home entertainment system or in an automobile) will deliver sound quality roughly comparable to that of a cassette tape. FM is available almost everywhere in stereo. Unlike AM, FM is interference-free on the same frequency at night. Largely because of FM's superior sound, nearly 80% of radio listening is to FM stations.

11. WILL AN LPFM SIGNAL SOUND LIKE A FULL POWER FM SIGNAL?

Yes. LPFM will broadcast over the FM band using the same type of equipment that other FM stations use, except that the signal will not travel as far. Within the range of the signal, it will sound the same as other FM signals.

12. WHAT ARE THE KEY TECHNICAL PARAMETERS FOR LPFM STATIONS?

An FM station's signal reach is largely determined by its effective radiated power (ERP), expressed in watts and by its Height Above Average Terrain (HAAT), which is the average antenna height over the surrounding terrain for a 2-10 mile radius. There are two classes of LPFM stations: LP-100, which have a maximum ERP of 100 watts and generally will have a maximum HAAT of 30 meters (100 feet); and LP-10, which will have a maximum ERP of 10 watts and generally will also have a maximum HAAT of 30 meters. By comparison, the least powerful of full power FM stations will usually have a maximum ERP of 6,000 watts and a maximum HAAT of 100 meters (328 feet). The most powerful class of full power FM stations have a maximum ERP of 100,000 watts and a maximum HAAT of 600 meters (1,968 feet).

13. HOW FAR CAN AN LPFM STATION BE HEARD?

The coverage of an FM station is defined in terms of "coverage contours" -- imaginary signal boundaries within which the signal strength will equal or exceed a given value. The coverage contour that defines a useable, consistent signal of an LP-100 station will be a circle whose radius extends about 3.5 miles from the antenna (or less if a full power FM station's nearby "translator" or "booster" station must be protected). The coverage contour that defines a useable, consistent signal of an LP-10 station will be a circle whose radius extends about 1-2 miles from the antenna (or less, depending on translators or boosters). By comparison, a 6,000 watt FM station has a useable signal up to about 18 miles from the antenna, and a 100,000 watt station has a useable singal up to about 60 miles from the antenna.

14. WHAT RULES DETERMINE WHERE AN LPFM STATION CAN BE BUILT?

The FCC's "mileage separation" rules are the most important factors determining where a new LPFM station can be built. The mileage separation rules establish how far your antenna must be from the antennas of other FM stations of different classes. You will have to design your application to conform to the rules protecting co-channel stations (those on your same frequency), first adjacent channel stations (those whose center frequencies are 200 MHz above or below yours; e.g., if you are on 105.9 MHz, your first adjacents are 105.7 and 106.1 MHz), and second adjacent channel stations (those whose center frequencies are 400 MHz above or below yours). Full power (but not LPFM) stations are also subject to third adjacent protection rules (governing stations 600 MHz above and below the center frequency).

15. HOW WILL WE KNOW IF AN LPFM STATION CAN BE BUILT IN OUR TOWN?

You must submit an application for a specific site. You must propose a particular frequency and physical location for the antenna. No LP-100 stations are available in many large cities (including New York) because the FM spectrum there is virtually saturated. Only a few LPFM stations can be created in most large cities. The FCC is developing software for its website that will show where licenses might be available. Private engineers are available to do such a study.

You must make the engineering showing necessary to demonstrate that your proposed station will comply with the FCC's rules governing interference with other facilities. Thus, you will need to engage a communications consulting engineer to undertake a "frequency search" in your area to determine where a new station could be located.

16. HOW CAN WE FIND A SITE FOR OUR LPFM ANTENNA?

Nearly all LPFM stations will locate their antennas adjacent to their studios on structures such as office buildings, churches or other buildings that are at least 100 feet tall. Other good tower sites include electric utility poles, water towers, and towers of other FM stations or TV stations. An AM tower will seldom accommodate an FM antenna, but an FM or TV tower will almost always accommodate several FM antennas. If your studio and antenna are not located in the same place, you'll need to apply to the FCC for a Studio to Transmitter Link (STL) microwave license; STL applications are routinely granted.

Before you file your LPFM application, you should have written permission from the site owner to lease or locate space on its structure. You will have to take into account local zoning laws.

Finally, if your antenna will be located near an airport, you may need to engage an aeronautical consultant to be sure your site will conform to Federal Aviation Administration (FAA) rules governing tower height or electromagnetic interference (EMI) with the frequencies used in air navigation, such as those of runway localizers.

Since a bad site can get you disqualified at the FCC, you would be well advised to secure your site through an experienced site acquisition firm, or through a communications consulting engineer. Be sure your site acquisition specialist or engineer breaks down the various technical parameters of your station into lay terms so you can understand them.

Back to the Top

IV. OWNERSHIP OF AN LPFM STATION

17. MUST WE BE LOCAL RESIDENTS TO HOLD AN LPFM LICENSE?

For the first two years of LPFM service, the licensee of an LPFM station must either have its headquarters or campus within 10 miles of the LPFM station's antenna, or 75% of its board members must live within 10 miles of the station's antenna. After two years, non-local entities will be eligible to seek licenses, although the FCC will still prefer local applicants over non-local applicants when choosing licensees.

18. CAN AN INDIVIDUAL OWN AN LPFM STATION?

No. You must form a nonprofit corporation or other nonprofit entity.

19. MUST WE BE TAX EXEMPT?

It is not required by the FCC, that you secure a federal tax exemption (such as those authorized by 26 U.S.C. §501(c)(3)), but it may be helpful, to document your nonprofit status.

20. HOW MANY LPFM STATIONS MAY WE OWN?

For the first two years of the service, an organization may own only one station in a community. During the third year, the FCC will allow an organization to have up to five licenses, and after the fourth year, it may hold ten licenses. At no time may an organization hold licenses within seven miles of one another.

21. CAN A LOCAL AFFILIATE OF A NATIONAL ORGANIZATION APPLY?

Yes. If you are a local affiliate of a national organization, the ownership of other stations by other affiliates of your national organization will not be attributable to you. This means that your national organization can help dozens of its local chapters secure their own LPFM stations -- as long as the control of each of the stations remains firmly in the hands of the local chapter. However, under the FCC's point system for evaluating competing (mutually exclusive) applicants, the extent of your local roots will weigh heavily.

22. MAY A FORMER "PIRATE" BE AN LPFM LICENSEE?

Former radio "pirates" who did not sign off the air when asked to do so by the FCC or after February 26, 1999 (whichever date came first) are not eligible for LPFM licenses under the present rules.

23. MAY A FULL POWER STATION HAVE AN INTEREST IN AN LPFM STATION?

To the FCC's credit, the answer is no. Full power broadcasters may not hold an LPFM license or hold an "attributable interest" in an LPFM station, such as a board membership or an agreement to operate the station. The LPFM station may obtain some help and advice from full power broadcasters.

24. CAN THE OWNER OF AN LPFM STATION LATER SELL THE STATION?

No. If the licensee no longer wishes to run the station, it must turn the license back in to the government. The FCC will then entertain applications from others who wish to broadcast on the station's frequency in its community.

Back to the Top

V. OBTAINING AN LPFM LICENSE

25. WHAT IS OUR BEST STRATEGY FOR APPLYING FOR AN LPFM LICENSE?

Get all the information you can, as soon as you can. Log onto the FCC's website and download the application form, or download it from the CDC's website (http://www.nlgcdc.org/faq.htm#43). Put together a team of people who are ethical, who are willing to work hard, who share your vision and goals, and who together possess the skills and resources needed to build and sustain a radio station. These skills will include programming, fundraising, and management of volunteers and day-to-day operations. Focus on pulling together the right team first -- then think about how to get the license. It doesn't work the other way around.

26. WILL WE NEED ENGINEERING HELP?

If you've read this far, you know the answer. Unless you're a communications consulting engineer, you'll need one to prepare the engineering portion of your application correctly, minimizing the risk that the FCC might consider you technically unqualified to hold a license. You may also need to engage an aeronautical consultant and a site location firm.

27. WILL WE NEED LEGAL HELP?

While it's possible to construct and operate an LPFM station without legal assistance, you'll need this assistance now to successfully navigate the licensing process at the FCC. Here are four reasons you'll need communications counsel:

1. to minimize the risk that the FCC would consider you legally unqualified to hold a license (see Q&A #39)

2. to structure your applicant group and plan your application strategy to enhance the likelihood that the FCC will select you as the superior applicant, and won't select an unqualified or unethical applicant (see Q&A #41)

3. to negotiate share-time, point-pooling agreements with other public-spirited applicants (see Q&A #42 and #43)

4. to make sure you stay current on the FCC's rules after you sign onto the air.

28. HOW DO WE APPLY TO THE FCC FOR AN LPFM LICENSE?

The FCC will open a succession of five-day windows within which it will accept applications for construction permits for new LPFM stations. A "construction permit" authorizes you to build the station at a particular location, frequency and power; after you do build it, the FCC issues you the license, then you start broadcasting. There will be a non-mandatory electronic filing option for the first filing window. Forms will be available on the FCC's website before it opens the first filing window. Forms and directions should be available imminently. As explained below, it's important to be among the first to get this information and among the last to file an application within your window.

29. WHEN IS OUR LPFM APPLICATION DUE?

The first group of states will be able to file at the end of May, 2000. The first windows during which the FCC will accept applications will be for LP-100 stations only. The second windows will be for LP-10 stations. You may not apply before your window opens or after it closes.

30. WHEN SHOULD WE FILE OUR LPFM APPLICATION?

File in the first eligible (LP-100 or LP-10) filing window. The FCC has divided the country into five filing groups. The filing window for California is expected to be approximately the first five days of June, 2000. It may be best to file the application in the final hour of the final day of the filing window. Do it yourself; don't trust this critical task to a friend or relative. Don't file late, or your application will be returned without consideration -- no excuses. Don't file early, because application mills and other unethical characters will copy and use your engineering, or will structure their applications to trump yours comparatively.

Back to the Top

31. WHAT LEGAL FRAMEWORK WILL THE FCC USE TO SELECT LICENSEES?

With over 30,000 LPFM hits on the FCC's website, expect competition. In some communities, there will be several "mutually exclusive" applicants -- meaning that the FCC's grant of one of the applications would make a grant of any of the others impossible under the engineering rules. Thus, the FCC will use a point system to determine (1) which of the applicants is basically qualified to operate, and (2) among those, which is the superior applicant.

32. WHO IS QUALIFIED TO HOLD A BROADCAST LICENSE?

The same basic qualifications requirements that apply to full power stations apply to LPFMs:

• you must be technically (engineering) qualified
• you must be financially qualified
• you must have the "character" to be a public trustee.

33. WHAT ARE THE TECHNICAL QUALIFICATIONS FOR HOLDING A LICENSE?

Your application must include an engineering study that shows that your proposed facility will comply with the FCC's mileage separation and other rules designed to prevent significant inference with other broadcasters. Your proposed antenna site must be suitable and available, and you will have to document that the site owner has agreed to let you use it. If your antenna site is close to an airport, you must not pose what the FAA would consider a hazard to air navigation.

34. HOW WILL THE FCC CHOOSE AMONG QUALIFIED LPFM APPLICANTS?

To select among qualified applicants, the FCC will use a point system with three selection criteria earning one point each (there will be no half-points):

1. Proposed Operating Hours. Applicants pledging to operate at least 12 hours per day will earn one point. The minimum operating hours are five hours per day, except that operation Saturday or Sunday is not required. An LPFM station must be on the air a minimum of 36 hours per week.

2. Local Program Origination. Applicants pledging to originate locally at least eight hours of programming per day will earn one point.

3. Established Community Presence. Applicants with a community presence of at least two years duration will be awarded one point. An applicant can earn this credit by certifying that for two years prior to filing the application, it has been physically headquartered, had a campus, or has had 75% of its board members residing within ten miles of the antenna.

On January 20, 2000, when it created the LPFM service, the FCC stated that its goals were to "create opportunities for new voices on the air waves and to allow local groups, including schools, churches and other community-based organizations, to provide programming responsive to local community needs and interests." As examples, the FCC cited "linguistic and cultural minorities...groups with shared civic or education interests" who are underrepresented. The FCC was most concerned about "bringing additional diversity to radio broadcasting and serving local community needs in a focused manner."

It may seem odd that none of these factors will be used to actually select permitees. But in the FCC's defense, it must be said that using these factors, most of which are subjective, could have led to years of litigation and delayed the initiation of service to the public. The FCC hoped that the accessible, low-cost, noncommercial and localized nature of the LPFM service would draw out a diverse group of applicants -- and time may well prove the if the FCC was correct.

35. WILL THERE BE TIES IN APPLICANTS' COMPARATIVE POINT STANDINGS?

Almost always. Few applicants are likely to expend the time and energy applying for an LPFM permit if they can predict that competing applicants are certain to beat them at the FCC on points. Two of the three points are secured by a mere promise -- a promise to operate 12 hours a day, and a promise to originate locally at least eight hours a day of programming. Hardly anyone will not promise these things. The third point is secured just by being "local" -- and that's almost everyone who'd be interested in serving a neighborhood with a nonprofit radio station. Virtually all applicants will say they are entitled to all three points.

36. WHAT WILL HAPPEN IF THERE IS A TIE IN THE POINT STANDINGS?

The FCC will allow tied applicants to time-share and pool their points together. Thus, if your organization and four others each have three points, your organization and any two of the other organizations could jointly submit a time-sharing agreement, giving all of you a combined total of nine points and clinching the construction permit.

This point-cumulating procedure is intended only as a tie-breaker. Thus, in our example, the FCC will not require the three time-sharing companies to have a combined total of 24 hours of local programs -- or to be on the air a combined total of 36 hours per day.

37. WILL POINT POOLING LEAD TO ABUSES AND GAMING THE SYSTEM?

Take this test: a group of 20 ethically-challenged people decides to apply for a LPFM station. How can they maximize their chances of winning? Stumped? Here's the answer: conspire to form five corporations with four directors apiece and file five applications. If four other applications are filed by honest people, the five conspiring corporations will immediately propose to time-share and will then pool their points. Their combined points will beat out all the other applicants, even if all four of the honest applicants come together to time-share. This is unethical and it ought to be illegal. If past experience is a guide, it will be very common. The only way to ferret it out will be through petitions to deny.

38. HOW WILL THE FCC BREAK A POINT-POOLING TIE?

The FCC will hold a "last resort tie breaker" by dividing the license term into equal parts, and giving each applicant one of the parts. The order of selection will be based on the applicants' length of local residence. At the end of the license term, the license will be turned in to the FCC and new applicants must file for it as though it were spectrum being made available for the first time. As a practical matter, this will probably never happen, unless one applicant is incredibly obstinate or silly, or there are two applicants and they detest each other. Rational applicants will find a way to work together rather than "shooting a hole in the boat" and drowning themselves and their adversaries too.

39. WHAT CAN WE DO IF WE ARE UNFAIRLY DENIED AN LPFM LICENSE?

If you are denied a construction permit in favor of a competitor who covered up the fact that it was really unqualified, or cheated on points, you may file a petition to deny with the FCC. The petition to deny must be filed within 30 days after your competitor is tentatively selected. The petition to deny generally must show that the competitor misrepresented its qualifications (for example, by claiming local residence of board members who really are not local residents). The information an applicant relied on to claim its local residence credit will be available in the FCC's Public Reference Room in Washington, DC.

If the FCC rejects your petition to deny (or if your application was unfairly disqualified and thus not entitled to comparison with other applicants) you can appeal to the U.S. Court of Appeals for the District of Columbia Circuit. The cost of litigating an appeal in the D.C. Circuit starts at about $50,000. All appellate courts give considerable weight to the expertise of specialized agencies; thus, the chance of reversing an FCC decision is uncertain and often remote.

Back to the Top

VI. OPERATING AN LPFM STATION

40. MUST LPFM APPLICANTS KEEP THE PROMISES THEY MADE TO THE FCC?

The FCC says that LPFM stations will be held to their promises, which means the FCC can revoke an LPFM license if the licensee doesn't keep the promises it made in its original application for the construction permit. "Changed circumstances" -- always the defense in the past when promises were broken -- may be unavailable as a defense for LPFMs. Therefore, before you make a promise to the FCC, be sure you can carry it out. Then do it.

41. WHAT THE BIGGEST MISTAKE WE COULD MAKE IN BUILDING THE STATION?

Using equipment that's not certified. The FCC allows broadcasters to use only "certified" equipment for major components, such as transmitters, amplifiers, stereo generators and antennas. Certification is the process the FCC uses to be sure that equipment will not cause a broadcaster to interfere with other stations (e.g. by moving off the frequency or emitting spurious radiation.) Thus, the biggest mistake you can make is to try to save a few hundred dollars by buying a cheap transmitter kit on the overseas market and soldering the parts together in your basement. Congratulations -- you built a radio station all by yourself, and no one will ever hear it. The transmitter will be useless in American broadcasting if (as is likely) the kit, and the transmitter you built from the kit, are not certified.

42. HOW DO WE GET A CALL SIGN?

You'll have 18 months to build the antenna and broadcasting facilities. Then you'll notify the FCC that you're ready to sign onto the air, and you'll get on the FCC's website to select a call sign. Your call sign will be (e.g.) WXXX-LP (east of the Mississippi) or KXXX-LP (west of the Mississippi). It can't be another station's call sign, and it can't resemble another station's call sign without that station's permission. For example, you'll need Disney's permission to use WABC-LP. And it can't look like a word you can't say on the radio (i.e., obscene or indecent).

43. WHAT'S THE KEY TO HAVING A GOOD RELATIONSHIP WITH THE FCC?

Tell the truth and nothing but the truth -- and tell the whole truth. The reason the FCC requires so little paperwork of its licensees is that broadcasters comply voluntarily with the letter and spirit of the rules. So if you're not sure whether a rule applies to you, don't guess: ask your communications attorney.

44. WHAT'S THE MOST IMPORTANT FCC RULE WE'LL HAVE TO OBSERVE?

Check daily to be sure your tower is lit, so airplanes won't crash into it.

45. WHAT OTHER FCC RULES WILL APPLY AFTER WE SIGN ONTO THE AIR?

This part isn't hard at all, and it builds character. You must adhere to these rules, among others:

• Maintain control of the station! As the licensee, you can voluntarily agree to carry a program, but as the licensee you have the right to change your mind. The FCC has to know that control will always rest with the entity to whom it issued the license -- not someone it did not approve, or never heard of, who might not even be qualified to own the station.
• Perform as you promised in the application.
• Keep the station on the air 36 hours a week, at least five hours each day for at least six days a week (you are not required to broadcast Saturday or Sunday).
• Purchase an emergency alert system (EAS) decoder and transmit EAS messages to the public.
• Do not broadcast unidentified "hoaxes" (remember H.G. Wells' "War of the Worlds")
• Restrict "indecent" material (George Carlin's "seven dirty words") to specified hours when children are unlikely to be listening.
• Do not pass off recorded material as live, or misrepresent other types of programming.
• Give anyone personally attacked on the air a fair opportunity to respond.
• Be sure anyone you intend to put on the air has consented first (e.g. someone you telephone before patching them on live). It's common for broadcasters to get fined thousands of dollars for this unseemly invasion of someone's personal privacy.
• Announce your call sign (e.g. "this is WXXX-LP, Rochester, New York") when you sign on and off the air, and every hour in between. Although these rules are not difficult to understand, they often change. You should retain communications counsel to keep you informed.

    Back to the Top