Copyright 2000 Federal News Service, Inc.
Federal News Service
February 17, 2000, Thursday
SECTION: PREPARED TESTIMONY
LENGTH: 3367 words
HEADLINE:
PREPARED TESTIMONY OF KEVIN KLOSE PRESIDENT AND CHIEF EXECUTIVE OFFICER NATIONAL
PUBLIC RADIO
BEFORE THE HOUSE COMMERCE COMMITTEE
TELECOMMUNICATIONS & FINANCE SUBCOMMITTEE
SUBJECT -
LOW POWER FM RADIO
BODY:
SUMMARY OF TESTIMONY OF KEVIN KLOSE PRESIDENT AND CEO NATIONAL PUBLIC
RADIO
Good morning Chairman Tauzin, Congressman Markey and distinguished
Members of the Subcommittee. Thank you for the opportunity to comment on the
Federal Communications Commission's (FCC) decision to implement a new service of
low power FM radio stations. NPR favors, in principle,
diversity of voices and we applaud the intent of the FCC in adopting the recent
Report and Order regarding low power FM to encourage such
diversity. While recognizing that LPFM will never be a viable substitute for the
services provided now to millions of listeners by the public radio community, we
nevertheless believe there can be compatibility between a new LPFM service and
public radio. However, there are three significant unresolved issues that need
to be addressed in order to insure a compatible environment for the benefit of
our listeners. We seek the following actions:
1- Timely creation of a
swift, fair process at the FCC to adjudicate cases of interference, The FCC has
overturned long-standing policy of providing protection on "third adjacent"
frequencies and now will permit LPFM stations to acquire frequencies that may
disrupt radio stations in their extended coverage areas. In addition, the radio
reading services that rely on FM subcarrier channels are much more susceptible
to this kind of interference. Public radio is deeply troubled that the FCC has
chosen to commit to this course without providing a more complete remedy to
radio stations or their audiences if in fact interference does occur. 2-
Protection of translators: Many areas, especially in the West and the Midwest,
depend upon translator stations to receive public radio broadcasts that repeat
full service stations in the heart of the community. In rural and other
under-served areas, with relatively fewer radio and television signals
available, translators have heightened meaning to listeners of public radio.
But, the FCC Order provides secondary and inadequate protection for these
services.
3- Assuring the transition to Digital Audio Broadcasting.
Having both initiated the DAB process and having acknowledged the potential
effect of LPFM on this process, the FCC proceeded with its plan without
analyzing the impact on DAB. We believe it imprudent of the FCC to act on LPFM
without fully understanding the consequences of its actions to DAB or
considering the comments of broadcasters, receiver manufacturers and DAB
proponents.
We are considering appropriate administrative and/or
judicial processes to resolve these issues. NPR and our Member stations also are
prepared to seek an appropriate and timely legislative solution. Millions of
Americans listen to and support public radio. We ask that that support be
honored by a positive response to our presentation of the need for assuring the
compatibility of this powerful, yet fragile public radio space.
***********************
EXECUTIVE SUMMARY
Good morning
Chairman Tauzin, Congressman Markey and distinguished Members of the
Subcommittee. Thank you for inviting me to speak to you on behalf of National
Public Radio (NPR) and the hundreds of public radio stations that air NPR
programming across the country. As you know, NPR is a private, nonprofit
corporation that produces and distributes award-winning programming such as
Morning Edition, All Things Considered, Talk of the Nation, Performance Today,
and Car Talk. NPR is also a membership organization. NPR Member stations are
independent entities, licensed to a variety of non-profit organizations, local
communities, colleges, universities and other institutions. The majority of NPR
Member stations are licensed to educational institutions such as the University
of Houston and The Ohio State University. In addition, a number of states have
established state-wide networks to provide universal access to public radio
service.
Thank you also for the opportunity to comment on the Federal
Communications Commission's (FCC) decision to implement a new service of
low power FM radio (LPFM) stations. At the outset, let me say
firmly that NPR favors, in principle, diversity of voices and access to the
radio space. We applaud the intent of the FCC in adopting the recent Report and
Order (Order) regarding LPFM to encourage such diversity. While recognizing that
LPFM will never be a viable substitute for the services provided now to millions
of listeners by the public radio community, we nevertheless believe there can be
compatibility between a new LPFM service and public radio. LPFM stations can
onlyprovide service to narrow geographic segments of a community since the
largest stations covering 3.5 miles and the smallest stations covering 1 mile.
However, there are three significant unresolved issues that need to be
addressed in order to insure a compatible environment for the benefit of our
listeners. We seek the following actions:
1- Timely creation of a swift,
fair process at the FCC to adjudicate cases of interference. The FCC has
overturned long-standing policy of providing protection on "third adjacent"
frequencies and now will permit LPFM stations to acquire frequencies that may
disrupt radio stations in their extended coverage areas. In addition, the radio
reading services that rely on FM subcarrier channels are much more susceptible
to this kind of interference. We recognize that the FCC has chosen to rely on
its own engineering studies rather than the evidence submitted by NPR, the NAB
and others, and we do not intend to argue that issue in front of the
Subcommittee. However, what is deeply troubling to public radio is that the FCC
has chosen to commit to this course without providing a more complete.remedy to
radio stations or their audiences if in fact interference does occur.
2-
Protection of translators:. Many areas, especially in the West and the Midwest,
depend upon translator stations to receive public radio broadcasts that repeat
full service stations in the heart of the community. In rural and other
under-served areas, with relatively fewer radio and television signals
available, translators have a heightenedmeaning to listeners of public radio.
But, the FCC Order provides secondary and inadequate protection for these
services.
3- Assuring the transition to Digital Audio Broadcasting. The
LPFM decision was announced just four days before comments were due on the FCC
Notice of Proposed Rulemaking on the transition of analog radio stations to
Digital Audio Broadcasting (DAB). Having both initiated the DAB process and
acknowledged the potential effect of LPFM on this process, the FCC proceeded
with its plan without analyzing the impact on DAB. We believe it imprudent of
the FCC to act on LPFM without fully understanding the consequences of its
actions to DAB or considering the comments of broadcasters, receiver
manufacturers and DAB proponents.
We are considering appropriate
administrative and/or judicial processes to resolve these issues. NPR and our
Member stations also are prepared to seek an appropriate and timely legislative
solution. Millions of Americans listen to and support public radio. We ask that
that support be honored by a positive response to our presentation of the need
for assuring the compatibility of this powerful, yet fragile public radio space.
PUBLIC RADIO'S LONG-STANDING SERVICE TO UN-SERVED AND
UNDER-SERVED AUDIENCES
NPR and its Member stations appreciate and value
the public policy objective of fostering a diversity of broadcast voices to
ensure programming that is responsive to local needs and interests. Since its
origins in the first part of this century, public radio haspursued a mission of
producing and disseminating programming to meet the needs of audiences un-served
and under-served by commercial media. In fact, one of public radio's greatest
strengths derives from a proven record of producing high quality public service
broadcasting that both celebrates the individual community and welcomes national
programming. This powerful local-national amalgam has created a broadcast space
greater than the sum of its parts.
NPR's devotion to presenting ideas,
whether news or cultural, engages audiences and enhances the connections between
people in local communities and across the nation. For example:
-
Morning Edition is the premier national/local program on public radio, with 10
million weekly listeners, larger than the Today Show. The program is designed to
encourage local stations' news departments to report on community news and
events by inserting these stories into the national feed.
- All Things
Considered is NPR's award-winning, flagship program. It produced the Lost and
Found Sound series that included the "Quest for Sound," a call to listeners to
send in their home recordings of sounds of the last one hundred years. This is a
prime example of local contact that creates national content.
- Weekend
Al! Things Considered invites listeners to collaborate with novelist Paul Auster
by submitting true stories to be re-worked and read on air as part of The
National Story Project,
- Talk of the Nation is a distinctive news
program providing opportunities for listeners to call into national and
international experts to discuss the issues of the day and the issues behind the
headlines. The show also takes to the road on the last Thursday of each month as
part of a year long series, The Changing Face of America. This series also
allows a studio audience to share local concerns with a national audience and
allowing the national audience to compare and contrast local views with its own.
In addition, local public stations complement and strengthen this
noncommercial. educational service by producing programs particularly relevant
to their communities:
- WABE-FM in Atlanta. Georgia. produces The New
South Radio Drive-ln, drawing together some of Georgia's best talent in theater,
comedy, oral tradition storytelling, and folk music for a live. half-hour show
devoted to a celebration of Georgia's historic culture.
- WCPN-FM in
Cleveland. Ohio. produced a four-month special in collaboration with public
television station WVIZ-TV called Your Land, My Land. This special focused on
urban development and its impact on the citizens of northeast Ohio. WCPN-FM
produced a series of special news reports on all issues surroundingdevelopment,
while WVIZ-TV produced local TV programs. WCPN also hosted call-in programs that
featured local, state and national organizations on all sides of the development
issue.
- WWNO-FM in New Orleans, Louisiana, records and broadcasts 16 or
more concerts of the Louisiana Philharmonic Orchestra and other classical music
concerts each year. In 1997, the station won special recognition at the Big Easy
Awards Tribute to the Classical Arts for its role in the broadcast and promotion
of classical music.
The value of public radio goes beyond its own
broadcasts. Public radio stations are working directly with communities. Some
examples:
- KSMU-FM in Springfield, Missouri, works with fifth grade
students in the Springfield Public School system to produce and edit a monthly
news program about issues and activities at their school. KSMU-FM both
broadcasts and web-casts the program on the station's web site.
-
KPCC-FM in Pasadena, California, works with inner-city kids by sponsoring essay
contests and arranging for students to tour the station. In past years, young
people from Heart of LA Youth (HOLA) have worked with a KPCC-FM and a NPR
reporter to create radio documentaries that aired locally. Similar
collaborations involved African-American students from All Saint's Episcopal
Church in a program called Brothers Making a Difference.As a result, Americans
have come to rely on public radio to provide thought-provoking. in- depth
programming that addresses national, regional and local issues.
THE
SUBSTANTIAL LOCAL, STATE AND FEDERAL SUPPORT FOR PUBLIC RADIO
Consistent
with this public service record, the federal government has a long-standing
policy of promoting the development and expansion of locally oriented public
radio. Congress has made a substantial federal investment through the
Corporation for Public Broadcasting (CPB) to support the basic operations of
public radio and television stations and to foster the production of
programming. Congress has also invested in the construction of public broadcast
facilities through the Public Telecommunications Facilities Program (PTFP) since
1962. Moreover, Congress established the Public Radio Satellite System (PRSS) in
1978, the first of its kind. This nationwide interconnection system is a
lifeline that provides universal access to programming.
Although federal
support is important, the majority of funding comes from local and state
governments and from community sources, including listeners. The fundamental
element underlying the public's support for public radio has been the role of
public radio stations as community resources and as outlets of community
expression. Indeed, the history of public radio has been the evolution of public
radio stations as sources of locally responsive programming. It has accomplished
these important public service objectivesas the result of concerted federal
policies and with the assistance of a substantial investment of resources over
the past half-century.
THE LPFM ORDER
In several important
respects, the Commission's Order accommodated concerns expressed by public
radio. Although NPR appreciates these accommodations and the spirit in which
they were intended, we are deeply concerned that the Order may diminish the
service public radio provides to the American people. As the record
demonstrates, public radio is an invaluable community resource, and it makes
little sense to implement the LPFM plan in such a way as to undercut public
access to public radio.
INTERFERENCE: In eliminating 3rd adjacent
protection for FM radio stations, the FCC has departed from its long-standing
and traditional standard of measuring interference. It has done so despite
substantial evidence presented by NPR, the NAB and others. We recognize that the
FCC may disagree with that evidence, but we believe it to be imprudent for the
Commission to fail to provide an adequate remedy if, in fact, interference does
occur. The consequence of error by the Commission in this technical debate will
fall directly on existing radio services and the communities which long and
faithfully have supported these stations with substantial voluntary financial
support and growing audiences.Full Service Stations: If the Commission is
incorrect in its predictions about the likelihood and severity of interference,
there is no apparent means to remedy or even minimize the harm.
As a
related matter, we request clarification that mutually exclusive applications,
which in many cases have been held up for years, are indeed protected. Public
radio stations are making a substantial financial investment in gaining access
to spectrum in order to expand public service to the American people.
Radio Reading Services: The potential harm also extends to radio reading
services offered by public radio stations across the country to the
visually-impaired and others such as paraplegics whose disability prevents them
from using print media. This service is unique. No other source adequately
satisfies these citizen's needs. Approximately one hundred radio reading
services use public radio stations' sub-carrier channels, which operate closer
to other signals and thus are more likely to engender interference, for
broadcast information and programming to commonly available receivers.
For instance, the radio reading service in Pittsburgh. Pennsylvania.
serves 6.500 people.
24 hours, seven days-a-week with readings
from local newspapers, geographic and ethnic community newspapers such as the
Jewish Chronicle. Pittsburgh Catholic and The Pittsburgh Courier which serves
the African-American community. Moreover. the radio reading service provides
daily grocery and shopping information. In addition, community organizations
such as Lion's Clubs help purchase sub-channel receivers, andWDUQ-FM and its
licensee, Duquesne University, donate engineering assistance and the subcarrier
frequency on which the service is broadcast.
Translator Inputs &
Outputs: Although the Commission required LPFM stations to protect existing
translator/booster facilities, it did not expressly require the protection of
translator/booster input signals. Because translator/booster facilities
operating on nonreserved frequencies must be "fed" by an over-the-air signal,
disruption of the input signal could eliminate the service of that
translator/booster facility as well as every translator/booster facility that
depends on a clear signal to and from the affected facility.
Particularly in more rural areas of the United States, networks of
translator and booster facilities are typically the only means by which public
radio stations can cover large, sparsely populated areas. For example, KUWR-FM
in Laramie, Wyoming, has seven translators that carry the station's signal to
approximately 45,000 people in underserved areas. Similarly. the translators in
Rawlins and Dubois, Wyoming, provide the only public radio service in these
areas.
This problem may also impact other regions of the United States.
For instance, public radio station WKMS-FM in Murray, Kentucky, has translators
in Paducah, Kentucky, and in Paris, Tennessee. These translators bring the only
public radio service to about 43.213 persons. In Southwest Virginia, WVTF-FM is
in the process of constructing a translator in Lynchburg on 89.5. If its input
is not protected, the service it will provide may be entirely negated.
PROTECTING FUTURE TRANSLATORS AND BOOSTERS: While the FCC grand-
fathered existing translator/booster facilities, it required future translator
and booster stations to protect previously authorized LPFM stations. Since there
has been a freeze on translator applications since 1997. this aspect of the LPFM
decision is likely to further undermine the extension of public radio services
to under-served and un-served areas.
In addition, translator and booster
stations are considered a secondary service to full powered stations. As a
result, a translator or booster station that is forced to relocate to
accommodate a new or newly modified full power station will likely have an even
harder time relocating the facility and maintaining service once significant
numbers of LPFM stations have begun operations. If the dislocated translator is
part of a network of such facilities, service may be lost over a wide area.
DIGITAL AUDIO BROADCASTING: The LPFM decision was announced just four
days before comments were due on the FCC's Notice of Proposed Rulemaking
regarding the transition of analog radio stations to digital audio broadcasting
(DAB). Having initiated a proceeding to address the transition of existing full
power radio broadcasters to DAB. and acknowledged the potential impact of LPFM
interference to DAB, the FCC's Order essentially ignores the issue. Given the
uncertainty regarding the transition to DAB, we believe the potential affect of
LPFM stations on full powered stations warrants further analysis.
CONCLUSION
Although public radio supports a multitude of voices
over the nation's airwaves and the general principle of empowering communities
to make their voices heard, we do not believe that it constitutes sound public
policy to implement LPFM in such a way as to interfere with the educational and
community mission of public radio. Our belief in this proposition is only
strengthened by the realization that the LPFM proposal, as currently
constructed, could have the greatest harm on public radio audiences in rural and
traditionally underserved areas, the exact audience who may be in the greatest
need for access to public radio programming. We thus seek an adequate remedy for
existing stations in case of actual interference, greater protection for
translator services in rural and under-served communities, and reevaluation of
the LPFM plan in concert with the ongoing DAB proceeding.
END
LOAD-DATE: February 19, 2000
