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September 22, 1999 William Kennard Dear Commissioners: We write to you today not only as members of the music industry, but as concerned citizens. And as citizens, we want to stress a point that seems lost in the daily work in Washington, DC: the Federal Communications Commission does not work for the broadcasting industry. It works for the American public. And it is time for the FCC to show leadership in the Low Power FM Radio proceeding (MM docket 99-25). Throughout the past decade, we have seen an unfortunate trend in radio: huge corporations gobbling up radio stations for the expressed purpose of generating unprecedented profits. Consolidated ownership groups are streamlining decision-making, directing programming at finely defined demographic segments. As a result, the music that is played on the air comes not from love or respect for the art, but rather from a market analysis of how to squeeze more profits from a natural resource. Any music fan knows this is true. Despite specious claims from broadcasters about the "diversity" of commercial radio today, fans of critical genres including classical, jazz, bluegrass, reggae, opera, folk or punk are regularly left out of the programming picture - not to mention the myriad of artists who do not fit into the prescribed formats. While there are still some great examples of stations cutting against the grain, particularly in non-commercial radio, these stations simply cannot do it alone. Imagine television 20 years ago - without cable, without satellite, without choices. This is what consolidation is doing today: according to BIA, the top 25 radio ownership groups generated about 54% of the industry’s estimated 1998 advertising total of $13.8 billion. The three largest ownership groups alone received almost 35% of revenue. In 1998 alone, the industry went from 5,222 unique owners running 10,246 commercial stations to 4,241 owners running 10,636 commercial stations. In an era where consumers demand - and expect - choices, commercial radio broadcasters are aggressively moving in the opposite direction. Currently, there is a proceeding in front of the Federal Communications Commission that could, in a very small way, begin to address this problem. Low Power FM Radio stations will make it possible again to establish and manage stations out of love of music, not love of money. Most if not all of these stations will be non-commercial, and will rely on support of local governments, educational institutions or the community for survival - but because of their low-power nature the operating costs will be much lower than in a traditional full power station. Existing broadcasters say the technology won’t work, or that the Internet will make this all moot. Our response is simple: radio spectrum belongs to the public. Over 95% of Americans listen to radio, while few have access to Internet radio. As citizens, we need to have a say in how our resources are managed. In fact, the Federal Communications Commission is not in the business of protecting industry, it is in the business of doing what is best for citizens. And in this instance, the best interests of citizens and music consumers means ensuring beyond a shadow of a doubt that the FM band is fully maximized. We want to make sure our representatives in Washington understand how important this issue is to us, so we are holding "Left Off The Dial: 10 Days for Low Power FM" - a national concert series featuring performances from artists in dozens of cities from October 14-24. These concerts will illustrate the vast national support for Low Power FM in the music community. They will also serve as a important reminder to the FCC: there is an interest group with greater power than the National Association of Broadcasters. It is the American public. Sincerely, Mark Arm
(musician/poet/entertainer)
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