Are there any alternatives to LPFM?

With the closing of the low power FM application window in November 2013, and with no indication that the FCC will open another one, we have compiled a list of alternatives to low power FM broadcasting. The following discussion presents a range of alternatives and options that offer various levels of viability. It is our judgement at Prometheus that none of these are as generally promising as fighting for a reinstatement and expansion of the original LPFM service, however one of them might be appropriate for your group to pursue.

UNLICENSED LEGAL FM

Regardless of popular misconceptions, it is not legal to broadcast on FM at low power, or at any power, without a license from the FCC. It doesn’t matter if you are less than 100 watts or less than 1 watt. That is why the FCC has been trying to institute LPFM – to provide a legitimate license to very low power operations.

The only exception is that you are allowed to broadcast on FM without a license if your transmitter produces about 1/25th of a watt, or 25 milliwatts. This is only enough power to go about 100 feet, under the best conditions.

It is actually not the power but the field strength that the FCC measures. The way the FCC checks for compliance with the law is whether you exceed a measurement of 250 microvolts/meter at 3 meters on a field strength meter, which is a tool that is specifically designed to measure the strength of electromagnetic fields.

The section of the Federal Code of Regulations that regulates legal, unlicensed FM transmissions is Title 47, Part 15. For this reason, legal microbroadcasting is often simply referred to as "Part 15 broadcasting." This rule does allow for some radiotransmission (like the microtransmitters you may use to hook up an mp3 player to a car radio), but it is largely used to regulate and allow wireless microphones and similar remote devices. Because many garage door openers and computers accidentally exceed these limits, through poor design or breakdown of some sort, the fact is that FCC field agents actually spend very little of their time looking for illegal radio operators, but instead, are spending their days tracking down malfunctioning pieces of equipment like this that are inadvertently fouling up the electromagnetic spectrum.

 

UNLICENSED ILLEGAL FM BROADCASTING

If you choose to operate an FM transmitter outside these Part 15 parameters, you would be considered a “pirate” in the eyes of the FCC, and you can face penalties for violating the law. Sometimes a 1 watt station goes unnoticed by local licensed broadcasters, so a complaint is never filed and the FCC never finds out about it.

The Prometheus Radio Project was born out of the microradio movement in the late 1990s and some of the founders of our organization were radio pirates before we began advocating for the FCC to allow legal low power broadcasting. They set up pirate radio stations as an act of civil disobedience because they believed that the broadcast regulations of this country are fundamentally unfair. They ran great community radio stations in defiance of the wealth-based structure of our broadcast system. The FCC eventually confiscated their stations, but announced that they had gotten the message and would create a legalized low power fm radio service.

There is still a movement of unlicensed pirate stations that continue to operate in defiance of the broadcast regulations, which truthfully have only gotten slightly better as a result of LPFM. Morally we are sympathetic to these operations, but as advocates of LPFM we do not assist pirate radio stations. We focus our efforts instead on supporting the stations that are going to be able to become permanent fixtures in their communities, that are able to serve diverse communities because no one needs to worry about having their door busted down for operating without a license.

Free Radio Berkely has numerous resources and information about unlicensed broadcasting, inclluding a legal defense guide, which can be downloaded here.

 

UNLICENSED LEGAL AM

The legal limit for AM broadcasting is 100 milliwatts, with a maximum antenna length of about 10 feet (this is highlighted in Part 15 as well). In our experience with low power AM, the results have been disappointing. Ordinarily, this power is capable of going about 250 feet, but the audio quality becomes very poor after 100 ft. However, there are some professional “type-accepted” transmitters available that claim to reach 1.5 miles (type-accepted transmitters are devices that have gotten approval from the FCC for their design). From our experience, these coverage claims are pretty dubious. Though we haven’t seen every low power AM transmitter out on the market, what we have seen comes nowhere close to that kind of coverage radius.

A note about Part 15 – it does not require that you use a transmitter that has been type-accepted, so it is "legal" to use a homemade transmitter or a kit. But it is probably not that good an idea unless you know enough about the subject to have designed the kit yourself. Part 15 specifies very strict operating parameters. If you are using a kit or a homemade transmitter, an FCC inspector is much more likely to do a very careful inspection, and they will probably find something wrong with it. Generally, the FCC will not scrutinize a type accepted transmitter, because they already know the design will function legally and reliably.

When salespeople describe the range of their products, they often talk about the furthest out anyone has ever heard it. That may not be your practical range. Range generally has much more to do with the type of receiver that you are trying to use. (See the section below “It’s the Reception That Counts- the Range of a Broadcast Signal). Visit this geocities page for more information on legal, unlicensed AM broadcasting.

 

INTERNET RADIO

When the broadcasters try to make a case against low power FM they often say, "why don't these people use internet radio- that is where the future really is." In some ways, they are right. The Internet has a number of advantages over standard broadcast FM.

Internet radio operates in a manner similar to file sharing or other on-line services. The audio programs originate with a producer, who has the equipment to produce music or other programming (like an audio studio or similar set up) which are recorded and stored like any other computer file. The production equipment can be very simple and inexpensive, but must be able to create digital audio files in one form or another.

The programming files are then sent to a computer server somewhere that is connected to the internet. The server must have some specialized software that can read and then send audio over the internet to another computer or distant receiver. When someone calls up or links to the website, the server sends them the audio file. The receiving computer must also have compatible software that will enable the end user to play the files back. Hit the audio player on your screen, and voilá! out comes audio programming!

A major advantage of internet radio is that internet radio is minimally regulated. No government approvals are needed to set up and operate a radio service over the internet. The audio and computer equipment is relatively inexpensive (compared to buying broadcast equipment), and it needs no special location or facility to plug it in and get it going. Plus, there is no limit to the number of internet radio stations that can be set up -- anyone can set up a website and distribute any audio content they like. The only legal issues are licensing agreements with the music companies, which are the same kind of copyright agreements that regular broadcasters are subject to.

But internet radio is not the same as radio broadcasting, and the differences are important. One of the difficulties is bandwidth. To reach a remote computer (the listener), the server where the programming is stored needs to use an on-line connection between itself and the receiver. The capacity (bandwidth) of this connection is more than what is needed for email or text, and it costs more. The program originator pays for the bandwidth to distribute their audio files, and the more bandwidth they use, the more expensive it is. Once you get past a few listeners, you have to pay for a bigger connection and bigger servers. This can get quite expensive rather quickly if you start to reach a large audience.

[Most internet broadcasters would like to have that problem- most internet stations are ultraspecialized and have very small audiences. Often, as a result, these stations are little more than glorified, automated jukeboxes. On the other hand, some of these stations have great programming options that were undreamed of in the old world of FM and AM radio.]

Another problem is accessibility. Radio receivers are so inexpensive they are ubiquitous, so that cost is not a factor in having the right equipment to listen to the free airwaves of a broadcast. Every individual within any signal area has the ability to hear the station for the price of a cheap radio, which is why broadcasting is so cost-effective. Once you have invested in the major cost of a transmitter, a station can reach literally millions of people with minimal ongoing expenses.

But reaching people over the internet means reaching them one at a time, which is much harder. And many people in low income neighborhoods and rural areas can not get broadband. Of those who do use the internet, many use it only for work or email. Except for younger people, the public is not accustomed to using the internet for radio listening, so they need to be encouraged to begin doing so.

The constrictions of interconnection are another barrier. Only a small minority has the broadband connections and powerful computers that are required to make internet radio as easy to listen to as and of comparable quality to FM or AM. Just as the producer pays for wider bandwidth to put their audio onto the internet, the listener needs access to larger bandwidth to receive it, and they pay for it on their end. In many regions, such bandwidth is not available, and even where it is, the cost may be prohibitive for private users. For low-income, elderly or minority populations, access to broadband service may be limited or unavailable, so the potential audience for internet radio plummets further.

Finally, there is the problem of listeners finding your station. Radio broadcast stations can easily use their own airwaves to promote themselves within a local community. Everyone within their station listening area has equal access to their signal, and anyone wanting to listen can find them on the radio dial without a search engine.

But there are no geographic boundaries on the internet for reaching listeners. Making people aware of your station, helping them find it on-line, and successfully competing with thousands of other services, is a major marketing challenge that keeps many audio efforts very small. It is especially difficult if you are trying to serve a particular geographic region or a community with special concerns or needs.

Despite these problems, internet radio is proliferating, and there are thousands of specialized stations being webcast from all corners of the world. It is important for community activists to stake their claim in the internet radio landscape.

Just because “anyone” can put up an internet audio website with a few thousand dollars worth of equipment and bandwidth, that does not mean that this will always be true. The internet is still young- when radio was this young, it was considerably more free than it is today. Internet freedom must be defended by people who are stakeholders in its continued openness. A discussion of the wisdom of the current approach to regulating the internet is beyond the scope of this article, but suffice it to say that there are many potential threats to the current order of things that could end with an internet that is consideraby less free than the one we have today.

Already, companies are figuring out ways of packaging and promoting small portions of the available internet radio. There will likely soon be cheap internet devices that offer just 50 or 100 of the internet stations- those stations of the media giants, who pay to be the most accessible to the public, thus squeezing out the competition from the thousands of others who are only accessible through more cumbersome means. There is also talk of a “fast” and a “slow” internet- allowing greater functionality to those institutions willing to finance the extra infrastructure. An understanding of the coming battles for control of the internet can be well informed by reading up on the history of radio in the 1920s and thirties. Here are two sources that argue about what early radio history can teach us about the future of the internet: Rich Media, Poor Democracy by Robert McChesney and Jesse Walkers’ article criticizing the book.

When you consider creating an online broadcast, think about your reasons for starting a station. If you plan to produce very specialized content, and want to reach interested parties around the world, consider producing podcasts, or starting an internet station. If your aim is more localized, and you plan to create a community-targeted media hub, then traditional radio broadcasting probably serves your needs better.

While we believe there are some issues with internet radio, we believe it can be a valuable resource for many organizations. For this reason we have created a number of resources about broadcasting online. You can see our guide about internet radio here.

 

BUYING A COMMERCIAL FM OR AM LICENSE

Some people have asked about the process for purchasing a commercial radio station. In most instances, buying even a small station is a major investment, but in some locations, purchasing a station might be a viable option.

There are dozens of AM and FM radio stations on the market at any given time, and in many ways, buying one is similar to buying any other type of commercial business or real estate. There are brokers who specialize in broadcast properties, and for anyone interested, we can put you in touch with appropriate legal, technical and fiscal expertise to help you.

Valuations are based on a combination of factors, including frequency and power of the license, transmitter location, existing facilities, operating history, and future earning potential. Commercial radio stations in the largest markets are considered money machines, and they might be valued as high as $50 – $100 million dollars. Even in smaller cities, stations can be valued in the millions, though there are many exceptions. AM stations tend to be cheaper, and often are available for “fire sale” prices because they are not as desirable as FM stations.

But large media corporations are in the process of buying up groups of stations, both AM and FM, in many markets, and often they are willing to pay more than the frequencies are worth in terms of the revenue that they bring in. This drives the cost of stations up, and is beginning to make it difficult for smaller interests to break into the field as owners. When there was a limit on the number of stations any single corporate entity could own, there was a fluid market in licenses that kept the prices relatively low and spread the ownership widely. Now, though, most ownership restrictions have been lifted and a single operator can own hundreds of licenses across the country. Because of this, the era of small-time, ‘mom and pop’ local FM and AM commercial radio stations is virtually over.

In the days of “WKRP in Cincinnati” there might have been some room for a small business to compete, hiring local people and operating a nice little business. Today, most stations are almost fully automated. The owners feed these stations via satellite with generic content, so they pay one dj to record audio files for a hundred stations. They also have cross-marketing advertising schemes, which allow them to sell ads in hundreds of markets across the country. I encourage you to think carefully about your business model before you try to compete with Clear Channel Communications, which owns over 1000 radio stations across the country.

 

STARTING A NEW FULL POWER FM STATION

Commercial FM -- There are still a few opportunities to start new, full power FM stations. Most of the FM dial is assigned for commercial use, and frequencies are either pre-assigned, or allocated when an engineer is able to identify a vacant frequency using the FCC computations for determining interference patterns based on power and antenna height at a specific geographic location (similar to using the FCC’s “LPFM channel finder” tool.)

The FCC fee to file a commercial application is about $3,000, and on top of that, you will need engineering and legal assistance to prepare the application and associated filings. If you are lucky enough to find a frequency and apply for it, there is the added possibility that one or more groups will also file for the same frequency, making you one party among many that are mutually exclusive. Even if you filed first, you will have to invest additional money to resolve the situation. In such a scenario, there is no guarantee that you would be ultimately successful in winning the license.

As you would expect, most empty frequencies are in rural or unpopulated areas where it might not be viable to set up a commercial operation. But it is important to note that a not-for- profit group can apply for a commercial FM or AM frequency, and it does not have to be run as a commercial station. There are a growing number of commercial licenses held by non-profit organizations and run as non-commercial stations, so that there might be a commercial frequency in your area that is no good for a profit-making venture, but would be fine for a community –based radio service.

Non-Commercial FM licenses – The bottom portion of the FM band – from 88.1 – 91.9 FM – is set aside exclusively for noncommercial educational (NCE) use, which means the stations cannot be used for any profit making activity (no commercials) and they must be run by not-for-profit groups. This is why most public radio stations in the US are located at this end of the radio dial.

Just as in the commercial band, though, the NCE band is nearly filled up, and new frequencies are hard to find. But, again, based on your location and the number of other NCE stations in your area, there might be an available space on the dial. The engineering requirements are similar to commercial requirements, but the license applications themselves are much easier to fill out than for a commercial station, and there are no filing fees.

For the past twenty years, it has been very difficult to start non-commercial FM stations. If someone proposed a station on a given frequency in a given location, they had to issue a thirty day public notice. Often, when someone notified the public of their intention to build a station, other groups would put applications in nearby that competed for the same frequency. In order to decide who would get the license, there would be very complex “comparative hearings” where you would have to present all sorts of evidence about why your organization was better to hold the broadcast license, and why your opponents are moral abominations who are not fit to operate a station in the public interest, etc. etc. Then there were appeals, and appeals of appeals. While the process was set up to evaluate the best candidate, it was eventually acknowledged (even by the FCC) that what was really being discovered was who could afford more, fancier lawyers. Sometimes the opponents would buy each other out, and in fact some groups would start competing precisely so that they could be bought out- having no intention of actually starting a station.

Finally, the FCC decided that this set of rules was for the birds. They put a freeze on resolving mutually exclusive applications. This freeze has been in effect for many years now, as they try to figure out a better way. A few months ago, the FCC released the new rules for the system. They are better than they were, but still much more complex than Low Power FM. We can refer you to engineers who know how to go through this pretty complicated process.

The minimum power for a full-service NCE FM radio station is 100 watts. Once you have a construction permit to build the station, be prepared for the cost of purchasing equipment, especially expensive items like a transmitter and antenna, as well as recurring expenses like rent, electricity, and other usual routine and emergency operating costs.

 

BUYING TIME ON A LOCAL STATION

A serious option to consider in lieu of starting a new station is to purchase time on an existing station. While many radio broadcasters adhere to rigid program formats, all of them sell commercial time, and buying time on a station can be relatively inexpensive. At all commercial stations, the more time you purchase, the cheaper the cost becomes.

Buying time gives you complete control of the content, and while you may be limited on when the program will air, you will know the exact broadcast schedule for promotion and outreach. It also can provide the benefits of enabling you to produce a program to advance your cause, without the ongoing demands and costs of supporting a full-time broadcast operation. If you want, you can look for a sponsor or underwriter to help you cover the costs of producing and airing the show. There are some stations that specialize in programming to ethnic or other small audiences, and it is possible to buy large blocks of time on these stations at relatively low cost.

You may also reach out to a local full power or low power noncommercial station to find out what the procedure is to host a show or broadcast public service announcements. You may be able to find representatives of local noncommercial stations on our radio social networking site www.radiospark.org.

 

DOMESTIC SHORTWAVE RADIO

A word should be said here about short wave radio. It is not a local medium – domestic short wave has a national reach. But if there is any interest in developing programs for a greater than local audience, it is extremely inexpensive to buy time on short wave and have your show beamed across the country. One most have a specific shortwave receiver in order to access shortwave radio.

Unlike in Africa, Asia and parts of Europe and South America, short wave listenership in the United States is largely considered a hobby. Most radios in the United States included AM and shortwave, until FM was introduced in 1948. The story we’ve been told is that government officials, concerned about Communist short wave radio progpaganda stations, encouraged manufacturers in the US to take out the short wave tuner and put in an FM tuner, which can only receive local signals. In most countries, people like to listen to shortwave to get a different perspective from their nations’ media. Even in the US, thousands of people tune in to short wave each evening and are regular listeners to a wide range of programs produced at home as well as overseas. For some projects, this might be an appropriate and affordable approach. You can contact stations directly about buying time, or you can read this ehow page about starting your own shortwave station.

 

DIGITAL RADIO

Digital, or HD radio, operates on the same spectrum as analog radio, but transmits its signal digitally rather than through frequency modulation (FM) or amplitude modulation (AM).  Digital stations require special digital receivers, and allows for multiple digital channels to broadcast simultaneously on one frequency.

While there are a complex set of mandates relating to the roll-out of digital television, no similar mandates are currently in place motivating the shift from analogue to digital radio. Technical standards are not in place, and there are virtually no receivers on the market at this point that make it viable as a community service.

Some observers believe that there is a lot of potential in digital technology to solve some of the old problems of scarce bandwidth. From a technical perspective, they are right- the possibilities of a digitized radio system are amazing and could be used to remake the entire face of broadcasting. Unfortunately, the only serious proposal to digitize radio was designed by the very media giants who currently dominate the industry. It was designed not to liberate the FM dial, but to preserve the current business model of radio. The unfortunate reality of the digital radio issue is that unless activists fight very hard, we can plan on a digital future that looks almost identical to the oligopolistic past and present of radio. We advise that you not hold your breath to get one of the new channels that this technology could create.

(For a shallow overview of the technology, see the "How Stuff Works" write-up here. Here at Prometheus, we think that digital radio has more technical and social problems that its proponents admit: see our article on this subject here.)

 

AMATEUR RADIO

Many people ask about Amateur radio. Amateur radio (also called Ham Radio) is not “radio broadcasting produced by amateurs.” It is a set of bands that are set aside for two way communication between people with special transcievers.You are not allowed to broadcast on amateur radio- that means you can not transmit for more that two minutes at a time, and there has to be someone on the other side talking back to you. You can’t play music, or use it for business purposes. The same goes for Citizens Band, or CB radio.