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It is serious radio. It is not a hobby.  Your organization, as a broadcast licensee has a lot of responsibilities.  Violations of those responsibilities can lead to forfeitures (fines) or other sanctions.

Keeping the FCC in the loop

As a broadcaster, you have the responsibility of not just knowing the rules and regulations, but also keeping up with changes by the FCC that may impact your station.  This includes regularly consulting with the website, visiting once a day at the end of the day or reading the FCC's Daily Digest.  Unlike big broadcasters, you do not have staff attorneys or consultants to do this work for you.  You are just as responsible for keeping up with the FCC for any news or other changes.  REC operates several Facebook groups that provide information to LPFM licensees and permittees to assist on such changes.  But regardless, the ultimate responsibility is on the station licensee.

As a broadcast licensee, LPFM stations are responsible....

  • For every single word uttered over their station.
  • To assure that every announcement made over the air that acknowledges a donation by a for-profit business only identifies that business but does not promote it.
  • To seek permission from the FCC first before changing the station's antenna location, antenna height and channel.
  • To notify the FCC when the station has finished their initial construction as well as all subsequent modifications previously granted by the FCC.
  • To notify the FCC when the station installs a different antenna or changes the feedline the same location and height.
  • To keep the FCC up to date with any changes to the station's mailing address, email address and telephone number.
  • To notify the FCC when the board of directors of the organization changes by over 50 percent from the last time the FCC was notified of the board members.
  • To assure that all board members are of good character, are not denied federal benefits under the US Anti Drug Act and to notify the FCC when any board member is convicted of a felony or any crime against the US government (such as fraud).
  • To assure that at least 80% of your organization's board members are United States citizens.  (There are provisions to allow for a higher amount of alien control, but it is a complicated process that requires approval by the FCC and Homeland Security and requires involvement by an attorney.)
  • To assure that the organization's headquarters or a campus of the organization or 75 percent of the board members reside within 20 miles of the LPFM station (10 miles in the counties that are designated as Nielsen Audio (formerly Arbitron) top-50 metro markets).
  • To seek permission first before transferring the ownership to another organization, not carrying out the transaction until after the FCC approves it and notifying the FCC when the transaction is complete.
  • To operate the station at least 36 hours per week and no less than 5 hours per day and 6 days per week (for schools: except Saturdays and Sundays and for schools, during school holidays and vacation periods), or if in a time share schedule, to adhere to the time share schedule.
  • To notify the FCC when the station is going to be off the air for more than 10 consecutive days.
  • To have the capability to control the transmitter at any time and be able to shut down the station immediately upon notification by the FCC due to interference.
  • To operate a working Emergency Alert System decoder and periodically inspect the logs to assure that it is properly receiving tests from all monitoring assignments..
  • To participate in occasional national tests of the Emergency Alert System through the filing of reports (this normally happens once per year).
  • To file a license renewal application at least 4 months before the expiration date of the license and to carry appropriate public notice messages on the air after filing.
  • To assure that the station is reasonably available for inspection by the FCC and that requests for inspection are not refused.
  • To assure that your organization's nonprofit status with the state is maintained, which includes that any annual reports and/or fees payable to the state are made.
  • To maintain a "political file" to log any requests for airtime by candidates for public office (which LPFM stations cannot sell air time to) and to track candidate appearances for equal time reasons.
  • To maintain a station log that notes technical issues with the station and how they were corrected. 
  • To timely, truthfully and fully answer any correspondence sent to the station by the FCC, such as letters of inquiry.
  • To assure that the station maintains the appropriate licenses to air copyrighted music.

Using proper equipment in a manner authorized by the FCC

To assure public safety and assure that there is no interference to other radio services, including safety of life non-broadcast services, all LPFM stations are responsible...

  • To only use a transmitter that is certified for LPFM use as noted by an "FCC ID" label on the transmitter and not using old "hand-me-down" transmitters or kit built transmitters. Transmitters that are advertised as just "type accepted", "type verified" or "Suppliers Declaration of Conformity" do not cut it. This includes most of the transmitters you may find on Amazon or eBay, especially for a China-based manufacturer. The transmitter must be a model that was tested in a lab and has received a certification. Use only reputable manufacturers.
  • To assure that the power output the transmitter is set at matches the value authorized on the station license and to occasionally check the transmitter to assure it is in compliance.
  • To assure that the station has a certified Emergency Alert System (EAS) decoder that is on the a firmware version recommended by the manufacturer for compliance. 
  • To assure that the EAS decoder is connected to the internet and that it has the most current security certificate installed (those updates come from the manufacturer).
  • To assure that the EAS decoder is monitoring the correct radio stations as per your state's EAS Plan. 
  • To periodically check the EAS logs to assure that all monitoring sources (internet and radio) are properly receiving the weekly and monthly tests and to maintain those logs for at least 2 years.

To assure proper program content on the air

Even though LPFM stations are considered "noncommercial educational" facilities, not all programming has to be educational in nature.  However, there are still rules that must be followed over what can be said on the air.

  • LPFM stations cannot carry commercials.  LPFM stations may receive donations and can acknowledge the underwriter.  Those acknowledge messages may only identify the underwriter (name, address, phone number and a short description of their business) but may not promote the business (such as statements that may be comparative, qualitative or quantitative or to encourage the listener to take action) and such messages must be the station speaking to the listener thanking the business as opposed to the business speaking directly to the listener.
  • LPFM stations cannot sell airtime.  Selling any amount of time on the station, whether it is 30 seconds or several hours or the entire broadcast schedule is not allowed. 
  • DJs and announcers cannot use the radio station for their own personal gain such as promoting their own business, gigs or other performances (this is called "plugola").
  • DJs and announcers cannot receive money or any other consideration (such as concert tickets, T-shirts or even coffee mugs) for playing specific music or promoting specific bands on the radio (this is called "payola").
  • "Paid political advertising" is not permitted, nor is any endorsement for or against any candidate or ballot initiative.
  • The broadcast of telephone conversations are only allowed when all parties have not been notified that the call is being aired on a radio station before putting the call on the air is prohibited.
  • The broadcast of obscene or indecent material is not allowed unless it is done in a manner that is permitted under the "safe harbor" policies. 
  • The LPFM station must be properly identified with the FCC assigned call letters immediately followed by the city that appears on the license at a point nearest to the top of the hour.  LPFM call signs are four letters and has a suffix of "-LP" (such as WABC-LP).  The LP part must be spoken over the air during the top of the hour announcement, but stations do not have to use it during the rest of the hour.  (An example of a "legal ID" at the top of the hour is "WABC-LP New York")
  • The LPFM station must assure that emergency alerts from the EAS decoder are broadcast over the air per the State EAS Plan and that all Required Monthly Tests and National Periodic Test (about once per year) messages are rebroadcast.

This is a lot of responsibility that is expected of LPFM broadcasters.  Violations of these responsibilities can lead to forfeitures (fines) or other sanctions.

If your organization understands these responsibilities as an FCC licensee, let's move forward and review...