April 24, 1998

Secretary of the FCC
FCC
1919 M Street NW
Washington, D. C. 20554
202-418-0300
Reference: RM-9208 & RM-9242
 

We write on behalf of Citicasters, Co. radio stations KEX, KKRZ, KKCW, KEWS, KOPE, and KLOO AM/FM in the state of Oregon. We strongly oppose proposals under consideration by the FCC that would allow low power FM frequencies.

This concept of low power stations with micro-niche programming for minorities, churches, neighborhoods and community groups is well-intentioned, however, this small step would open the door to more problems than it would solve. Allow us to outline briefly our concerns.

Interference from these low powered stations with existing broadcasts could hinder the public safety. The low-powered, not fully- regulated, broadcasters could hinder public safety due to potential interference with aviation, cellular phones and emergency service providers who rely on the radio airwaves. They will also interfere with existing broadcasters. "Legalized pirate" radio will not serve a broader community, but hinder the community already being served.

Existing broadcasters already tremendously serve the greater public. Radio's strength comes from being a mirror of the community. Conservatively, Portland broadcasters alone contribute more than $10 million each year to local causes that match their formats and the needs of their listeners. From programming, on-air time, cash contributions, and coordination of major community events to special activities, both large and small. Through all of these efforts, the local community is well served.

A couple of examples of how our stations make a difference in the community: KEX provides diagnosis, eyeglasses and hearing aids to over 1,200 children each year in the public school system who fall through the cracks. During the past ten years the station has raised in excess of one million dollars and provided over 10 thousand children with eyeglasses or hearing aids. KKRZ produces a Christmas CD from which the proceeds provides over 500 needy individuals with the Christmas they could never afford.

These are two out of hundreds of promotions, fundraisers, and events that touch the community each and every day of the year. Some believe the days of consolidation have effected the broadcaster's commitment to the community. This is untrue. It has only effected the name on the license. Our commitment to providing community-related programming and serving the needs of the community has never been stronger.

Furthermore, if these proposals are adopted, the resulting impact on broadcasters will include:

Permanent amnesty to hundreds of "pirate operators" who have a proven record of arrogant disregard for technical compliance with FCC rules and operating regulations. Creation of a service which will create thousands of new stations without any realistic ability for the FCC to police or regulate these operations. Creation of a category of stations, fully capable of competing with local broadcasters, but with little or no "public interest" obligations otherwise required of conventional broadcast stations. A return to the chaos and calamity imposed on the broadcast industry in the 1980's with the adoption of Docket 80-90, when thousands of new signals flooded the spectrum.

We appreciate this opportunity to express our deep concern about the potential danger of this regulation to our community and our members, whom combined, employ hundreds of people in this market.

Sincerely,
 

Clint Sly
Co Market Manager
 

Ron Saito
Co Market Manager
 

cc: Sen. Ron Wyden
Sen. Gordon Smith