VIA FACSIMILE

April 27, 1998

Federal Communications Commission
Room 222
1919 M Street N.W.
Washington, D.C. 20554

Dear Sir or Madam:

We are writing to you to express our dismay that the FCC is considering enfranchising low power "pirate"  radio broadcasters. Our most worrisome concern is the potential interference that amateur broadcasters may cause to the quality of our stations' signals. Our Company has invested heavily in state of the art equipment  in order to bring our customers, the listeners, unequalled audio quality. Our livelihood depends on the uninterrupted delivery of quality information and entertainment. We not only compete against other radio broadcasters but we compete against other mediums. It is in our interest as well as the interest of our listeners not to jeopardize signal quality.

As broadcasters, we sometimes chafe at FCC restrictions and directives, but nobody can say that the Commission has not brought order to the radio spectrum that benefits everyone. In the 1930's a Los Angeles AM station owned by the Four Square Gospel Church drifted up and down the radio spectrum in search of listeners. We chuckle when we hear this story retold, but until now we never contemplated the effect on the competing Los Angeles broadcasters. The prospect of sharing radio spectrum with amateur broadcasters certainly takes the humor out of this story.

In reading news stories on pirate radio stations, proponents justify low power radio stations by referring to the first amendment right of free speech, recent radio industry consolidation squelching community expression and the lack of programming diversity. We strongly disagree with these assertions. Our stations continually indentify community problems and needs. We air programs by community leaders to discuss problems. Moreover, our stations support beneficial community and minority causes with promotional advertisement and in some instances financial support. At KISN-FM (one of our Salt Lake City stations) we established KISN Cares for Kids, a non-profit trust which raises money and interest in worthy children's causes, i.e., medical bills, children's charitable organizations, etc.

As anyone with some industry knowledge knows, radio industry consolidation is a result of Docket 80-90, which allowed a significant increase in the number of station signals, and resulted in severely damaging the industry. Consolidation permits certain economies of scale, greater access to public capital markets and, generally, a healthier business climate for radio. In addition, radio clusters let group owners offer wider choice of farmats to listeners. Before mavket clusters were allowed, there was an economic necessity to pursue popular formats. Now, group owners can (and do) pursue rnore niche formats than before, delivering greater choice to our listeners.

We ask you to consider all of these issues as you form your opinion on FCC File nos. RM-92O8 and RM-9242.
 

Sincerely,
 

Robert P. Burke

vice President, Corporate Finance

RPB:aeg