LPFM Reply Comments  

• Harold Hallikainen - Argues that should the Commission not find the petitions acceptable, the Commission should institute a rulemaking on its own motion.  The "need for service" should be determined by the market, not by a government study.  Argues that "diversity of voices" is more than "diversity of music formats," and that this diversity is desirable to society, and that this diversity can only be achieved through diversity of ownership.  Recognizes potential for interference with existing stations and suggests use of existing FM translator interference criteria along with setting aside a band for license-free operation.  Recommends use of FCC approved equipment.  Suggests that point of origin of programming on FM translators is not likely to vastly increase FCC workload.  FCC oversight of unlicensed stations (in dedicated band) would be similar to FCC oversight of cordless telephone operators.  Argues that failing to authorize LPFM results in inefficient use of the spectrum, as "gaps" between existing full power stations could be utilized to serve local audiences.  Suggests use of auction of spectrum leases to award licenses.  Suggests ownership limit of one station per licensee.  Recommends against preferences for existing licensees (such as AM or LPTV).  Suggests EAS equipment be required at licensed stations (translators authorized for local origination).
• Scott D. Hicks - In response to comments by NAB, claims that if existing stations were adequately serving their communities, there would not be the interest in LPFM.  While various stations are playing various music formats, the formats tend to be repetitive, rarely introducing new music.
• Arlene C. Kirsch & Hugh L. Gilderson - Requests amnesty for existing unlicensed stations.  One watt is not enough for community stations.  Owners should live within 25 miles of station.  There should only be one station per owner.  LPFM should not be restricted to nonprofit.  LPFM stations should be required to have local content.
• Scott Koskinen - Supports LPFM.  Is tired of "big corporate radio stations who are accountable only to their stockholders and not to the public."  Agrees with Americans for Radio Diversity that 1 watt is insufficient, that owners should live near the stations, that there should be a limit on the number of stations one can own, and that LPFM stations should be required to have local content.  The FCC should respect the first amendment rights of existing unlicensed community broadcasters.
• Ted Langdell Creative Broadcast Services - Supports the LPFM proposals for listed reasons: 1.  It's "doable".  Interference problems can be resolved.  2.  Helps "establish community" and provides advertising opportunities for neighborhood businesses.  3.  Balances the control of broadcasting between large and small owners.  4.  Allows the rich and non-rich to own stations, improving their individual life as well as the community.  5.  Allows communities to recover lost local radio service as existing stations program to larger nearby communities.  6.  Low power stations can be licensed to serve the public interest.  7.  The addition of low power stations will reinvigorate local radio.  Gives details of the Yuba City (California) radio situation.
• Keith Majic - "One watt is not enough for community stations.  Owners should be required to live near their stations.  There should be a limit to the number of stations any one person can own.  These stations should be required to provide local content."
• Robert McCord - "It has become dramatically apparent that a distinctively local radio service is needed."  "During the firestorm [Southern California fires of 1993] the stations from L.A. were here in helicopters, but the coverage was focused on the fire's sensational value rather than the dissemination of critical information the people of Laguna Beach needed."  "We learn nothing in this community on an 'instant' basis."  "... we are too small in the overall scheme to swing ratings for more diligent coverage by these broadcasting monoliths.  Now with the potential advent of Low Power FM the large radio voices are screaming infringement on their territory?"  Diversity is not "diversity of music formats", but rather "diversity of ownership", giving "... Americans the opportunity to the widest possible range of opinions."
• Russ Painter - Supports RM-9242 proposals.  America needs the diversity of voices LPFM would offer and the existing large owners do not provide.  NAB and other industry groups that have filed opposing comments speak to extend their members' exclusive use of the spectrum.  They do not speak for the majority of the population.  Use of second and third adjacent channels by LPFM stations would not cause any more interference than the existing 460 grandfathered short-spaced full-power stations.  In addition, there will be no interference from future IBOC digital broadcasting.  LPFM stations should have coverage comparable to LPTV stations, covering a 15 mile radius.  Supports the proposed three tier power proposal with a maximum of 3,000 watts.  Supports the local residency proposal.
• Joshua C. Pike - Airwaves are currently dominated by large corporations.  These stations lack in diversity and representation of the communities they serve.  It is currently too expensive for most people to start a radio station.  Agrees with Americans for Radio Diversity position that 1 watt for LPFM is insufficient.  Supports ownership limits and local content requirements.  The FCC should grant amnesty to existing pirate broadcasters for their civil disobedience.
• Stewart Port - Supports the establishment of a noncommercial LPFM service as proposed in comments on RM-9208 filed by the National Lawyers Guild's Committee on Democratic Communications.  Those commenting in favor of LPFM are writing for love, while those opposing LPFM are writing for money.  It does not matter if an LPFM service causes financial harm to existing stations.  They were not guaranteed a profit.  Creation of an LPFM service should not be looked upon as "rewarding the pirates."  Instead, "pirates" have broken unjust laws, as has been done throughout history.  It is ironic that as other media become more democratic (especially the "everyone's a publisher" aspect of the Internet), that broadcast ownership has become restricted to the rich.
• Edwin Santos - Expresses support for the establishment of LPFM.  The airwaves belong to "We the people."  Stations are to serve their community's needs and interests.  Having a station license is a great responsibility, and owners are mere stewards.  Those with limited financial resources are precluded from access to radio.  Wonders if the Commission will be able to approve RM-9242 with all the pressure from politicians and big station lawyers.  Radio cannot become a Wall Street commodity.