Before the FEDERAL COMMU (CATIONS COMMISSIO ' \Vashington, DC 20554
In the Matter or ) ) Broadcast Localism ) MB Docket No. 04-233 )
To: The Secretary Attn.: The Commission
CONSOLIDATED COMMENTS OF 34 LICENSEES AND I'ERMrnEES OI'ERATING 112 STATIONS
A. Wray Filch III Gammon & Grange, P.c. 8280 Greensboro Drive, 7th Floor McLean, Virginia 22102 703-761-5013 TABLE OF CONTENTS
Main Studio Rule . 4
COllllllunity Advisory Boards . 9
Local Programming . 12
Voice Tracking ...... 13
Conclusion . 14 SUMMARY
As seen frolll these comments from 34 diITerent licensees and penniuccs operating over 110 stations, adoption of many of the proposals in the Localism Rulcmakillg will result in less service. Twenty four hour slafling will severely pinch the budgets of already strained budgets resulting in stations ceasing to broadcast in a worst case scenario or at minimum in 11 reduction of hours of operation or reduction in other services such as news. Perhaps ir the additional staffing served a purpose such a sacrifice could bcjustilicd but it doesn't. The llwin studio is no longer the main contact point for stations... the intcmct and phone arc. Therefore the requirement of a main studio in every city of license and additional slaffing would force the expenditure or funds
for minimal or no benefit at a significant cost. Also evident from the comments is that stations do not need advisory boards or additional regulatory burdens...slations recognize that in order to survive in a compelilive marketplace they must provide the type of local service that will aUraet
In the Matter of ) ) Broadcast Localism ) MB Docke. No. 04·233 ) To: The Secretary Attn.: The Commission CONSOLIDATE» COMM~:NTSOF 34 LICENSEES AN» PERMITTEES OPERATING 112 STATIONS Cedar Cove Broadcasting, Inc.; 1 Community Educational Broadcasting, Inc. ("CEB,,);2 Eagle's Ncst Fellowship Chureh;3 Educational Media Foundation of Brazosport, Inc.;4 Gatcway Creative Broadcasting, Inc. ("Gatcway,,);5 Gospcl Music Broadcasting Corporation;6 Great Commission Broadcasting Corporation;7 Greeley Broadcasting Corporation;H Illinois Bible Institute, Inc. ("IBI");'l Illinois Dislrict Counsel of the Asscmblics of OOd;IO JER Licensee, I Licensee of KEZF(FM), SOUlh Greeley, WY, and KMPB(FM), Frisco. CO; and permittee of KEZG(FM), ESlcrbrook, WY. and KMPZ(FM), Salida, CO. 2 Licensee ofKDUV(FM), Visalia, CA. j I'enlliltee of new noncommercial educational 17M station in Ilarrington, DE. 4 Licensee of KYBJ(FM). Lake Jackson, TX. 5 Licensee of KI-IZR(FM), POlOsi, MO, and KI'VR(FM), Bowling Green, MO 6 Licensee of KGSG(FM), Pasco, WA. 7 Licensee of WGCA-FM, Quincy, IL; and pcrmittee of ncw nOllcollllllerciul educatiOlllll FM station in Kirksville. MO. g Licensee of KFVR-FM, 1..<1 Junta, CO; KGRE(AM), Greeley, CO; and KLMI(FM), Rock River. WY. 'I Licensee of WBGL(FM), Champaign, IL; WUMV(FM), MOllnt Vernon, IL; WCIC(FM), Pekin, IL; WCRT-FM, Terre Haute, IN; WIBI(FM), Carlinville. IL; WNLD(FM), Decatur, IL; WI'RC(FM), Princeton, IL; WSCT(FM), Springfield, II.; WTSG(FM), Carlinville, II.; WVNI.(FM), Vandalia, II.; and WZGI.(FM), Charleston. IL. LLC;11 JKJ Educational Foundation;12 Kimball Radio, LLC;1J KSBJ Educational Foundation ("KSBJ");14 KZLZ, LLC;IS Laramie Mountain Broadcasting, LLC;16 Logos Broadcasting Corporation ("Logos"); 17 Lufkin Educalional Broadcasting Foundation ("LEBF"); 18 Michael Radio Group; 1'1 Montrose Broadcasting Corporation ("Monlrosc,,);20 Ocean Side Broadcasting, Inc.;21 Pan American Broadcasting Company, Inc.;22 Radio Training Nctwork, Inc. ("RTN,,);23 Riverview Baptist Christian Schools ("Rivcrview,,);24 Sebago Broadcasting Company, LLC 10 Licenscc of WCFL(FM), Morris, 1L. II I\:rmith.:e ofncw FM stations in Newell, SOUlh Dakota; Lcnkcy, TX: and Rosholt, WI. 12 Pcmlillee ofncw noncommercial cducational FM station in Colonial Heights. VI\. 13 Licensee ofKIMI3(AM), Kimball. NE, and KYOY(FM), Kimball, NE. I~ Lieensec of KSI3J(FM), IJumble, TX, and KZBJ(FM), Bay City, TX; and permittec of KBEX(FM), Brenham, TX. 15 Licensee ofKIIIL(AM), Willcox, AZ; KWCX-FM, Willcox, AZ; and KZLZ(FM), Kcarny, AZ. 16 Licensee of KFMI I(FM), Belle Fourche, SD; KRGQ(FM), Yuma, CO; and KUSZ(FM), Laramie, WY. 17 Pemlitlee ofKLFF-FM, San Luis Obispo, Ci\.. 18 Licensee of KAVX(FM). Lufkin, TX, and KWSI'(FM), Lufkin, TX; and pennillee of new nonCOlllmercial educational FM st'ltions in Many, LI\, and Buffalo, TX. 19 Liccnsee ofKGRK(FM), Glenrock, WY. and KRK1(FM), Newcastle, WY. 20 Licensee of WBGM(FM), New Bcrlin, PA; WI'EL(AM), Montrosc, PA; WPEL-FM, Montrosc, PA; WI'GM(AM), Danville, I'A; and WPGM-FM, Danville, Pi\.. 21 I'crmiuce ofKEZII(FM), J~lk Mountain. WY, and t1CW noncommcrcial FM stations in Minooka, IL, and Kimball, NE. 22 Licensce of KDAZ(FM), Albuquerque, NM. 23 Licensee of KWND(FM), Springficld, MO: WI\FJ(FM), Belvedere, SC; WI\QV(FM), Cryslal River, FL; WCCE(FM), Buies Creek. NC; WI11J(FM), Ocala, FL; WIZB(FM), Abbeville, AL; WJFH(FM), Sebring, FL; WJlS(FM), Bradenton, FL: WJLF(FM), Gainesville, FL; WLFJ-FM, Greenville, SC; WLFS(FM), Port Wentworth, GI\; WLI'J(FM), New Port Richey, FL; WMBJ{FM). Murrells Inlet, SC; and WRTP{FM), Roanoke Rapids, NC; and pennitlce ofllcw FM station in Wadlcy, Gft., and new Iloncollullercial cducatiot1'l1 FM st'ltion in Frostproof, FL. 24 Liccnsec ofKOLU(FM), Pasco, WA. 2 ("Sebago,,);25 Side By Side, Inc.;26 Son Broadcasting, Inc.;27 Behnax Broadcasting, LLC;2~ Todd Robinson, Inc.;29 Tomlinson-Leis Communications, L.P. ("TLC,,);30 United States CP, LLC;31 Youngers Colorado Broadcasting LLC;32 WA Y-I~'M Media Group, Inc.;3J and WVJT, LLC. 34 lt (collectively "Commentcrs ) jointly lilc these Comments in response to the Commission's Report 011 Broadcast Localism and Notice o.f'Proposcd Rulcl1laking, 23 FCC Rcd 1324 (released January 24,2008) ("NOPR"). In its NOPR, the Commission seeks COmments on a variety of aspects of broadcast localism including thc main studio rule, starling, community advisory boards, locally produced programming, and voice tracking. Commenlers respectfully submit the following comments on these topics. 2S Licensee ofWCTG(FM), Chincoteague. VA. 26 Licensee of WYSA(FM), Wauseon, 01 I; WYSM(FM). Lima, 011; and WYSZ(FM), Maumee, OIl. 27 Licensce of KCHF(TV), Sama Fe. NM. 28 Liccnscc of KYNM-LP, Albuquerque, NM. 2') Licensee of KTKE(FM), Tnlekee, CA, and KZlD(FM), Orofino, lD. JO Licellsee of KNET(AM), Palestine, TX, and KYYK(FM), Palestine, TX. Jj Licensee of KRYE(f"M), Rye, CO; and permillee ofK.XCL(FM), Westcliffe, CO. 32 Penllittce ofKEZZ(FM), Waldcn, CO, and KJ'CR(FM), Burlington, CO. H Licensee of KBW A(FM), Brush, CO; KJWA(FM), Trinidad, CO; KR WA(FM), Rye, CO; KWYA(FM), Astoria, OR; KWYQ(FM), I....ongview, WA; KXWA(FM), Lovcland, CO; KYWA(FM), Wichita, KS; WAYD(FM), Aubum, KY; \VA YF(FM), West Palm Bcach, FI.; WAYl-I(FM), Harvest, AL; WAYI(FM), Charleston. IN; WAYJ(FM). Fort Meycrs, FL; WAYM(FM), Spring Ilill, TN; WA YP(FM), Marianna, FL; W/\YQ(FM). Clarksville, TN; WA YT(FM), Thomasville, GA: and W1\ YW(FMj, New JolmsoTlville, TN. H Liccnsee of WIQO-FM, Covington, VI\; WKEY(AM) Covington, VA; WRON-FM, Ronceverte, WV; WSLW(AM), White Sulphur Springs, WV; WXCF(AM), Clifton Forge, VA; and WXCF-FM. Clifton Forge, VA. 3 t. Main Studio Rule A. LocMioll Commenters do not believe that the Commission should revert to its pre-1987 maln studio rule which required a station to be located within its community of license. Reverting to this rule neither encourages broadcasters to produce more programming locally nor increases the interaction between the station and the community. Adoption of the old rule will incrcasc stations' operating costs and decrease the funds stations have available to produce local programming and actively participate in community activities. Thc merc presence of a building in a community will not materially increase the interaction between a station and a community. Individuals today do not interact with a station by visiting its main studio. Communication betwecn stations and their listeners most ollen occurs online through emails, the station's website, or by phone. Instcad of requiring the costly maintenance of a main studio in a station's comll1unity of license, COll1lllenters believe the Commission should encourage stations to make themselves 1l10rc accessible by creating i1 strong presence onlinc, by encouraging panicipation in comlllunity evcnts, and by advising listeners how they can be involved with the station. Even in very small communitics ofliccnsc, contact with main stlldios is minimal. Sebago Broadcasting (licensee of WCTG(FM), Chincoteague, Virginia) cstimates that since the beginning of broadcast operations in 2002, it has had fewer than a dozen visitors to its main studio for any substantive purpose such as review of the public file or programming related issues. The vast majority or the few main studio visits were primarily from individuals who merely wanted to stop by to say "Hi" and take a "look" at a main studio. Station contact with the community is primarily by phone or through the efforts of station personnel out in the 4 community or through appearances in community events. Sebago's expenence is also the experience of KZID(FM), licensed to the small community of Orofino, Idaho. TLC notes that, "from decades of experience it has been ascertained that listeners arc nol interested in the studio or transmitter location, but ralher to the programming of the station." Montrose rep0l1s thut for years an organization located next door to its studio hand delivered their community calendar announcements to the studio. Last week for the first time they were emailed. Reliance on the phone and the internet, even in sl11all communities, is the preferred. 1110S1 utilized meanS of connectedness with a station. What's more, requiring a studio to be within a station's community or license docs not necessarily best serve the station's listening audience. Particularly for stations licensed to a suburb of a metropolitan arca, locating the main studio in a remote suburb docs not encouragc accessibility to the stCllion. RTN notes that its station WAFJ(FM) licensed to Belvedere, South Carolina, currently serves almost a million people. IfRTN is required 10 place its main studio in Belvedere, a census designated place with a population of around 5,600 people, fewer people would have access to the studio. Instead, RTN's main studio is in the center of the population it serves, allowing the studio to be accessible to a larger number of people. Likewise, KSBJ notes that for its stations licensed to communities ncar the Houston metropolitan area, listeners identify Houston as home and arc interested in hearing about cvents happening in Houston. It makes sense to place the main studio where it is accessible to the largest number of people. Comment is also warranled on behalf' or the noncommercial educational broadcasters. The additional cost of having 10 maintain separate main studios in each community would, in many instances, effcct the financial tipping point to wherc compliance with the main studio rulc would make provision of any service no longer viable. Indeed, the Commission routinely 5 recognizes and grants waivers to noncommercial educational stations who request waivers of the main stll Red 5024, 5027 (1988); see also American Family Association, (Marksville, Louisiana), 12 FCC Rcd 15128 (Hearing Designation Order 1997); Public Broadcaslillg ill NorthlVest Ohio (Defiance, Ohio), 12 FCC Rcd 15114 (Hearing Designation Order February 19, 1997); Greater WashillglOlI t:dl/calioll Telecommullicatiolls Association, I"c., (Leonordtowll, MmylclJld), 12 FCC Rcd 15123 (1997). It is instructive to note that stations that have been granted main studio waivers provide needed service to their communitics even without any main studio. A final issue worthy of comment on the main studio question is the effect of any change 111 the main studio rule on existing broadcasters who would be required to move their main studios. Aside from the additional unnecessary expense and burden or requiring broadcasters to maintain a studio in their respective communities or license, should the Commission adopt a change in the rules, many licensees would experience potentially devastating additional linancial burdens if they arc required to move and incur the significant expense of relocating their main studios. Therefore, ir the Commission determines to adopt the old main studio rule, the rule should be applied proactively and existing stations should be grandfathered. B. Staffing Requiring full time staffing at all timcs whl::n u station is on the air docs not increase a station's level of service to its cOITII11LJl1ity. This requirement would have the opposite effect on stations by forcing stations that do not have the income nccessary to hire additional staff to broadcast fewcr hours per day or to ellt back in locally produced programming. It could even force some stations in small markets to shut down. RTN estimates that the addition of staff 6 members to meet this requirement would increase a station's operating costs between $80,000 to $100,000 annually, while CEB estimates that hiring additional staff would increase its annual cost of operations by 15%, or $150,000, creating unneeded and potentially devastating financial hardships. TLC, operating two stations in Palestine, TX, estimates it would cost approximately thirty six thousand dollars a year to "hire at minimum wage a person to be a baby sitter at the studio". This additional expense in a small market, "would probably necessitate signing the stations off the air for six hours overnight". for small market stations in par1ieular, around the clock staffing would have serious adverse financial eonsequcnces and could make the difference between continuing service and no service at all. Sebago's start up station in Chincoteague, Virginia, has sustained losses for its first years of operation and is only now getting to a place of profitability. The additional costs imposed by further regulatory compliance would force Scbago to drastically reducc its broadcast operations or not broadcast at all. Ncw station KTKE(FM) in Truckee, Calilornia, has also had similar experiences. TLC claims that twenty four hour staffing is "not only cost prohibitive...it would actually lessen the exposure in the community". TLC would need to cut services to the community because staff would need to be reassigncd to cover the board instead of covering local and area events. The Commission must weigh heavily the reality that for many stations that arc barely surviving, additional costs (much less additional unwarranted costs) would result in lcwer operational stations and less servicc, a far worse situation than service that might not be as local as listcncrs may want. This issuc raises the reality that imposition of additional regulatory requircmcnts is disproportionately morc [nlf(lensome on smaller market stations than on stations in larger markets that gcnerate a greater cash flow. KSBJ, which operates several noncommercial stations 7 in the outskirts of the Houston market in smaller markets, reports that fro111 experience, it can expect $4,000-$6,000 per month in listener supported income per station from these stations. With tower leases, utility bills, and other hard costs factored in, there is insufficient funding for additional stafT. 181, which also operates several noncommercial stations in smaller markets, some with main studio waivers, reports that requiring main studios in each community of license with additional stalling would be "crippling" and would require that Some stations go ofT air. Riverview, which operates channel KOLU(FM) in Pasco, Washington, reports, "It is likely that KOLU would have to curtail its hours of operation, preventing it from serving listeners during unattended periods, such as overnight operation." Stations have found alternative ways to fully serve their communities without having a staff member constantly present at the station. Montrose, for example, always has an experienced staff member on call. If an emergency situation arises necessitating on atr annollllecmcnts, the 011 call starr member will go to thc station, record an announccment, update thc announcement as allen as necessary, and broadcast the announccment as many times as it would be broadcast if there was a staff member at the station all the time. The Commission notes in its NOPR that the reason for loosening its main studio rule in 1987 was due to advances in technology that had occulTed in the previous 35 years. NOPR at '1 28. Requiring stations to employ additional personnel ignores the advances in technology that have occurred in recent years and the technical advances on the horizon. Riverview notes that if Common Alert Protocol is implemented, it would be possible for a station operator to be on call and to remotely activatc emergency warnings. Instead of encouraging rules that ignore advances in technology, the Commission should encourage developments in technology and support 8 stations' utilization ofleehnology that is available, thus allowing stations to put more money into local issues and programming. 2. Commullity Advisory BOllrds Commenters do not believe that adoption of a new rule l1nposlllg regular community advisory board mcctings IS necessary to cnsurc the nceds of a community arc being met. Listeners today have a number of options for listening to music including satellite radio, internet radio, iPods, and traditional radio. The primary competitive advantage that radio has ovcr the other music sources is that radio can provide local programming. Radio will by economic forces be required to provide local programming to survive. Stations are able to adequately provide local programming and be involved in their communities without advice from a community advisory board. For example, CEB uscs a combination of phone calls and emails to local leaders, pastors, and listeners to ascertain key issucs that are of importance to the community. Logos electronically conducts monthly listener sllrvcys. Both RTN and Gatewuy currently utilize local advisory boards made up of members of their choosing to glvc fcedback and suggestions 011 progWl11lll111g. KSBJ's board of directors, which oversees radio station operatIOns,..tS composed 0 f1oca1commullIty . memhers. JS SBon road·castmg notes statIons. cun and do direct members of the community to the station web site to provide feedback on programmmg. 35 Son Broadcasting notes, "relying on a community advisory board to ascertain the needs and interest of the community puts broadcasters at the merey of a limited number of llldividuais who from time to time may have a personal agenda based on their specific background or beliefs and who based Oll their personal agendas, advocate for certain needs and interests; that are not nccessarily the majority nced and interest of the community". 9 As secn from the above examples, stations currently identify and address local issucs without Commission regulated community advisory boards. 36 Moreover, stations have a lb TLC states, "our General Manager belongs to the Palestine Chamber of Commerce and visits with Chamber members monthly. lIe discusses with the members their ideas of current and additional programming... including publie affilirs, news, publie service announcements, the wellness of the comillunity, areas of concern in the community and music. I-Ie also meets with Chamber members in nearby Cherokee and Henderson Counties for their comments about the above. Since virtually all of the Chambers members arc merchants or arc in the service industry he and the stations staff see thcm frequcntly, and easily can eonvcrl>e about the city and county events which may lead to public affairs, public service announcements or news within local news casts. lie attends the Rotary Club mcetings in Palestine weckly. lIe has been 1I0minated to received the Rotarian Paul Harris Fellow award. He talks to the sheriff monthly. lIe lrequelltly talks to City COlllmissioners. He frequently llleets with the Visitors Bureau regarding atlracting tourism for the county. lie gives lectures one day each semester to both Palestinc Middle School and Westwood Middle School about radio Cllrecr opportunities. lind listens to the students as to how they enjoy the radio stations and any changes they suggest. The General Sales Manager is involved with the local Red Cross; specilically, he is on the board lor raising funds. aile of our leading account repre~entative~ is a Red Coat Ambllssador lor the Chamber of Commerce. and assists ill promotion of the annual Dogwood festival and the Garden Show promoted on both stations. Our FM drive time 1lI0ming announcer interviews cOlTllllunity leaders (example .. Doug Lowe the District AHomey regarding credit fraud). Monthly he also interviews in prime Illoming time representatives from not only Palestine, but also IrOln nearby Jacksonville, Athens, and Tyler regarding the following local subjects. Chamber reviews; economic development such as promoting joh growth; marketing cast Texas; Crime Stoppers report such as preventative mea~ures and safety reminders; city managers report; arca school updates lrom the superintendents of the schools; county agents report regarding health, lamily, lind possible diseases; librarians regarding subjects such as children's awareness progralllS and elderly and parenting issues; Westwood lligh School students; Trinity Vlllley Community College news and students when available; Palestllle High School students; Lon Morris Community College news and students when available; Athens lIigh School information and students when available; Univerl>ity ofTexas at Tyler news; Jacksollville lligh School news from students when available; and Jacksonville Community College Newl>. The above interviews arc approximately five minutes in length. The AM station broadcasts lWO minutes of news at the top of the hour from 6AM to 5PM Monday through Friday. The news is received from the Texas State Network. The FM station broadcasts two minutcs oflocal and regional news hourly between 6AM and 5PM. Monday through Friday. Both stations broadcast weather reports and infonnationtwiee an hour 2417. Both stations broadcast ~ports reports daily highlighting local, regional and statewide sports developments. 10 financial motivation to provide local content. Many noncommercial stations are listener supported. [rthe listeners are not hearing the local content they would like to hear, they will tum to olher media sources and stop supporting the station. Similarly, if individuals listening to commercial stations arc not receiving the desired local content, they will stop listening, and advertisers will be less likely to purchase advel1ising time on the station. Finally, stations aim to meet different needs of groups in a cOlllmunity. [t is not practical to h NOPR at '126. Requiring a religious broadcaster to have members of the local sports conltmmity on its community advisory board docs not serve listencrs of a religious station any more than requiring a sports broadcaster to have clergy on its community advisory board serves the listeners of a sports station. Different stations serve different needs, and stations themselves arc in the best position to ascertain the needs of their loea[ listening audience. Commission regulation of localism through community advisory boards will detract from, instead of enhance, . 37 IIoca programmlllg. Furthennore, by quantifying, regulating, and homogenizing local programming, there is real potential that creative means of providing local programming or community involvement will be hindered since "it won't count." Sebago is involved in its community by participating, Both stations broadcast onc hundrcd (100) public scrvicc amlOunccmcnts per day regardless of length. The content is mostly local and repetitive to reach as many listeners during the day as possible. The FM station broadcasts the thirty minute Farm and Market Report from the Texas State Network for the farmcrs/ranchers in the area at 5;30 AM daily Monday through Friday:' 17 The COlllmission has acknowledged that stations need not address every community need or public issue. See Deregll!alion ofRadin, Report and Order, 84 F.C.C.2d 968, 997 (1981) ("What is important is that broadcasters present progr(lmming relevant to public issues both of the comlllunity (It I(lrge or, 1I1 the appropriate circumstanccs, relevant primarily to the more specializcd interests of its own listenership. It is not neccssary that c(lch station attempt to provide service to all segments of the cOlllmunity where alternative radio sources are available.") II lor instance, in the annual Chincotcaguc Pony Swim. This is thc type of the community connectedness that the public and the Commission seck, but it can take different lonns. For instance, a station can be involved by airing announcements lor the event, by being prescnt at the event, by participating in community mectings prior to the event, by having starr or personnel involved in the actual planning and organization of the event. This active type of' community involvcmcnt, which involves broadcaster discretion, carrics more weight than the typical community leader interviews or other local personality interviews that arc oftcntimes aircd during early moming hours when listenership is at its minimum. 3. Loc:,) Programming Just as with community advisory boards, Coml11enters agree that Commission regulation of local programming is not ncccssary and would havc an adverse impact on local programming. As noted above, stations have a financial motivation to provide local content. Local programming provides traditional radio stations an advantage over other media outlets and encourages listcners to financially contributc to noncommercial stations and advertiscrs to purchasc time on commercial stations. Commcntcrs currently overwhelmingly provide local programming to their listening audiences. CEB docs not usc any network programming. It broadcasts a morning show that is almost entirely about local issues. CEB becomes aware oflocal issucs through its staffs active involvcmcnt in the community - CEB's program director helps coach a high school track team, its gcneral manager is on several advisory boards, its development director is on the board or directors of H devclopmental1y-disabled baseball league, and its other stallmcmbcrs volunteer with community causes. Logos regularly airs public service announccmcnts and local event 12 infonnation as well as interviews with local leaders such as thc blood bank director and rescue mission director. Gateway airs public service announcemcnts every hour (i'om local churches, hospitals, and community organizations. Additionally, Gateway provides local news and infonnation Monday through Friday in the morning and afternoon. RTN makcs air time available to local churches and civic and community organizations. During 2007, RTN broadcast ovcr 8,000 hours of free air~time on its stations for local churches and non-profit organizations. LEBF airs public scrvice announcemcnts every hour that arc provided by the community about local events and happenings. Last year KSWP and KAVX aired over 20,750 public service annOllllcelllents. Requiring stations to doeumcnt and disclose the local programming aired will only place an undue financial burden on stations. Stations that arc already struggling financially, do not have the funds necessary to hire additional personncl to monitor and document local programming. Further, COlllmenlers do not support thc COlllmission's proposal to implcmcnt regulations re(]lliring a set amounl or local progr Commission's proposal to consider thc amount of local programming aired when processing renewal applications. COlllmenters believe that the funds that would bc nccessary to document local programming would be bcttcr spent producing local programming. 4. Voice Tnlckillg The NOPR also seeks comment on voice tracking, the prevalence or voice tracking, and whether the Commission should take steps to limit thc practicc, require disclosure, or otherwise address it. Voice tracking provides the technology and costs savings that allow stations to be Illore personal and local with significant cost savings. Especially in small markets, voice 13 tracking allows stations to stay local and personal when they otherwise might not be in a position to have on air personality presence but would instead have other music and programming in a jukebox format. Again, this may be a large markeUsmall market issue. The cost savings from voice tracking in large markets is inconsequcntial in comparison to gross revenues. The cost savings in smaller markets can be such that voice tracking allows stations to continue broadcasting. 5. Conclusion As seen from these comments from 34 different licensees and pennitlees operating over 110 stations, adoption of many of the proposals in the Localism Rulemaking will result in less service. Twenty four hour staffing will severely pineh the budgets of already strained budgets resulting in stations ceasing to broadcast in a worst case scenario or at minimum in a reduction of hours of operation or reduction in other services such as news. Perhaps iI' the additional slafling served a purpose such a sacrifice could be justified but it docsn't. The main studio is no longer the main contact point lor stations... the internet and phone arc. Therefore the requirement of a main studio in every city of license and additional SHifting would force the expenditure of funds for minimal or no bcncfit at a significant cost. Also evident from the comments is that stations do not need advisory boards or additional regulatory burdens...stations recognize that in order to survive in a competitive marketplace they must provide the type of local service thut will attract and keep listeners. Stations have been doingjust that all their own. 14 Respectfully submitted, Belmax BroadcJ:lsting, LLC Cedar Cove Bro~ldcasting, Inc. Community Educlltional Brmldcasting, Inc. Eagle's Nest Fellowship Church Educational Media Foundation of Brazosport, Inc. Gateway Creative BrmldcJ:lsting, luc. Gospel Music Broadcasting Corpol"ation Great Commission Broadcasting Corporation Greeley Broudcasting Corpol"lltion Illinois Bible Institute, Inc. Illinois District Counsel of the Assemblies of God JEll Licensee, LLC JKJ EdueJ:lliOlwl Found:ltion Kimb~lll Radio, LLC KSBJ Educational Foundation KZLZ, LLC L~lnHnie Mountain Brmldc~lsting, LLC Logos Broadc~ls(ing Corporation Lufkin EducatiolHll Brmldcastillg Foundation Michllel Radio Group Montrose Bromlcasting Corporation Occan Side Bro,ldcast'ing, Inc. Pan Amedclln Brmldcasting Company, Inc. Radio Training Network, Inc. Riverview Baptist Christillll Schools Sebago Broadcasting Company, LLC Side By Side, Inc. Son Broadcasting, Inc. Todd Robinson, Inc. Tomlinson-Leis Communications, L.P. United States CP, LLC Youngers Colorado Broadcasting LLC WAY-FM Media Group, Inc. :V~~ll ,:".Aj\',&....lc:=---- A.wr~h4J - Their Attorney Gammon & Grange, r.c. 8280 Greensboro Drive, 7th Floor McLean, VA 22102-3807 (703) 761-5013 April 28, 2008 15