Before the Federal Communications Commission Washington, D.C. 20554

In the Matter of: ) ) Retention by Broadcasters ) MB Docket No. 04-232 of Program Recordings ) )

To: The Commission

COMMENTS OF Bruce Goldsen, President, , Inc.

Jackson Radio Works, Inc., the licensee of WKHM (AM), WKHM-FM and WIBM, pursuant to the Notice of Proposed Rulemaking, MB Docket No. 04-232, hereby submits its comments on the Commission's proposal to require the recording of programming by broadcast stations, and the retention of such recordings.

As the owner-operator of three commercial radio stations in a market of 150,000 people, I am adamantly opposed to the Federal Communications Commission proposal to require the recording and retention of programming aired by broadcast stations.

The majority of commercial radio stations in the United States have an unblemished record of fine, local programming and exhaustive service to their community. Requiring stations like ours to purchase and install logging equipment places on licensees a completely unnecessary financial and manpower burden. With less than 20 full-time employees, we do not have the resources to record and catalog such a large volume of material, multiplied by three stations. Just the costs of purchasing and installing the necessary equipment for our three facilities could easily approach $15,000.00! In addition, we would have to dedicate an already over-extended staff person to cataloging and archiving the recordings.

Licensees that traffic in the type of programming that the Commission deems “indecent” do so on a regular basis; indeed, it is programming that they have chosen to air because it targets a particular audience they are trying to win. Listeners who take issue with those programs can continue to record these programs, as they have, and will certainly not have a difficult time finding it.

Forcing thousands of licensees, who believe that airing indecent programming is not only bad for business but also ethically inappropriate, to record all of their programming is a needless regulatory edict, and will cause a great hardship for most of the nation’s radio station licensees. I sincerely hope the Commission will consider these factors as it prepares its rulemaking.

Bruce Goldsen, President Jackson Radio Works, Inc. WKHM AM/FM, WIBM 1700 Glenshire Drive Jackson MI 49201 (517) 787-9546