The Letter Not Sent (re: LPFM, NPR, NHPR, complaint)

I was going through my files and found this unfinished letter to NHPR, my local National Public Radio affiliate, regarding the FCC’s proposed licensing of community-based low-power FM radio stations (LPFM). My point was (or it was going to be) that NPR was afraid to compete against other non-profit stations. NPR paints itself as an alternative to commercial radio (and it does a pretty good job most of the time), but it’s also a business. So NPR joined with commercial broadcasters to kill LPFM before it could get off the ground.

The fight included big broadcasting’s techs playing faked interference to scare lawmakers, but then they had to backtrack and call it “simulated” when somebody blew the whistle. Sadly, it really didn’t matter what the played; they brought the money and the pols gave a bullet to LPFM.

April 2, 2001

Mr. Sean T. Gillery
Director of Development
New Hampshire Public Radio
207 North Main Street
Concord, NH 03301-5003

Mr. Gillery

I recently received a letter from you regarding renewals to our NHPR membership and I wanted to take a moment to express to you my concerns over National Public Radio’s opposition to community-based low power FM radio. As you know, NPR joined with the National Association of Broadcasters to lobby for legislation that has blocked the FCC from licensing LPFM stations.

I believe that NPR’s position on LPFM betrays the beliefs and philosophy that had once drawn me to public radio. Can NPR or NHPR be trusted to put its listeners’ needs first and its commercial interests last? Not anymore.

I am growing increasingly concerned that the recent and ongoing consolidation of the radio marketplace will further limit and degrade coverage of news, culture, and local events. NPR has covered the consolidation and aired concerns about its negative effects:

Morning Edition, “Radio Merger Explosion” December 1, 1997
Weekend All Things Considered, “Black Radio” August 9, 1998
All Things Considered, “Radio Consolidation” January 9, 1999.
All Things Considered, “Radio Merger” October 4, 1999.

Unfortunately, coverage of the mergers ended when the FCC began considering LPFM in 1999. Since then, NPR has run a handful of LPFM stories. Each one focused on the potential for technical problems the LPFM law might create and the battle in Washington to prevent the licensing of LPFM stations. But none of the coverage discussed the reasons why the FCC was proposing LPFM. None of this coverage put LPFM in the context of the earlier commercial radio consolidations.

NPR, of course, had to issue a very carefully crafted press release to explain their position. I can’t imagine what the response, if any, from NHPR would have been had I sent the letter.

In the time that’s past, the republican controlled FCC has proposed measures that would lead to further market consolidation. Ironically, an NHPR sponsored station is one of the few LPFM licenses granted by the FCC before the law ended further licensing. The station, which plays classical music in the Concord area, went on the air just this year.

For immediate release
March 30, 2000 Siriol Evans, NPR


Washington, DC – National Public Radio(NPR) announces its support for HR 3439, the Radio Broadcasting Preservation Act of 2000, which addresses the recent Low Power FM (LPFM) decision of the Federal Communications Commission (FCC). The bipartisan bill was approved by the House Commerce Committee last week. NPR President and Chief Executive Officer Kevin Klose says this legislation takes “a carefully balanced approach” toward the licensing of new LPFM stations.

Under the bill, the FCC may go forward immediately licensing LPFM stations as long as interference protections to existing stations are maintained, including protections to third adjacent channels. At the same time, the legislation requires the FCC to set up an experimental program in nine markets to test whether LPFM will result in harmful interference to existing stations if third adjacent channel protections are eliminated. Among other things, the legislation provides that an independent party will conduct a study of the affect of LPFM without third-adjacent channel protections on digital audio broadcasting and radio reading services for the blind.

NPR has consistently stated that it supports LPFM in concept and believes that public radio and LPFM can be compatible, complementary services. NPR and its member stations believe that the FCC took inadequate steps in adopting its LPFM decision to protect the signals and transmissions of public radio stations and radio reading services. NPR believes that LPFM interference to public radio stations is particularly likely for the following reasons:

1) most public radio stations operate on reserved FM-band spectrum and are more tightly “packed” together than stations on the non-reserved FM-band spectrum, resulting in severe frequency congestion. Thus, there is a much higher likelihood of interference from new stations, even those of low-power;

2) public radio stations send signals that are “lightly processed” to preserve the natural dynamic range of the programming, particularly in the case of jazz and classical music, news/talk, and special programming that is rich in natural, on-location sound recordings. Heavily processed Top 40 stations limit the dynamic range to emphasize loudness. Lightly processed signals are much more vulnerable to interference making them more susceptible to interference;

3) many NPR member stations operate statewide networks configured to achieve maximum signal coverage to the population based on actual receipt of a signal rather than predicted contour overlap;

4) many public radio stations are more vulnerable to interference due to restrictions on power and antennas required to minimize interference to channel 6 television stations.

NPR had hoped to resolve its concerns without legislation. On March 16, 2000, NPR requested that the FCC reconsider and delay implementation of its LPFM decision, pending further testing and the adoption of suitable additional safeguards. However, it appears clear to NPR that the FCC intends to begin implementing its LPFM proceeding, including opening application filing windows, prior to resolving the significant issues NPR has raised in its pending Petition for Reconsideration.

Renowned for its journalistic excellence and standard-setting news, information, and cultural programming, NPR serves a growing audience of 14.6 million Americans each week via 625 public radio stations. NPR Online is available at [url=][/url] NPR also distributes programming to listeners in Europe, Asia, Australia and Africa via NPR Worldwidesm, to military installations overseas via American Forces Network and throughout Japan via cable.