FCC Record, Volume 27, No. 1, Pages 1 to 936, January 3 - February 3, 2012 Page: 64
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these restrictions, we believe that LPFM offerings in both the audience and advertising markets are lower
quality substitutes for the offerings of full-service commercial FM stations.
5. First. the limitations on the maximum power of LPFM stations substantially reduce the
number of potential listeners they can serve and, therefore, the number of listeners they are likely to draw
away from full-service commercial FM stations. The requirement that LIPFM stations operate at no more
than 100 watts appears to constrain their ability to gain listeners significantly. As a result of this power
restriction, the reach of i.PFM stations is limited to about 3.5 miles, which is substantially smaller than
the reach of the median full-service commercial FM station of approximately 26 miles." Further. the
median coverage area of full-service commercial FM stations is approximately 55 times larger than that
for I.PFXI stations, 1he median coverage area population of full-service commercial FMX stations is I10
times larger than that of IPFM stations, and the average coverage area population of till-service
commercial FM stations is approximately 30 times larger than that of the average ILPFM station."
6. The low power of an IPFM station affects not only its geographic reach and coverage
area, but also the quality of its signal and the ability of listeners to receive its signal consistently inside the
station's coverage area. For example, several of the station managers interviewed for our Case Study
Analysis explained that their station's signal was not able to penetrate the walls of homes sufficiently.
Such indoor reception problems reduce potential IPFM listenership. As described further in the case
studies, LPFM signal propagation also may be vulnerable to intermittent interference from full-service
stations and changing weather conditions." In addition to reducing potential I.PFM listenership within an
IPFM station's coverage area. these reception problems may cause an LPFM station to be regarded as
providing a lower quality signal than full-service stations. Additionally, we note that the relatively small
coverage area of. and reception problems associated with. LPF:M stations limit their appeal to potential
underwriters.
7. Second, the fact that IPFM stations must operate on an NCEt basis substantially limits the
types of entities that may become LPFM licensees. The types of entities that are eligible to sen e as
LPFM licensees - such as churches, community organizations, public safety organizations, and
educational institutions - are likely to have listenership and revenue-earning goals that are different from
those of for-profit licensees. Many IPFM stations may have a limited need for underwriting because they
have institutional financial support, with funding from their school, church, government agency, or other
institution.' We note in this regard that it appears that a large percentage of LtPFM stations do not
currently provide any underwriting announcements." As demonstrated in other parts of the Economic
Study and in the record in this proceeding, LPFM stations also tend to operate on small budgets,
particularly in comparison to full-service commercial FM stations.'
See Appendix A.I.
'See i.
8 See Appendix A.2.
SSe e id.
o See id.
See Appendix A.2. (noting that only three of eight sample stations in the case study analysis accept underwriting
from local businesses, with one station receiving approximately $3,000 in annual underwriting revenues: one
receiving approximately $12,000 in annual underwriting revenues: and the third receiving between $120.000 and
$130.000 in annual underwriting revenues): see also Report at Section IV (reporting results of 2011 Prometheus
survey of l1PFM stations in which most respondents reported that they rely on underwriting to fund 25 percent or
less of their annual budget).
2 See Appendix A.2. (finding that the case study sample stations had typical annual budgets of $10.000, compared
to the median full-service commercial FM station budget of $723,000); see also Report at Section IV (reporting
(continued....)64
Federal Communications C:ommission
DA 12-2
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FCC Record, Volume 27, No. 1, Pages 1 to 936, January 3 - February 3, 2012 (Book)
Biweekly, comprehensive compilation of decisions, reports, public notices, and other documents of the U.S. Federal Communications Commission.
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United States. Federal Communications Commission. FCC Record, Volume 27, No. 1, Pages 1 to 936, January 3 - February 3, 2012, book, February 2012; Washington D.C.. (https://digital.library.unt.edu/ark:/67531/metadc154714/m1/80/: accessed April 25, 2024), University of North Texas Libraries, UNT Digital Library, https://digital.library.unt.edu; crediting UNT Libraries Government Documents Department.