As a result of their call for help, many K-Love and Air-1 supporters posted comments on the FCC's comment filing system. If you did that, you played a role in a very important government process and we appreciate it when any member of the general public comments on an issue with the FCC. You have commented on rulemaking that could lead to some changes in the broadcasting rules that would result in more localism. The issues dealing with FM translators and LPFM stations are just a small part of the proceeding.

Some of you may be familiar with the Low Power FM service. Some of you may have an LPFM station already operating in your neighborhood. For those who are not familiar with the stations, the Low Power FM broadcast service was created back in 2000 as a way to bring some additional voices to the airwaves. This need for the new stations was prompted by the large consolidation of media in the commercial broadcasting industry as well as the expansion of large non-commercial organizations, such as EMF into urban areas. Remember, there's very limited room on the radio dial, only so many stations can fit. With that, the FCC must manage the limited space on the radio dial and make sound judgement calls to assure that the public interest is being met. LPFM stations operate in a manner that their average coverage area is just a few miles. Perfectly suited for a small to medium sized community or in the neighborhood of an urban area. Like K-Love and Air-1, LPFM stations are non-commercial and they can only be licensed to non-profit organizations including schools, churches, ministries and local government. In fact, a considerable number of LPFM stations are operated by local churches and ministries and some of them program the same music and messages you hear on K-Love and Air-1.

Now, many K-Love and Air-1 listeners had commented that you feel that the music and the positive messages is something that is not available elsewhere. To some extent, we agree with that. However, we must also look at the fact that EMF, a California based organization is programming basically the same two program feeds across the country. While we recognize that some stations may break away for local programming, it's pretty much the same thing. REC feels that nationwide networks such as K-Love, Air-1 and ones from other organizations are better suited for satellite radio, the Internet and other sources. The local radio spectrum is very finite and there needs to be priority given to local organizations that want their voice heard on the air.

REC does feel that EMF has blown the whole situation way out of proportion. First, the FCC has not stated that they currently considering allowing LPFM stations to replace translators such as the ones operated by K-Love and Air-1. The FCC is actually considering to harmonize the rules between LPFMs and translators. Basically meaning that translators and LPFM stations would have a more equal footing. The concern comes from pro-LPFM organizations such as REC (us). Our concern is about organizations that operate "imported" signals brought in from other parts of the country as these stations prevent local organizations and churches from constructing their own non-commercial radio station. In many comments to the FCC, REC has suggested that translators who depend on a primary station that is "over 400km away and in a different state" than the translator is not capable of providing a local broadcast service and therefore someone who can provide a local broadcast service (an LPFM station) should have priority over these stations.

The FM translator service was originally created to bring FM service into small rural communities and other areas that were blocked by terrain from receiving full service FM stations. In the 1980's, the broadcast regulations were changed to allow for a major expansion of full power FM stations into more smaller towns. In the mid-80's, the FCC allowed non-commercial broadcasters to be able to use satellites to send programming to their translators (up until then, a translator station had to pick up the radio signal directly from the primary station or from another translator). This satellite rule was originally put in place to allow for statewide public radio networks to be able to put translators in remote communities that can not receive any other FM stations. Unfortunately, this loophole in the law has allowed a broadcast station in Idaho to have a translator in Key West, Florida.

When it comes to the translator rules being proposed by REC and others, EMF (K-Love/Air-1) does not have much to worry about. This is because a majority of EMF's listeners are on full power FM stations and of those who listen on translators, those translators pick up the signal of a station near you, either in your state or in an adjacent state but very close. Even though we are concerned about the fact that EMF owns a lot of full power stations (they are the second largest owner of non-commercial full power stations) and a significant number of translators (both local and distant ones), the local full power stations have some form of obligation to the needs of their local community and they are require to keep local emergency monitoring equipment. Therefore, a translator that rebroadcasts this type of station 80 miles away does not bother us as much as the Idaho station with a translator thousands of miles away in Florida.

REC has done some research into the impacts of our proposed rules on many of the non-commercial broadcasters including K-Love and Air-1. Out of all of these broadcasters, K-Love and Air-1 would not be that strongly impacted because of the large number of full power FM stations. In fact, a majority of the impacted translators would be those that rebroadcast KLOV out of Oregon. REC's bigger concern is some additional rules that are being proposed by a different non-commercial Chrisitan broadcaster that would allow for an expansion of the satellite-fed translators in America.

REC feels that we have a reasonable approach to promoting localism in broadcasting while maintaining as much of the existing infrastrcture as possible.

If you don't mind reading legal-ease, please feel free to read our comments [PDF] about localism in broadcasting and our proposed changes to the LPFM, translator and full power FM broadcast services. If you would like to repsond, you may file reply comments with the FCC before the close of business on December 1, 2004.

As a convenience, we have provided the following on-line tool. This tool will determine which K-Love or Air-1 station you listen to. It will tell you the type of station it is. If it is a translator, it will tell you where the source of the programming comes from and it will tell you if you are served by a distant translator that may be subject to displacement by LPFM stations or if your translator is considered by REC as a local translator.

Again we stress, the FCC has not approved the displacement of any translators for LPFM stations. Thank you for your concern in this matter and taking the time to hear both sides of the issue.