On July 12, 2024, WGHN, Inc. had filed an informal objection to the short-term renewal of WAWL-LP, Grand Haven, Michigan. WAWL-LP previously entered into a Consent Decree regarding underwriting announcements which included a voluntary contribution of $2,500 to the US Treasury to settle the issue. At the time, REC released a video that reviewed the texts of the announcements and how they did not comply with the Commission’s Policy on the Nature of Educational Broadcasting, also known as the underwriting policy.
The underwriting policy is an interpretation of Section 399B(a) of the Communications Act, which defines a “commercial”.
In their objection, WGHN forwarded transcriptions of announcements allegedly heard over the air on WAWL-LP. We will, once again, review those announcements and provide public feedback in an effort to assist other LPFM and NCE stations to assure that their announcements meet the FCC’s underwriting policy.
This is an independent review. REC is not a party to either WGHN, Inc. nor WAWL-LP. REC does intentionally take a more conservative approach to underwriting messages given the limited resources available to many LPFM stations to defend complaints. These were reviewed by a non-attorney with over 20 years of experience in NCE/LPFM and is done to solely promote compliance by all NCE and LPFM stations.
REC has reviewed the copy of 10 messages and judged 1 pass and 9 fails.
Most of these announcements include testimonials, which is where instead of the station voice, the announcement uses the voice of a representative of the business speaking about their business or from a customer of the business. Announcements made by owners who are prominent in the community also violate the underwriting guidelines by "speaking to reputation". Underwriting acknowledgement messages are intended to be the station speaking to the listener to thank a local business for their support of the station. These need to be done in a station voice. Allowing the business to voice the announcement and speak directly to the listener can be seen as a purchase of time, inconsistent with §399B(a)(2) of the Act. If these announcements were voiced by the station and used “they” instead of “we” and did not refer to the names of the employees or business owners, they would not fall under a testimonial.
Preferred Auto Group
|
Support on 103.5 WAWL comes in part from Preferred Auto Group. This is Julie. We offer new cars, used cars and service centers. Our locations are on the west side of Beacon Boulevard in Grand Haven. Our website is Preferred Automotive Collection dot com. Preferred Automotive Group is a proud Underwriter on 103.5 WAWL. |
Testimonial. |
FAIL – Testimonial (business speaking directly to listener).
Stan’s Bar
|
Underwriting on 103.5 WAWL comes in part from Stans Bar and Grill in Spring Lake. |
|
|
Hi this is Joe Stalec. |
Testimonial |
|
Stan’s offers cheeseburgers and bar food |
|
|
for dine-in and take out. |
Solution suggestion |
|
We’re located at 208 West Savage Street in Spring Lake. Our phone number is 616-842-1553 |
Testimonial |
|
and you can find us on facebook. |
Call to action |
|
Stan’s Bar and Grill is a proud Underwriter on the mighty 103.5 WAWL Community Radio. |
|
FAIL – Testimonial (business speaking directly to listener). You cannot promote the business by stating the business amenities (take out and dine in). “Find” is a verb. Suggested rewording, “They can also be reached through Facebook”. Since the copy suggests “find us on Facebook”, it can also be seen as an enticement to patronize the business through contact over Facebook. This is no different than using “You can call them” or “You can call us”. You cannot suggest listener actions.
The Surf Shop
|
This is Laura Girard of the Surf Shop, a proud Underwriter of 103.5 WAWL. We offer swimwear, surfboards and beach accessories. We’re located at 16 Washington in downtown Grand Haven. The Surf Shop is a proud Underwriter of 103.5 WAWL. |
Testimonial |
FAIL – Testimonial (business speaking directly to listener).
A Shade Above Blinds
|
Support on 103.5 WAWL comes in part from A Shade Above Blinds. |
|
|
Hi this is Lindsey. |
Testimonial |
|
A Shade Above Blinds is a mobile showroom |
Qualitative |
|
that brings blinds and fabrics to residential and commercial businesses. |
Solution suggestion |
|
Our phone number is 616-8474393. A Shade Above Blinds is a proud Underwriter of 103.5. |
Testimonial |
FAIL – Testimonial (business speaking directly to listener). Also promotes the convenient nature of the business and suggesting it as a solution for residential and commercial customers.
D Baker and Son
|
Support for 103.5 WAWL comes in part from D Baker and Son Lumber, |
|
|
featuring lumber and hardwood such as oak, cherry and hickory. |
Menu listing |
|
On the web at Baker lumber dot com and located at 720 Pennoyer in Grand Haven. D Baker and Son lumber, a proud supporter of 103.5 WAWL. |
|
FAIL – The underwriting guidelines allow for a limited amount of product lines or brands. If they had only said “lumber and hardwood” and did not get into “oak, cherry and hickory”, this announcement would have passed.
Fritz Auto Body
|
Support for 103.5 WAWL Community Radio comes in part from Fritz Auto Body of Grand Haven. |
|
|
Hi, this is Mike Fritz. |
Testimonial |
|
Fritz Auto Body works on collision repair, frame alignment and paint work. The phone number is 846-5006 and is located next to the railroad tracks off Taylor. Fritz Auto Body supports 103.5 WAWL. |
|
FAIL – Testimonial (business speaking directly to listener).
Harbor Transit
|
Underwriting on 103.5 WAWL comes in part from Harbor Transit. Trolley season is finally here. Harbor Transits lakeshore Trolleys will run daily from 12pm to 10pm through Labor Day. This year riders can track the trolley on our website and the transit app, so you’ll know when the trolley will next arrive at your stop. Learn more about the trolley routes, track the trolley and purchase your tickets at Harbor Transit dot org slash trolley. Harbor Transit is a proud Underwriter on 103.5 WAWL Community Radio. |
|
PASS – Harbor Transit is the brand name of the Harbor Transit Multi-Modal Transit System, a public agency. As this is not a for-profit entity, it does not meet the §399B(a)(1) definition.
J Dubs Market and Wine Shop
|
Underwriting on 103.5 WAWL comes in part from J Dubs Market and Wine Shop. J Dubs Market and Wine Shop offers cheeses, wines, plus gift baskets and |
|
|
we’re located at 705 Washington. |
Testimonial |
|
J Dubs Market and Wine Shop, a proud supporter of 103.5 WAWL Community Radio. |
|
FAIL – Testimonial (business speaking directly to listener). This is not the station speaking, but instead, the business. A simple change of “we’re” to “they are” would make this announcement compliant.
Spring Lake State Farm
|
Hi, this is Doug Heins from Spring Lake State Farm Insurance proud Underwriters on the 103.5 WAWL Community Radio. We offer auto, home and retirement planning. Our website www dot Doug Heins dot com. We’re located at 701 Savage Street and our phone number is 846-4040. And we are proud Underwriters on WAWL Community Radio. |
Testimonial. |
FAIL – Testimonial (business speaking directly to listener).
Straight Line Design Kitchen and Bath Studio
|
Underwriting on 103 5 WAWL comes in part from Straight Line Design Kitchen and Bath Studio. |
|
|
Hi this is Jim Tompkins, we offer cabinetry, countertops and flooring. We’re located just north of Leppinks on Old Grand Haven road. Our phone number is 616-296-0920 and our website is Straight Line Kitchens dot com. Straight Line Design Kitchen and Bath Studio is a proud Underwriter on 103 5 WAWL Community Radio. |
Testimonial |
FAIL – Testimonial (business speaking directly to listener).
For more information on LPFM/NCE underwriting compliance, see:
https://recnet.com/compliance
