Online construction permits

These days you can order an automobile on line, choosing colors, options and delivery date. Ditto everything from travel to furniture to tango lessons. Why not FCC construction permits?

Right now, filing a form 301 for a minor change entails entering all the technical information using an online form. "Filing" requires the applying entity to have an account (FRN) and payment of a fee, usually by credit card. It is possible to pay by check but only at the applicant's peril, as sometimes check and application are not reconciled before the FCC purges the application for nonpayment.

Once the 301 application is received and the fee paid, the FCC puts the application on public notice by listing it in the daily "Broadcast Applications" list available on its website. Anyone with a comment on the merit (or lack thereof) is invited to be heard by the FCC. Most minor change applications receive no comment. On balance, most minor modifications represent changes that licensees are automatically entitled to, provided they are the first to file, and so comment for or against has little effect.

Following public comment, most applications enter a dormant period lasting about 90 to 120 days. Then the FCC applications staff examines the technicals and, provided there are no errors, grants the application. If there are errors, the applicant gets a so-called "30-day letter" listing the errors found by the staff and setting a time limit for filing a corrective amendment.

Since about 1980, the technical parameters of minor change applications have been prepared using computers. As we all know, broadcast software has become extremely sophisticated, multifunctional and easy to use. We at AMS hold licenses for almost every broadcast software package. As might be expected, they all produce nearly identical results. FM spacings almost always agree exactly, since the formula for computing distance is published in the FCC rules. Contour distances under FCC F[50,50] and F[50,10] vary slightly, owing to the coding required to implement the associated graphical curves in software. Some software draws 360 radials, some 72, some allows user selection. All packages work pretty much the same way, implementing the coverage and spacing models embedded in the FCC rules.

The FCC goes through much the same process in checking an application for grant. The same spacing and coverage parameters must be checked for accuracy and compliance. Tower coordinates must be cross-checked, since the FCC uses NAD27 datum and the FAA uses NAD83/WGS84. All this FCC checking involves human applications processors. This is unacceptably wasteful. We believe the majority of 301 applications could be handled by an automated "back end" of the present online application process.

Such an automated real-time checking function would give an applicant immediate feedback as to whether the application is grantable or not. Technicals which conflict with an existing license or prior-filed application, fail to cover the community, etc. would simply result in an on-screen error message. Applicants would be presented with the choice of correcting, seeking a waiver or quitting. A completed application, free of errors, might be granted instantly subject to finality following the mandated public notice period.

Requesting a waiver would put the application into the manual checking queue to be processed the old fashioned way, with the attendant delays. Thus licensees would be rewarded for filing applications that comply with the rules. Follow the published rules and you get an instant CP. Ask for special treatment and you go to the back of the line.

Some rules, like ownership, might be a bit complicated to implement in software. An interim solution might be to automatically mail notice of any application to all the other stations within the associated Arbitron Market, inviting comment as to violation of the ownership limits. In non-Arbitron markets, mail to every station within a given radius, perhaps within the predicted interference-free contour. Market competitive forces can be harnessed in this way to ensure compliance. Automatic mailing is cheap, easy and relieble.

Ultimately, every attributable ownership in a broadcast property and the associated individual should be indexed along the lines of the present FRN system, thus allowing an automated vetting of ownership compliance. Right now, the FCC mostly relies on self-policing of ownership, accepting as honest whatever map and list the applicant provides. Falsification risks getting you stuck to a lack-of-candor tar baby, so deliberate misrepresentation is rare anyway.

If as many as half of the routine, rules compliant applications out of the manual vetting process, the waiting time for non-routine applications is sure to fall. By creating an incentive to file a routine application, some applicants will choose that route where they might not have otherwise. Peter Moncure, author of the RadioSoft package, believes an application process back-end can added to the FCC's online filing system. FM, because of the straightforward technicals, would be easier and might be the best place to start. But I can see no reason such a system wouldn't be possible for AM and TV as well.

Frank McCoy
Executive Vice President, Engineering
American Media Services, LLC Read more!

Mike Sullivan's Comments in RBR

Mike Sullivan makes the excellent point (see below) that we have been talking about since our first AMS Radio Index revealed that one of the main reasons Americans like radio is local programming for news, traffic, weather and community events. And one of the things they like least is the commercial load. Mike's is an excellent example of making a strong impact in his market, and there are many other examples across the country. All the best, Ed Seeger
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RBR Online
May 17, 2006

It's sad to see people like Scott Evans get so brainwashed by the "informed media observers" who bash Clear Channel on a regular basis.

First of all, yes, Clear Channel's primary objective is to satisfy Wall Street and its stock holders. Last time I checked, that was called being a responsible business. I do appreciate Mr. Evans acknowledging ClearChannel/s ideas as innovative and progressive. But to call them quick fixes is ridiculous. The fact is, for many of CCR's properties, "Less Is More" took a leap of faith. They needed to realize that the short-term bottom line may take a hit, but in the long run, they are offering a preferable climate for listeners and advertisers. Similarly, the attempt to train advertisers to provide their messages in :30s and :15s (and :05s) instead of :60s is an attempt to reduce clutter and increase average rate-per-second. I fail to see how anyone can fail to "do the math" on that issue.

Finally, to address the paramount "sin" that Clear Channel is accused of .... killing localism .... let me just state that I have now worked in radio (on-air, sales, and management) for over 35 years. I have worked under ten different ownership groups... and I have never worked for a company that has COME CLOSE to allowing the local autonomy that Clear Channel has. We have more local news, sports, and contests on our seven radio stations than we have ever had. Our Morning Show DJ's are revered in our communities. We have won awards for community-based benefit promotions. And, I might add that we're looking forward to the challenge of HD because it will provide us with an opportunity to do even more local "niche" broadcasting. To say that Clear Channel is a Wall Street-driven company and that's why they're making innovative, progressive moves is akin to saying that your local supermarket is trying to be profitable by coming up with ways to better serve their customers. It's called smart business.

Mike Sullivan
Eau Claire, WI Read more!

Leveling the Playing Field

"When we released the first AMS Radio Index in late January, it revealed to me that the mainstream media ARE interested in the story of terrestrial radio, and how the American consumer views our industry. One of the most compelling findings in our first survey was that 64% of Americans are listening to radio as much as, or more than, they were five years ago. That's something we haven't heard in a while, and the results of our survey was picked up by such consumer publications as the New York Daily News, the Orlando Sentinel, the Louisville Courier-Journal, Hartford Courant and others. But the mainstream reporter who got it best was Martin Miller of the Los Angeles Times, who called me after the index was released and talked with me for almost an hour. He went on to talk with others in our industry, and the result was this piece in the LA Times on February 21st. Imagine if we had a number of articles like this to counter-balance the PR onslaught of satellite. It would help level the playing field." --Ed Seeger

Broadcast radio prepares a content expansion to rival satellite offerings
February 21, 2006
Los Angeles Times
By Martin Miller, Times Staff Writer

Terrestrial radio is beaming a new message to satellite radio — and wants to make sure that its 200 million-plus daily land-based listeners and Wall Street investors overhear every word: Your 15 minutes of fame are over.
Pummeled by an enormously successful holiday media and publicity blitz, terrestrial radio this week begins a multi-pronged marketing counteroffensive that it hopes will bring its overhead competitors back down to earth, preferably in one huge crash.
Cooperating in unprecedented ways, terrestrial radio broadcasters are officially unveiling a significant tech innovation of their own and a high profile nationwide campaign to trumpet it. One campaign that began Monday in Los Angeles and more than two-dozen other big cities heralds terrestrial's long-awaited entrance into the digital age.
This latest, more muscular marketing push comes on the heels of several smaller independent efforts over the past couple of months, in which individual radio companies tried to highlight one of their strongest selling points against their roughly $13-per-month competitors: We're free.
The term "free radio" is being used, well, freely around town in billboards advertising DJs on the AM and FM dials, such as Howard Stern's L.A. replacement, Adam Carolla, on KLSX-FM (97.1); Mancow Muller on KLAC-AM (570) is being hailed at the King of all Free Media.
At stake is whether traditional radio can recapture some of the consumer and industry buzz temporarily ceded to satellite radio in the wake of shock jock Stern's defection to Sirius Satellite Radio. (Oprah Winfrey will be going to Sirius' larger rival, XM Satellite Radio). Industry observers wonder whether these initial steps by terrestrial radio will be enough to maintain it as a dynamic media business.
Like other forms of old media (newspapers, network television), terrestrial radio must fight the perception that it will inevitably lose major ground to the new media, even though it can still appeal to mass audiences. But radio needs to fight back fast and hard against its satellite competitors, according to analysts.
"If you've got 11 million satellite subscribers there's nothing trivial about that," said Mark Ramsey, president of Mercury, a San Diego-based radio research and marketing company, referring to XM and Sirius' current subscriber base. "I think what you're seeing now is radio responding to the chorus on Wall Street that is saying, 'Hey, what's up with you?' "
Radio's answer to that long-simmering question is HD digital radio, the industry's next-generation product that can best compete with satellite's sound quality and dizzying programming options. In the works for more than a decade, digital radio will enable broadcasters to significantly upgrade their signal — AM will sound like FM, which in turn will sound like a CD, they say.
Further, the compressed digital signal will allow for multicasting, which means radio stations will be able to divide their dial spot into anywhere from two to four channels. For instance, Clear Channel Radio's KBIG-FM will continue to air an adult contemporary format at 104.3, but now is also playing round-the-clock disco hits on its side channel, 104.3-2.
Nationwide, only about 700 stations are broadcasting in digital and just about 260 of those stations are or will soon be multicasting, including about a dozen in Los Angeles. Industry officials say both those national figures are expected to more than double within the next year.
"From a creative standpoint, the secondary channel will allow us to be more experimental," said Kevin Weatherly, program director at KROQ-FM (106.7-FM), which expects to begin multicasting a harder-edge rock channel at 106.7-2 within several months. "It's going to double the choices overnight and at the end of the day it's going to be great for the listener."
Like KROQ-FM and KBIG-FM, a station's multicast typically serves up niche programming loosely related to its main format. The radio industry has pledged the side channels will be commercial-free — at least for the next few years. Starting this week radio stations in 28 major market cities will begin running ads — valued at some $200 million — to alert consumers of the digital advancements and, they hope, to stimulate real sales.
"This is sort of a marketing person's dream," said Peter Ferrera, president and CEO of the HD Digital Radio Alliance, a 12-member consortium of the nation's leading radio companies formed last year to roll out the new product. "We're selling radio on the radio to people who are listening to the radio."
HD radio, however, has some major obstacles to overcome before the market situation could fairly be described as dreamy. While it's true digital radio is free, consumers currently need to shell out at least several hundred dollars to buy a special receiver to hear it.
The in-car incarnation
Analog radios, of which there are an estimated 700 million units in the U.S. alone, do not benefit from the digital signal. For that, consumers will need to purchase a special receiver, which only recently dropped below $500. Radio officials would like to see that figure drop to around $150 — a price point at which they believe consumers will take quicker advantage.
Another problem for HD radio is sheer numbers — right now, there are probably less than 100,000 units in use nationwide. Many stations that have been broadcasting in digital or multicasting may have been doing so to audiences in the thousands, or even less. And, at the moment, HD Radio doesn't have a Howard Stern-like selling point to crystallize interest and demand.
The most urgent matter for the radio industry is negotiating a deal as soon as possible with automakers to have digital radios installed in cars. So far, just BMW has agreed to put them in its cars. Meanwhile, radio officials have been feverishly lobbying American automakers to follow suit.
"It's critical they get into cars, where most of the listening takes place," said Scott McKenzie, Billboard Radio Monitor's managing editor. "If they can't do that, it's not going to be a going concern."
For their part, XM and Sirius Satellite Radio regard terrestrial's digital launch and accompanying marketing as more circling of the wagons. Driven by the holidays and a publicity windfall surrounding Stern's move to Sirius, both companies combined to score nearly 2 million new paid subscribers in the last quarter of 2005.
The huge gains came at a heavy cost — both companies reported a combined quarterly loss of roughly $600 million as they continued to shell out big dollars for publicity and their marquee talent. Meanwhile, a high-ranking XM official resigned from the company's board earlier this month and warned of a possible financial "crisis."
Despite the financial hemorrhaging, the two companies contend subscribers will reverse the bleeding, and indeed have made bold predictions for their future — Sirius says it will double subscribers to 6 million by the end of this year; XM says it will have 20 million by 2010.
"We wish them luck," said Patrick Reilly, a Sirius spokesman, of terrestrial's move to digital. "We have more than 125 channels of great programming, including commercial-free music channels, and so we think that what is good for radio will be very good for us."
Even at this point, terrestrial radio officials don't like to admit satellite is a threat. Joel Hollander, CEO of CBS Radio, formerly known as Infinity, which was Stern's former radio home, characterized satellite as a "boutique" business. Still, he praised Sirius' marketing chops in publicizing the transition.
"I don't think there's a person on the planet that doesn't know Howard went to satellite," he said. But, he noted, the strategy could easily backfire. "The next quarter for Sirius is critical," added Hollander, whose company made millions off of Stern's popularity. "You either are going to sign up or you're not."
But there's little doubt among industry observers that satellite's emergence played a substantial role in an almost unheard-of alliance between intense radio rivals including behemoth Clear Channel and CBS Radio. After more than a half-dozen high-level meetings over nearly nine months, the group officially came together in December to accelerate the push for digital radio.
"I think everybody, especially on Wall Street, wants to see we're investing in our future," said Hollander. "Our group may not agree on a lot of things, but we do agree that together we can really help our industry and we're going to do just that."
One way terrestrial radio intends to improve its position is through aggressive marketing. The various campaigns started ramping up in October of last year when Stern was jumping from terrestrial to satellite. Then CBS stations began branding themselves as "Free FM." For the record, CBS officials deny the "free" is a reference to cost, but rather to the spirit of its content, as in "free form" or "free for all." Similarly, the "HD" in HD radio doesn't actually stand for "high definition" either.
"Quite honestly, it doesn't stand for anything," Ferrera said. "The concept was somewhat of a steal from HD television, where viewers know it means better quality."In January and February, the radio industry, with help from big-name artists including the Rolling Stones, Avril Lavigne and Alicia Keys, banded together to air spots titled "Radio. You hear it here first." More campaigns lauding radio's "free, over-the-air" strengths and its ability to provide live on-the-spot news coverage are on the way, according to the National Assn. of Broadcasters, a radio trade group.
As terrestrial radio rolls up its sleeves while it rolls out its product of tomorrow, the message it ultimately is trying to convey to its millions of daily listeners is that rumors of its death have been greatly exaggerated.
"It's like when the 8-track player came out and everybody said it was going to kill radio. Then they said the same thing with cassettes and CDs," said Ed Seeger, president and CEO of American Media Services, a radio development and consulting firm based in Charleston, S.C. "Well, it didn't happen." Read more!

Pomposity of Sirius

"Audio Graphics has done a good job in going through some of the "pomposity" of satellite radio's public relations campaign and, as we all know, found quite a few holes in what they're saying. At AMS, we've been trying to get our industry to push back for years. 2006 could be the turning point." --Ed Seeger

A Sirius Attack on Radio Industry and XM?
April 3, 2006
Audio Graphics Many justifiable accolades have been given to the publicity department at Sirius Satellite Radio, especially in its handling of Howard Stern's debut, but this time it's gone too far.

First you'll have to read the publicity release linked below to understand the points mentioned here. The dribble that's been put out today may signal an act of desperation more than one of pride. It's an attack on the radio industry and XM Satellite Radio, done with pomposity.

There's no doubt Sirius should be proud of its star. Howard Stern is as important to its success as its satellites overhead. But the descriptions of where this company is at, relative to the reality of the industry, aren't supported by verifiable fact. All claims are superlatives. Here are examples of a few statements from that press release (and coming from just the first two paragraphs!), which may leave you wondering where these people are coming from:
"It turns out Sirius is now the 'Big Dog' of satellite radio leaving XM
in the dust." (XM just announced 6.5 million subscribers.)

"Not only are subscribers jumping aboard in waves, but
corporate advertisers are also storming the gates of Sirius."

"Although this trend is obviously crushing their only satellite
competitor XM, terrestrial radio stations are also taking a huge
hit in lost advertising revenue thanks to the success of Sirius."

Wayne Perry, President of SiCap Industries, is quoted in paragraph three. It is a glowing report that has Mr. Perry tripping over himself with niceties. One statement of his shows the lengths of satisfaction reached: "Barely six months ago, SiCap Industries was spending 100% of their radio budget on local terrestrial stations in mid to large markets over twenty percent of the country. Today SiCap is spending 40% of their radio budget on Sirius..."

These sentences are immediately followed by this - presumably from Sirius: "Commercial spots on Sirius appear to be welcomed by listeners who have come to expect at least some advertising, and that’s where the Sirius traffic department plays it smart. Commercial space on Sirius is limited, and the company is choosy when it comes to contracting potential advertisers." Here's a bet. Call Sirius. Tell them you want to drop $50,000 on an ad campaign for swiss cheese, talcum powder, or old Coke bottles. Odds are you'll be placed in their chosen advertiser group.

There's no lack of - uh - testosterone at Sirius, nor is there any lack in its ability for creative writing. But statements like those found on this press release are the kind that should make any competitor react. In this case, broadcasters should respond with a conjoined effort to let Mr. Perry take 100% of his advertising dollars to Sirius, and see if there are enough people in the audience to keep him happy.

4 million people subscribe to Sirius. Do the math: With over 100 channels available, how many persons are tuning into any single channel at a given time? How many persons are Sirius subscribers, in say Cleveland, Ohio, out of the 1 million+ in its ADI?

Howard Stern is the big draw. However, it's still accurate to say that every other channel is building its audience. Even Howard isn't impressed with numbers of "fans" who followed him to Sirius. (See next story.)

We're still dealing with individual-channel audience numbers that couldn't possibly be better than those of a small (or at best) medium market radio station. If they were, Sirius would be plastering the numbers out in multiple press releases. Also, all of these Sirius channels have their audiences geographically stretched across the nation; so the "potential" advertiser pool is limited to those with a national distribution system.

In the past the Sirius PR department earned a reputation for bravado. Today, it's also showing a knack for BS. Broadcasters need to shove back by showing Mr. Perry and his product the door. Read more!