LPFM Proposals with Kevin Fodor

A lot of us saw this coming - Low Power FM stations are seeking more flexibility in operations and some protection for their licenses. Two petitions are before the FCC, asking for power increases, the right to sell commercials, and even to buy and sell LPFM licenses. Kevin Fodor, Program Director for Gray Fox Broadcasting, talks with Chris Tobin and Kirk Harnack about the proposed changes for LPFM.

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Kirk Harnack: This Week in Radio Tech, Episode 272, is brought to you by the Axia DESQ and RAQ IP-audio mixing consoles, six-fader AoIP consoles with big-console features. By the family of Z/IPStream audio processors and stream encoders, including the astounding Z/IPStream 9X/2. And by Lawo and the crystalCLEAR virtual radio console. CrystalCLEAR is the console with a multi-touch touchscreen interface.

A lot of us saw this coming. Low Power FM stations are seeking more flexibility in operations and some protection for their licenses. Two petitions are before the FCC, asking for power increases, the right to sell commercials, and even to buy and sell LPFM licenses. Kevin Fodor, Program Director for Gray Fox Broadcasting, talks with Chris Tobin and Kirk Harnack about the proposed changes for LPFM.

Hey, welcome in to This Week in Radio Tech. I'm Kirk Harnack, your host. Glad to be here, and it's our Episode Number 272. I guess eventually here we're going to reach 300 episodes. Wow. When are we going to call it quits? I don't know. We just keep on going, I don't know about forever, but I can see myself doing this into my old age. Maybe we'll have to update...

Chris Tobin: Why not?

Kirk: ...the name of the show, though. Hey, we're here on our 272nd episode, and I'm Kirk Harnack, along with Chris Tobin in New York, and also Kevin Fodor is with us. He's our guest and we'll get to Kevin in just a minute. Hey, Chris, how you doing? Welcome in.

Chris: I'm doing well, thanks. As you asked before, the weather here in New York City, it's 89 degrees Fahrenheit, 32 degrees Celsius, and the humidity is 39%, dew point's around 60. It's quite sticky and uncomfortable if you're running about. Today is a T-shirt and shorts kind of day, with sandals.

Kirk: All this interest in weather has gotten me interested, too. I've purchased a new weather station, one that I can actually do something with. My friend... well, Tom Churchill, the guy that we had on last week, on the show, Tom suggested this ambient weather unit. It's not as professional as the $500 and $600 units. It's $116 on Amazon. The reason I bring all this up is that now it's reporting to Weather Underground. So weather at Harnack House, in Nashville, Tennessee, is being reported about every two minutes to Weather Underground.

It's 91.8 degrees here at Harnack House, dew point is 65. And if you go to... well, I'll put a link in the show notes, how about that. We'll put a weather link in the show notes.

There's also a webcam, I've got that running. It's not on the Weather Underground page yet, but it's available separately, and I'll stick that on the show notes as well, so you can go look at the webcam of the skies here at Harnack House. Yeah, it's pretty similar here. It's hot and sticky. And Chris, after the show, do you have plans for tonight?

Chris: No, actually I don't.

Kirk: You don't? Usually I don't either, but tonight, I'm going to the ball game.

Chris: Oh, aren't you lucky.

Kirk: Yeah, the Nashville Sounds, Triple-A team, they're going to be... I forget who they're playing tonight. But I'm taking my son there. My wife and the foundation she runs is throwing a little shindig there for pediatricians and residents and students and things like that, so we're going to go party while the pitches are being thrown.

Chris: Excellent. This is always great weather for a ball game, and a ball game's always fun to go to, Triple-A or professional, so it's perfect, enjoy it. Definitely enjoy it.

Kirk: I'll post on the pic on my Facebook page, but the Nashville Sounds have a new stadium, and their stadium for years has been famous for having a guitar-shaped scoreboard. What else would you expect from Nashville, right?

Chris: Exactly. That's great, I love it.

Kirk: I'll stick that on Facebook. Any of our viewers, listeners, if you don't... Hey, you ought to follow the show. On Facebook, just look for This Week in Radio Tech, or TWiRT, you'll find it right away. If you...

Kevin Fodor: If you're on Facebook, This Week in Radio Tech is where this is actually coming from.

Kirk: I hear Kevin speaking. Hey Kevin, we'll bring you in in just a second.

Kevin: With This Week in Radio Tech.

Kirk: Let's go ahead and bring Kevin in now. He's talking... Kevin, how are you? Glad you're here.

Kevin: I'm doing good, Kirk. How are you?

Kirk: I'm terrific. You're our guest for this evening, and you're going to be talking about Low Power FM and a couple proposals that are before the FCC and rationale behind some of the things that LPFMs would like to see changed in the law. Have I got that about right? You're going to talk about that?

Kevin: Yeah, I would say that's pretty close.

Kirk: Okay, good deal. Hey, I've got to tell everybody, our show is sponsored by three different sponsors, and we're going to talk about one of them right now, before we just jump right into our conversation with Kevin Fodor.

One of our sponsors is Axia and the Axia DESQ, that's D-E-S-Q. Isn't that a fancy... that's the IKEA spelling, right? The DESQ, the DESQ console. There it is, there's a picture of it, right on screen. And really, really beautiful little six-fader console. Now, this console works with the Axia product called the QOR, Q-O-R, the QOR.16 or the QOR.32, and here's what's even cooler. You can plug two of these consoles into a QOR.16 or a QOR.32 and have two completely separate work surfaces. They don't interfere with each other. if you've got two work stations, two little production rooms, an LPFM station and a production room in the room next door, you can have two inexpensive consoles, these little desk consoles, plugged into a QOR.16 or a QOR.32.

Now the QOR.16 and the QOR.32, those have built-in mic preamps, analog inputs and outputs, AES inputs and outputs, all the things that you need. Plus each one of them has an Ethernet switch on the back, and that carries all your Livewire. And it'll be AES67 compatible, so you can get all those ins and outs going that way as well.

I've installed one of these, actually the sister to this, the RAQ, the R-A-Q RAQ console in American Samoa, in our newsroom. Fantastic little console. I tell you what, before we plugged this in we were always breaking cables and the news lady would have hum and pops and clicks and we just had an awful little analog console there. Keeping that thing maintained was tough in a news environment where they're throwing pens around and papers everywhere and stuff under the board.

You move to an AoIP environment, Audio over IP environment, and those audio problems just go away. You have short audio cables, they plug into the back of the unit or to a node somewhere on the Axia network, and now we have really crystal-clear audio between the newsroom and each of our control rooms. It was so easy to plug in, literally one cable from the rest of the Axia system into the newsroom and bam, it is hooked up, sources available, sources being sent both directions. It's really an awesome little console.

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All right, so Chris, we have our guest here. It came to my attention a couple weeks ago, because the comment period for some LPFM proposals before the FCC, that comment period ended a few days ago, the end of August. And so Kevin Fodor is here. Kevin, welcome in, glad you're here, buddy.

Kevin: Well, thank you very much for having me. I'm very happy to be here today.

Kirk: So Kevin, you look like you're in a classroom. You've been chatting with a student or two there. Is that where you are, in a classroom?

Kevin: Yes, actually I am in the radio classroom here at the International College of Broadcasting in Dayton. It's a couple of things that I do for a living here. I am a professional commercial radio broadcaster with the stations of Cox Media Group here in town.

I do the LPFM thing as a sideline, and then I also teach radio broadcasting and have actually written and rewritten the course over here. An interesting thing about the school here is the fact that not only am I an instructor at the school, but I graduated in its forerunner, which was the International School of Broadcasting. and that was established in 1968.

Kirk: Wow. So the school that you teach at, it's again called the what? International School of what?

Kevin: International College of Broadcasting.

Kirk: Oh, College, yeah.

Kevin: It's a two-year associates degree, fully accredited course, that very soon we're going to also be adding social media to the mix as well as radio and television and video.

Kirk: Got you, okay, all right. So next time I come to Dayton I need to stop by and see this. I did not realize that there were still, in the U.S., colleges specifically dedicated to broadcasting. And Dayton seems like a great place to have this. How long have you been teaching there?

Kevin: I've been teaching here probably about seven or eight years now.

Kirk: Now years ago, I sat in on a high school class that was broadcasting, when I lived in Memphis, Tennessee. I was a contract engineer. They had a little radio station there that they ran a few months out of the year. I think they were supposed to run it on full time, but they didn't. I sat in on a class, and I didn't speak up, didn't say anything, but honestly, what was being taught as far as best practices for commercial broadcasters and FCC rules and regulations concerning broadcasting, what was being taught didn't have a lot of basis in reality. It was a lot of old information. How do you keep your information up to date so that your students are getting current information?

Kevin: Well, first of all, our college is instructionally a member of the Radio Advertising Bureau. We are a part of the Ohio Association of Broadcasters. Both instructors of radio here, I do the night classes and the head of our radio department, Tommy Collins, does the day classes. Tommy has been a 30-plus year broadcaster. He just recently left our employ at Cox Media Group. Of course I work full time in broadcasting.

It's interesting that you mention the FCC rules and regulations, Kirk, because one of the things that we are doing here is also hooking in with the Society of Broadcast Engineers. And very shortly, we are going to be teaching the SBE operator certification course.

We know that there are radio stations certainly that teach basic rules and regs to their new employees or their new hires, but I have always thought, and we think here at the school that, when you teach something like the SBE course, if the students could have that certification, it's almost like... We also offer a recording engineering degree here, and if you have a pro tools certification, it can help you.

So likewise for the radio program, we think if you have SBE certification as an operator, at least it might make the chief engineer smile when you go in for a job interview.

Kirk: Cool. I commend you very highly for that, that's awesome. I'll put this in the show notes, but if folks are interested in the International College of Broadcasting, the web address is ICB.edu. ICB as in International College of Broadcasting, ICB.edu. But I hadn't looked at that website yet. Thanks very much for telling me about that.

I only introduced you as being a professor, a teacher there, to then move into the fact that you've got some broadcast experience, you teach this stuff, apparently what you teach is up to date. So we ought to jump right into the LPFM realm here. And I want to invite Chris, please jump in here at any moment.

I'm a commercial broadcaster. I own some radio stations. They're all full power stations, although we own a couple of translators here and there. We have some stations in American Samoa and in a very rural part of Mississippi, in the Mississippi Delta. And I've always thought that when people complain that broadcasters are abandoning localism, and we hear that a lot, we hear evidence of that a lot, I always thought that didn't apply to me.

Because we have stations that, yeah, there's a lot of voice tracking, a lot of it we do ourselves, there are local live shows, but we also bring in the Rotary Club, the Lions Club, we do auctions, we have local news, although interestingly, it's not actually done in our towns, but we feed the news to another guy and he does it.

We have a very efficient operation, and some people don't always think that efficient means as good as it could be, but I promise you, you listen to our stations and you just know that they are local stations and you feel that they're local people.

So that all said, I've always thought like, man, all this complaining that the LPFM guys do, that doesn't apply to me because we run stations that sound awfully local.

Okay, so that said, I maybe, I guess I commend LPFM guys for working to get something on the air and provide some localism. We've got a great LPFM here in Nashville, Radio Free Nashville is on the air here. I've helped them out with a little bit of engineering help. But I know that there are plenty of commercial broadcasters who look at LPFMs as just a bee buzzing around. Really, guys, come on. You're not real broadcasters.

So Kevin, give me your take on this because, you can find examples, in any realm, of great commercial broadcasters and not so great. You can find examples of great LPFM operators, and I think you're part of that, and LPFM operators that honestly are not so great, it's some guy wanting to play his MP3 player in his basement.

So give me a little bit of your view of LPFM over the last 15 years and where we are today with it, and then we'll get into what these proposals before the FCC are asking for.

Kevin: Well first of all, your comments are right on, Kirk. There are still commercial radio broadcasters that do a wonderful job of serving their communities, and nothing that I say should be considered as criticism of those particular stations. There are also LPFM operators around the country that, whether it is through maybe not just knowing what they should be doing or perhaps outright ignoring the rules, are also not doing what they should be doing.

I got involved in LPFM, but I, too, am a commercial broadcaster, and I heard both good and bad stations, like you. I heard stations that were doing a very good job of offering programming, and then I heard, like you suggest, the guys who want to play 20,000 songs and they think that they're going to get a gigantic audience by playing lots of songs that nobody's ever heard of. Ten after three or four years trying that, they're trying to figure out why they're not getting more financial support in their community than they are.

So I wanted to get involved in LPFM, because I wanted to see if an LPFM station, programmed professionally - and by the way, when I say professionally, I do not mean exactly like a commercial radio station - but programmed professionally could pay its dues, be able to pay its bills, and maybe be able to make a little extra money at the end of the day to be able to put back into their business. So I got involved with this company, Gray Fox Broadcasting, which operates two LPFM stations that are about 70 miles from where I'm sitting right now in a resort community of about 1,500 people in central Ohio or north central Ohio, if you will.

It's one of the first LPFMs that was actually licensed, or among the first. It's WRPO-LP 93.5 in Russells Point, Ohio, and the station had come on the air right at the beginning of LPFM as a big band station. The station actually did quite well for several years doing the big band format. They played old records. Not everything was CDs and computer files and all of that. Like I say, did quite well for several years.

Then the format started to wane for them and they tried for about a year, year-and-a-half, to do smooth jazz, which let's face it, even in a big market, smooth jazz is, at best, a niche format. The problem that I think they found was if you have a smooth jazz station and it gets maybe a 2 share or a 3 share of metro market, now take that down to a city of 1,500 people and that 2 share doesn't mean you count a lot of listeners.

So the gentleman at Gray Fox Broadcasting was trying to find out what the community wanted him to do. He commissioned the church that is across the street from the radio station to do a survey. They called 100 households in this community of 1,500 people, and it was not a totally blind survey. He wanted to judge some perceptual things about the listeners' attitudes about his station. But the final question in that survey was, "Is there some kind of music that we are not offering you that, if we did, might encourage you to listen longer?" Fifty-eight out of 100 households said rock and roll oldies.

When Gene shared that with me... Gene Kirby, the general manager... I looked at him and I said, "Gene, I've been in commercial radio for almost 40 years now and I know commercial radio operators who would sell their mothers into slavery if they had a similar study that showed that 20 out of 100 would indicate a particular format." But here he had almost 6 in 10, and I said, "You need to be playing oldies."

So we formulated a playlist utilizing largely what I guess anybody in radio would call poor man's research and we put it on the air about four, maybe four-and-a-half years ago. By the second year, the radio station was meeting its expenses and by the third year, we were certainly turning enough "profit" that it was able to go back into the business.

Since that time, we have also hooked up with another community six miles from Russells Point that has also licensed an LPFM. WRPO, by the way, licensed to the village of Russells Point, Ohio. The new village is the village of Huntsville, Ohio. They have WOHP-LP at 101.3, and we are running the programming for both stations, presently doing a simulcast.

Kirk: So you simulcast one station on the other. Now one question that people would ask is okay, well, how does that serve the community if you're simulcasting this other station? And I don't want to get into the nitty-gritty of that, but I think you've got a quick answer for that.

Kevin: Yeah, we are six miles apart, and our communities are close enough that when we do local news, when we do local weather, and so forth, it's all indigenous to what we call the Indian Lake resort region. So the news for Huntsville is also news that people in Russells Point are interested in and vice versa, so it all works out very well.

Kirk: Got you, got you. So let's talk about a few things that LPFMs are constrained by right now. My feeble imagination reminds me that LPFMs are pretty low power, 100 watts, 100 feet off the ground, so the coverage area is probably only two or three miles. They, what, nonprofit and there's different things about that. Can't sell commercials but can take underwriting money as long as they're not commercials.

I think we all have a pretty good sense of that from the public radio realm, where you can run announcements but they can't ask you to take an action or make an on-air comparison . . .

Kevin: Correct.

Kirk: …that kind of thing. What are some of the other things about LPFM that constrain them, either financially or signal-wise or however?

Kevin: Well, the very first challenge for a lot of LPFM stations is getting, particularly if they intend to offer underwriting to businesses, is to get the businesses to understand what underwriting is.

Naturally a business comes to you and, "Oh, radio, well, I want to say this, this, and this," and you have to go, "No, wait a minute, you can't say that." You kind of have to explain. And I think the way that, we don't like to use the term advertising, but I think it is appropriate, even though we are not a commercial entity.

An underwriting announcement could be compared to a business card, and basically with underwriting you're allowed to give the business's name, address, telephone number. Web address is considered okay because it is the online address of the business. You can also offer a brief, non-promotional description of the goods and services that the business offers, and the FCC does also say that you can, if the business has a slogan that it has used for six months or more, that is again, non-promotional or comparative in nature, you can also use that.

Some radio stations, some LPFM stations, will slip a music bed behind some of those announcements, nondescript style, and I don't have a problem with seeing that happen. There might be some wags out there in the commercial broadcasting community that would say, "Oh, that's too much like a commercial." But the fact of the matter is we're not doing it for promotional purposes, we're doing it to make the announcements more listenable. But outside of all of those entities... oh, and you have to keep them under 30 seconds in length. So that is the whole thing about underwriting.

Kirk: Wow. Okay, all right. What about, give me a couple examples of the programming constraints. What are you required to do, what can you do, what are your options? Not necessarily what you should do, but what do you have to do?

Kevin: Well, typically the spirit of LPFM indicates that you're going to offer the community the opportunity to have a microphone, which means if you're going to do a format or offer a particular type of music, you certainly can, but you're also expected to be able to offer programming that allows for different tastes.

All the LPFMs that I am involved with, I'm actually involved with a total of three, all of them do that, whether it is in the form of live sports broadcasts, high school, college sports, whether it's talk shows, whether it is local entertainers coming in to perform, or whether it is programming music that would be ethnically diverse.

I know that one of the LPFMs that I work with has a gentleman who's a big fan of the station, who is Native American, and he is working on a program to come in and play Native American music for an hour a week.

So we try to offer programming that is diverse, and again, small town radio is what our stations are primarily doing, right now.

Kirk: What do your stations, that appear to be well run and serving the community, what do the local commercial broadcasters, what do they think about you?

Kevin: Well, you know what? I actually am on fairly good terms with the gentleman who owns the nearest local commercial broadcaster up around the Indian Lake region. So even though he kind of casts, I guess you might say casts a wary eye our direction, he understands, I think, that we're not a giant threat to him and that we're not out there to try and steal all of his business. So he generally has a live-and-let-live attitude toward us up there.

The situation in the other city, of the third LPFM, as I was kind of mentioning to you last night is a very unique situation. It pains me to see what's going on down there, because the city that I'm talking about is where I started my broadcast career, in October of 1974, on one of those stations.

There is a full power AM daytimer and a full power, 3 kilowatt FM station in that town. The commercial broadcaster was sold a number of years ago to a group that owns a station in suburban Dayton. They have combined a number of daytime AMs together so they can get a reasonable amount of coverage in the Dayton metro market. They are programming largely to that market.

The businessmen in that community complain very mightily to me about what they do, and I've had a number of the businessmen tell me this directly. "The only time we see anybody from that commercial radio station is when they come into town once a year to sell their broadcasts of their coverage of the county fair." They say, "And then we never see them after that."

The FM station, which is where I started my career, was sold to a minister, who has since passed away. But they are now a non-commercial religious broadcaster.

Sadly, there is no studio for this station. If you look up their call letters on radio-locator.com, the telephone number listed for the radio station is a Sacramento ZIP code. As I understand it, the people who have had contact with the present owner of the station tell me that that person has indicated to them they have no desire whatsoever to put any local programming on the station. It is merely a satellite dish at the transmitter site.

Kirk: Well, there's room in the rules for those, but yeah. Chris Tobin, what do you think about... we're just trying to set the stage here so we kind of are on the same page with what LPFMs are, for those of us who don't know much about them, other than okay, that's that 100-watt guy over there. Any of these in New York City?

Chris: Good question. I don't know if we have any Low Power FM. We have a lot of community stations that circle the city itself. I have to look that up. But you can't forget that Low Power FM, the concept, the class of radio station, was put forth back in what, 2000, if I remember correctly. Part of it was because of the 1996 Telecommunications Act that allowed the ownership caps to be lifted in the industry, the radio industry.

As a result, the LPFM movement, the whole licensing approach, the class of operation it is, was put together in order to sort of be an alternative to radio homogenization that was taking place.

So as a result of an act of Congress in 1996, the industry decided to shuffle around and become consolidated because it was a better business deal. As a result, programming suffered. Now, FCC doesn't usually regulate programming, they regulate technologies or the standards that implement the technologies. So the LPFM approach should be taken with hey, because of consolidation, because of the fact that you now have these satellite stations, if you will, and there, because of the, how would you say? The ruling that was put forth in 2000 was crippled and the lobbying against it from the NAB and others, Congress passed it through and it was not exactly the way they probably should have done it. That's the way it works in any political arena, you have lobbying and you see what comes of it.

So I think the LPFM approach should be, hey, make them a class of operation if they're an alternative to what's going on because of an act that took place, a rule that's on the table, maybe [inaudible 00:31:29] that is, rulings that say "Hey, if you're going to do commercials, here's the limitations. If you're going to do this, here are the limitations. Technology-wise, or the technical aspects, maybe 100 watts is okay, but the height restriction should be lessened or reduced, or the restriction, that is, maybe go higher, maybe allow a certain footprint." These are things that should be looked at and discussed because it's an alternative. That's why they introduced it. That's why it was there.

But because of lobbying and efforts of the others who didn't want the competition... As we mentioned earlier before the start of the show, Kirk, you made the remark about taxis, medallions here in New York City, and many other cities as well, and the alternative transportation services that have come out as a result of the years of medallion services and the way things went.

Well, look at the LPFM and the years of commercial broadcasters and where things have gone. I think that's where we should think about these things, and really consider it. And maybe there's an argument that can be made and justify it, as Kevin points out, and say hey, more should be done. But why should a radio station only come out to your community once a year because of a state fair?

Kevin: Chris, you might be interested to know that I believe you do have an LPFM that is actually showing up in the Middlesex borough book. This was just online the other day, the station was showing up like a 0.36-plus.

Chris: Okay, Middlesex, New Jersey.

Kevin: Yeah. So yeah, you definitely have them around there, and I was listening to them online and they sound very slick. They're an oldies station, but the live morning show, the guy's giving traffic information, the guy's bringing people, from the community, in to talk with him. They were doing community announcements and that sort of thing.

As a programmer, I could nitpick here and there, but for what they're doing, it actually sounded pretty good, online.

Chris: Well, yeah, but see that's what you're talking... here's you just commented. Here's a Low Power FM, as we'll use the moniker. I would just say it's an FM station or noncom rather than saying low power and sort of demoralize people thinking of it, and say hey, here's a station that sounded presentable. You call it slick. And why do they sound presentable? Why? They're serving a need or a purpose or an alternative to what is not being provided. That's the genesis of broadcasting from the early days.

If you want to go back to the days of KDKA in 1929 and all the others around the country, that's what it was. Whether it would be farm reports or weather reports of the day, or today, now it would be maybe music or a certain genre or style of music. That's what it's about, and that's how it should be treated.

I think to just say commercial broadcasters look down on you or you have a weary eye of a guy across town, it shouldn't be a weary eye. He should be looking at you and going hey, this guy is stirring the pot because we all share the same end user.

Think of the Internet and what the Internet has done for end users of consumption of content, of materials. Radio has gone through the same thing, whether it be FM noncom or FM commercial. I think Low Power FM has a place and should be approached in that fashion, and maybe the technical restrictions should be modified, should be more beneficial to fill in the radio homogenization that's taken place as a result of the Telecommunications Act of 1996. Just my opinion.

Kirk: Good conversation. You're watching or listening to This Week in Radio Tech, Episode Number 272. Our guest is Kevin Fodor, he's talking about LPFM. And we're going to get to, next, what these proposals are about, before the FCC. Two different proposals have been made, many, many pages long, LPFMs want a lot of things.

How do we feel about that? What are those things that they want? Do they want to be protected in certain ways, as regular licensed commercial stations are, and a few other things. We'll get to that in just a minute.

Chris Tobin is with us from New York City, I'm Kirk Harnack, and Kevin Fodor is with us as well to answer these questions and talk about LPFM. So that's coming up.

Our show is brought to you in part by my friends at Telos and the folks who are now making the Z/IPStream software. If you are a station that is broadcasting over the air, whether you're an LPFM or a full power station, or whether you want to have your own Internet radio station... there's some free software out there that kind of, sort of, gets the job done. Hey, if it's free, I promise you, they're not using reference computer code, licensed code, to make the encoded stream. It may play back okay or it may not play back okay. But for streaming, what you really want to do is have a combination of audio processing and stream encoding.

Then there's a lot more things that go into it other than that. But let's talk about audio processing for a moment. Audio processing for FM is different from processing for AM, and that's not just so the processing manufacturer can make more money. They are genuinely different transmission schemes, each with their own quite different constraints and foibles and strengths. Well, that's why an AM processor doesn't sound so good on an FM station. Neither one works that well on an HDTV station.

None of those work all that well, or as well as they could, on a stream. What's different about an Internet stream? Well, you're dealing with coded audio. You're dealing with audio where an encoder is going to try to pull out audio that doesn't need to be encoded. So if you process this with a smashed-up-against-the-top clipper, like you have with both AM and FM... With AM and FM, you can do upwards of 10 dB of clipping and it doesn't sound that bad. It's the nature of the way things get rolled off and constrained.

But when you do clipping and you feed that clipped audio into a psychoacoustic encoder like AAC or MP3, you've got a problem. You've got square waves going into an encoder that's trying to get rid of audio that can't be heard. So what you really need to do is multi-band audio processing that is... Well, you can do something fairly aggressive, but you sure can't do any clipping. You also need to do look-ahead limiting, and that's the kind of audio processing that's in the Z/IPStream products, whether it's the hardware Z/IPStream like I've got here in my office, or software Z/IPStream like the Z/IPStream X/2, which runs on a Windows platform as a service.

These products have processing that is made specifically to be followed by a psychoacoustic encoder, a streaming encoder. And then, in the same box, in the same software, you've got those streaming encoders. So for example, Z/IPStream X/2 is the one I'm talking about here. It is a less expensive product from the folks at Z/IPStream, the Telos Alliance. It has a three-band audio processor, got its roots back with the original Omnia-3 processor, and a look-ahead limiter that Frank Foti and others designed.

It's really intelligent. It's an intelligent look-ahead limiter, it's just awesome. So you can adjust the audio in several different ways. You can adjust the audio in several different ways. You can get exactly the signature sound you're looking for. And then after that, you've got encoders. You've got MP3, different flavors of AAC, and all kinds of bit rates, too. If you want to make a stream that's MP3 at 128 kilobits, no problem. If you want to simultaneously do other streams, you can do that too.

That's one of the really interesting ways that Z/IPStream X/2 serves you, the guy who's going to buy it and install it. If you buy one license of the Z/IPStream X/2, you bring one program audio into it. But you can process it different ways and you can encode it different ways, up to the limit of that PC's CPU.

Now, I've got a PC under my desk here that I've processed 20 different programs and encoded 40 different streams at the same time, and it's a basic gaming PC. So my point is that you can do a lot with Z/IPStream X/2 running on your PC.

So you do processing, you do encoding, and you can do not only several different end codes, several different formats and bit rates, each of those then, you can then export, you can send out to multiple different locations. So if you've got a Wowza server that you're streaming and you're streaming also to an Icecast server, and maybe you're using a content distribution network over here and a different one over there, you've got backups, you've got redundancy, you can do all that with the same software. Just keep adding to them.

At my stations, we're using this software, and so we have a little SHOUTcast server in each one ourselves as a confidence monitor, so if it ever goes "off the air," off the Net, so to speak, we can check it at the CDN, we can check it locally as well, right off the machine that's producing it.

There's also metadata, and we've just recently implemented this at our stations in Mississippi that we're putting title and artist on them now, and that's great, that's an amazing thing to have, so we've got some help doing that our of our Rivendell system.

I mentioned earlier that Z/IPStream X/2 runs as a service, and that's pretty important. It runs in this low-level mode. It's not an application that has to come up and run, it's a service, so it's almost part and parcel, not quite to the kernel, but you know there are a lot of services that run in a Windows machine, and the Z/IPStream X/2 comes right up and runs as a service with the others.

Now if you want to observe it, if you want to adjust it, make changes, watch the metering and so forth, then you just open a browser, and you browse right into the service that's running on the same PC.

I love this software. You can get the X/2 software with the three-band processor. If you want to just go all out, get the Z/IPStream 9X/2. Costs more, but it includes Omnia.9 processing. We've got that on a few of our stations as well. It's just amazing.

In fact, on the website we're going to put up a link in the next few days that you can listen to my stations online and hear other stations as well, processing both with the basic three-band and with the Omnia.9-style processing by Leif Claesson.

So much to tell you about, this is just amazing software. And bottom of my heart, I mean folks, this is good stuff. We run it and love it. Go to TelosAlliance.com, TelosAlliance.com and look under Omnia and you'll see Internet coding and streaming and processing and look for the two different products. The Z/IPStream X/2 and the Z/IPStream 9X/2. Love the stuff.

All right. Thanks to Omnia and Z/IPStream for sponsoring This Week in Radio Tech.

All right, we're talking here on This Week in Radio Tech with Chris Tobin in New York and Kevin Fodor in Dayton, Ohio. Kevin, we were going to get right into what these proposals are. Now I know we've been saying that the whole show.

Let's see if we can bullet point some of the things that LPFMs are asking for from the FCC, things that they don't get now, that they want.

Kevin: Well, the one thing that both proposals talk about is a power increase to 250 watts. Now it gets very controversial when you get some of the bigger broadcasting groups, it raises the blood pressure of some VPs real quick. But the fact of the matter is, the original LPFM proposal that Chris alluded to earlier, way back when in 2000, was for commercial operation at 1,000 watts.

If you do the engineering on the differences between 100 watts and 250 watts, the old engineering adage. I am not an engineer, I am just a broadcaster who had engineer friends, is that if you double the power, you half the distance.

So with LPFM stations at 100 watts, you have a station that might get out on a good propagation day somewhere between 3 to 5 miles. And by the way, only about a mile of that, a mile-and-a-half of that can be heard on a stationary table radio. So you're talking about maybe expanding the distance that you can hear that station on a stationary radio about 3 miles, and in a car, it might get 7 to 10 miles of reasonable coverage.

I'm sorry, I have a college textbook not far from me here in this classroom that defines the Class A FM, 3,000, 6,000 watts, typically can get about 20 miles, and can be heard at least a good solid 10 miles or so on a table radio. So gee whiz, I don't think that where a station would fit at 250 watts, that's that big of a deal.

Kirk: Talk about being able to go up in power to 250 as a blanket or only if the contours don't interfere with other stations?

Kevin: Only if the contours fit.

Kirk: Okay, okay, all right.

Kevin: Then one of the other proposals talks about the... well, and by the way, in both cases, both proposals, neither talks about an increase in tower height. They're happy to stay at 100 feet. That's kind of sad in a way, because one of our stations here in town has an 80 watt translator that's up at 900 feet on a tower, and if we didn't have a directional antenna on it, it would get to Cincinnati. As far as the other proposal, and by the way, one proposal from the folks at REC Net, the other one through LPFM-AG. So the power increase is one of the more controversial ones.

And as is, I think the LPFM-AG proposal, which has already pins and needles thrown it by the NAB the other day, and I understand why they're getting it, but I think they do speak to some very important points when it comes from somebody who's operating or working to operate an LPFM station at a local level. It asks the Commission to consider making LPFM a primary service. As of right now . . .

Kirk: Yeah, explain that. It's not a primary service now, which means your license isn't guaranteed?

Kevin: That's correct. If a station wants to, they can pick up the phone, call you, and say, "Hey, I want to put a translator on your frequency. Goodbye." And at that point, years of work, 50,000 maybe, who knows, maybe more than that may go down the drain. It typically costs someone or an organization or benefactors anywhere from $20,000 to $50,000 or more to get one of these stations on the air.

Oh yeah, sometimes you have to get into the legal battle, too. The station down in Southwestern Ohio that I work with, the minute they filed their application of broadcaster, commercial broadcaster, 90 miles away filed an objection saying that the LPFM would interfere with their fringe contour, which was in another state. Now it's like, "Come on guys, 100 watts just doesn't do that."

Of course, granted the FCC kind of laughed that one out, but still the LPFM operator had to hire an attorney, file the paperwork, answer the objections. Clearly, LPFMs have dealt with broadcasters who are doing nothing but trying to eat up all their money so they can't get on the air.

Kirk: Well, and I've got to point out that that happens to commercial broadcasters, too. I've applied for licenses and had just completely specious objections filed against them. Of course the objections were tossed right out, but we had to pay for an attorney, too. I guess anybody can object for any reason, but then you have to go get represented to say look, FCC, this is obviously specious. And it was, nd pffft, toss that away.

So that's typical efforts to slow people down who are going to compete with you, and that's how we get things done or prevent them from getting done.

Kevin: True.

Kirk: So that's not exclusive to LPFMs, but yeah, I hear you. So a power increase within contours, no height increase. Making it a primary service, so once you get a license, you're locked in, you're there. Now that's not to say that somebody couldn't move you if shuffling of frequencies would help out.

My business partner in our stations has done that numerous times to increase... and it always ends up increasing coverage of signals over people, because that's what you pretty much have to show.

So an LPFM, just like a commercial station, could be ordered to show cause why they don't have to move in order to make things better, so that could still come along. What about selling an LPFM station? That can't be done right now, right?

Kevin: No, it can't be done right now, and I do believe that the LPFM-AG proposal does have a codicil in it that would allow the sale of a radio station, but it's only after a number of years. So in other words, you couldn't get in the business of buying and then I guess "flipping" might be the term, an LPFM station.

Kirk: Well, you can flip it, but you've got to run it for a few years.

Kevin: Right.

Kirk: And okay, I get that. Honestly, I wouldn't have an objection to it being flipped. Well, on the one hand, when you have something that you've paid for, you're more likely to take care of it. It's more valuable, it's more precious to you. On the other hand, the idea here is to serve local communities. You don't want to turn these into little mini 80-90 docket stations...

Kevin: Exactly.

Kirk: ...where back in the '80s, it was thought that hey, we're going to have stations that serve local communities. We're going to open up a whole bunch of, basically a lot of Class A stations, 3,000 watts. We're going to give preference to minorities, and we're going to serve local communities better.

Well sure, a lot of those are on the air and happily programming and doing it with the original intention. But also a whole lot of them were obtained by minorities and non-minorities and in pretty short order flipped to, sold them to larger companies. They were moved in, moved here and there. The local community that had been set up to, we're going to get a radio station, once again, isn't served.

I guess my question, in setting this up like that, and I'm not saying it's a bad thing, but what's to prevent LPFMs from becoming little mini 80-90 Docket stations, more of them coming on, now you've got a guarantee that you've got the license because it's a primary, it won't go away. Now you can sell commercials, and now you can sell the thing, and now it's going to still move into the "community of financial interest" rather than the community of license. What's to prevent that scenario from happening, kind of, all over again 30 years later?

Kevin: I would have to suppose that that might be a possibility, but you know what? That's for the FCC to determine, and that's well above my pay grade.

Chris: It's a rule making, that's part of the rule making process.

Kevin: [Inaudible 00:52:10].

Chris: It's the same rules that said 30, 40 years ago that you had to maintain a profitable operation before you offloaded it. Maybe you bring that back in its modified form just for the LPFM approach, say you have a window.

Kevin: Remember too, Chris, back in the early days, when you applied for a radio station, you had to show that you had the financial wherewithal to operate it for three years.

Chris: What a concept.

Kevin: You don't have to do that anymore.

Chris: No, you don't have to do that for anything anymore. You could have $20 billion in debt and still put in and get a loan and buy things. So yeah, why not.

Kirk: I think it's what [inaudible 00:52:44] doing right now.

Chris: Yeah. But the rule makings, that's what the FCC is about. But that's what's happened, everything has fallen apart. I think if the LPFM groups or movement was to look at that and say hey, you know what? Maybe we say five years you have to hold onto it before you let it go and then maybe have a rule or have a procedure for that. This way you can keep the local alternative to the radio homogenization that took place. Who knows? There's a lot of things you could probably take and do with it.

But I still don't believe, and I agree with Kirk as an open market-type thinking, we shouldn't be treating the LPFM as just a sore on the back of the elephant or something to that effect or the broadcast industry. It should be really treated to how's the end user going to consume it, what's going to happen, how do we serve the community at large? So that's . . .

Kirk: Kevin, maybe you can tell me if my next question is addressed in either of these proposals. LPFMs want the ability to sell commercial advertising time. I don't really have a problem with that. Some commercial broadcasters would say well, here's a scenario. LPFM operator goes into the Mom and Pop store and says hey, we'll sell you ads for $1. That commercial station's charging you $10. And Mom and Pop store, they may very well think that all radio stations are about the same, have the same coverage and the same amount of listeners.

So then it makes the commercial station go back and say wait a minute, you bought commercials from LPFM for how much? Of course, because they only have 72 listeners. We've got 7,200 listeners, and we can show you that.

So I guess what I'm saying is it may increase the workload on salespeople from existing radio stations and they may feel more of the irritation factor, they're letting this LPFM sell commercials, hitting on my clients now, that it's hard enough to sell them. So that's one objection.

But I guess what I was getting at is the bigger question of if an LPFM can sell commercials, then seems like you ought to also allow anybody, including existing commercial operators, to own LPFMs. What do you think about that notion?

Kevin: Well, again, that would be something that would have to be the FCC to answer. I suppose that could be possible. As far as commercials on LPFM go, though, I have always said that, as a broadcaster who's been in this business, again, 40-plus years, I don't have at basis an objection to that.

But as to whether that can be legally done or easily done or done without amending a rule in Congress like the Local Community Radio Act or so forth, again, I don't know. That's for the FCC to figure out.

As someone who works in the LPFM movement, we're prepared to deal with it either way. You can get people to underwrite your radio station. The one thing I will say is that there are operators out there that would like to be able to have a news service, that might like to barter a jingle package, that might like to be able to have imaging libraries so that they can make their announcements sound better or at least to have some generic production music.

Let's take it even a little further, to have a news service, to have a weather service. All that stuff is out there for barter. There's syndicated programming that you can have out there for barter, and right now all of that is locked out to LPFM stations.

I do believe the LPFM-AG proposal does have a codicil that like, I think, at the very minimum, it says let's define better what stations can do with underwriting. Example, you could do a slogan on LPFM underwriting. Define what is not promotional for a slogan. I suppose "Serving the community since 1946." If that's a factual statement, that's probably okay. But then let's get into the murkier area. "Subway, eat fresh."

Kirk: Or "Joe's Pizza, the best since 1947."

Kevin: Well, now that right there would be a problem because...

Kirk: Yeah.

Kevin: ...you're getting into one of those EST words. That's comparison. But still, when you talk about "Subway, eat fresh," you're not directing people to eat at Subway, so is that really a call to action, or...?

Kirk: Yeah, I hear you, and I appreciate that subject. I think we ought to just do away with having to make those distinctions by saying you know what? Public radio and LPFMs can sell advertising, and if they really feel it's in their best interest to run obnoxious advertising, fine, go ahead and do it, and you're going to end up like the commercial broadcasters that some people loathe. But if you want to keep it "classy," then keep doing what public radio does now such a nice job of. You know, "This hour of music has been..." I'm sorry, go ahead.

Kevin: I was going to say, and if you don't mind me saying, there's one other thing that bothers me as an LPFM broadcaster. There are rules against third-party fundraising. I agree when it comes to, let's say, an LPFM that's owned by a college, does not want to necessarily be on the air, trying to raise money for the college. I understand that.

But it also is calling into attention whether an LPFM can run a public service announcement for, let's say, the DARE program at the high school down the street, because they're having a car wash to raise money for the DARE program.

Now, some in the LPFM movement say well, yeah, you can do those announcements, because of the rule that the FCC enacted that allows noncommercial broadcasters to air old-time radio commercials. You can even do calls to action in those. But the FCC hasn't defined that. Also, let's talk about the Advertising Council. The federal government contracts the Advertising Council to do public service announcements.

But we are told LPFMs can't run them because they involve calls to action. Silence. Silence out of the FCC. Look, we're not talking obscene, indecent, or profane broadcasting here. One would think they could define the rules a little better. I think if they did, you'd have a whole lot fewer LPFM broadcasters violating rules.

Kirk: Wouldn't it be interesting if we lived in a world, though, where okay, here's the quid pro quo. LPFMs, you can't run call-to-action commercials, only underwriting. But you can air obscene stuff if you want to.

Kevin: Well, theoretically, we're under the same rules as commercial radio stations. You have safe harbor between 10 a.m. and 5 p.m., and you can run an unexpurgated rap. You can run music with four-letter words, just like commercial stations do. Go figure.

Kirk: This is really interesting. Chris and Kevin, we're going to have to wrap it up after our last announcement here, so think of what you want to get in to say. We really should give this subject more coverage here on This Week in Radio Tech.

It's interesting, Chris and I are both kind of free-market guys, but I'm a station owner, so I don't need another fly buzzing around, selling ads, when my own salespeople are having a hard enough time selling ads. But on the other hand . . .

Chris: But see, that's a form of restraint of trade if you're going to say that.

Kirk: Right, right. Exactly, exactly. So all right. I hope it gets worked out, in the interest of lots of free trade. It's good for everybody in the long run.

All right. Hey, our show is brought to you in part by the folks at Lawo, L-A-W-O, Lawo. Website, lawo.com. They are a German-based manufacturer of audio consoles, and they make some big, honking, gorgeous audio consoles, but they also make a line of consoles for smaller broadcasters. Including radio stations. Including LPFM stations.

The one that they want you to know about is the crystalCLEAR console from Lawo. This is an amazing console because the engine for this console is the same as their crystal console, which is a hardware console. So the engine sits off in a rack somewhere. That's where you connect your audio inputs and outputs, or gazintas and gazoutas, as I say. It also has the power supply and a redundant power supply, if you want that. It also has the network connection, so you can have RAVENNA or AES67-compatible streams in and out, so it's a networkable console. So local ins and outs, networking, and power supplies.

But then the actual surface that you use is basically a PC. It's a PC that's running a very special app. And this app is the Crystal app, and it looks like an audio console. Fills the screen, and you almost can't tell it from an audio console. And here's what's cool. They've chosen a PC with a fantastic touchscreen, 10 touch, multi-touch touchscreen interface.

I know, I'm sorry, I keep looking down. I'm looking at my hands, as if I were running the faders up and down and touching the option knobs. There, like that person's doing in that picture there. You can touch up to 10 places at once, move faders up and down and push buttons and turn faders on and off. And because the console is entirely software based, you're not constrained by hardware buttons and hardware knobs.

You can have buttons do exactly what you want them to do when you press them. Totally contextual, totally context sensitive. So when you hit an options button to do an AutoMix or set a level on a microphone automatically, which you can do with this console, you don't get options in there that don't apply to you. They just apply to what you're doing right then and there.

You've got linear faders on the screen for monitor volume and for headphone volume, and then of course for, they have eight faders on the screen at one time. And that's about all you need to do most radio shows. Of course you can change what's coming in on the faders easily. Push a couple buttons, bam, you're in a different show.

You've got another show that uses turntables? No problem. Hit a button, bam, your turntables appear. You've got a show that has everything's on the automation system including lots of hot buttons? No problem, bam, now you've got four, five, six faders that are from the automation system.

You're doing a talk show that includes external telephone hybrids or codecs, bam, you hit a button and you can have that show loaded. You've got a show with lot of local mics in your studio, and again, bam, hit a button, you've got local mics.

You have automatic Mix-minus and talk-back to all of your sources that can receive it back, like talent in the studio or in the next studio across the way. Or codecs, satellite feeds, phones. All this stuff, it's all part of what the crystalCLEAR console can do. And when you network it, it's just amazing.

If this concept is interesting to you, check it out at Lawo, L-A-W-O, Lawo.com. Look at radio products and look for the audio consoles and you'll find the crystalCLEAR. But what you ought to do before you do any of that is just go to that website that you've been seeing there on screen and click on the video where Mike Dosch is explaining the concept of the crystalCLEAR console.

I believe we're going to see more and more of this kind of technology from Lawo and perhaps from others as well. Cool stuff. The Lawo crystalCLEAR console.

Thanks Lawo, for sponsoring This Week in Radio Tech.

All right, tell you what, Chris Tobin, maybe you have a final comment or so and we're going to give Kevin the last word on this whole thing. So Chris, what you got?

Chris: I wish I had a better comment other than I would hope that the broadcasters in general and NAB included would just look at the LPFMs as just another form of broadcasting, and if it's competition, so be it.

Those broadcasters in the market that bellyache about their salespeople having other things to do or they have more work to do, well, that's how it goes. If you had a lumberyard and somebody came into town with another lumberyard who was competing with you, would you go to the local business commerce directorate and say, "Hey, get these guys out of here, because it's going to give me more trouble than it's worth?" No? You wouldn't be able to, so the same should be true for these guys.

Kirk: Got you, got you. Kevin, how about you? Give us a last word.

Kevin: Well, LPFM stations that I'm involved with, we are trying very diligently to follow all the rules. We would like to be able to see there be more specificity to the rules so that we can do a better job and keep our stations within the rules.

Commercial broadcasters, there's an old programming adage, and you know it. It is that where everything is equal, big stick beats little stick 100% of the time. So any LPFM that would come directly straight on at a commercial broadcaster is trying to commit suicide.

We're trying to serve our communities. We're in small town America, many of us. We're in places where commercial radio stations now say they don't want anything to do with us. But let one of us start getting an audience, and suddenly people start screaming.

We just want, just like you, we are licensed to serve public interest, convenience, and necessity. I've believed that for 40-plus years. I have never considered myself a disc jockey or a program director or a newscaster, and I do all of those things.

I consider myself a broadcaster, and we can complement commercial broadcasting. We can be your farm team. We can be one of the places where you can get tomorrow's radio stars if you give us the chance.

Kirk: I like your comments about farm team in the article that you wrote. Boy, a lot of commercial stations don't seem to have space for farm team activities. How do you grow the talent that you're going to need? Hey, I gave a quick link here to our producer, SunCast, to see if he can show it. SunCast, are you going to be able to show that link real quick, or did you... or not?

I've got a link to Delta State University, where they just got a new LPFM on the air. And I'm proud to say, I didn't know he was going to do it, but my business partner Larry donated some equipment to make it happen. So we helped get... there you go, right there. That is Elijah Mondy, and actually we bought a radio station from Elijah, and that's the one in Greenville. So anyway, that's their LPFM going up at Delta State University. I haven't heard it yet, so I need to listen to it next time I go down there.

Kevin, thank you so much for being on the show, and I really appreciate you taking the time, and thanks for working through the technical difficulty of getting the Skype working for you, and I appreciate that very much.

Kevin: I'm not the most technical person there, Kirk, but I'm a disc jockey so I'm all thumbs when that kind of stuff comes to the case, but I'm glad we were able to work all the problems out.

Kirk: Yeah, it's good to hear your perspective, too. In fact, I guess I didn't realize you're not an engineer. You're a program director by trade and an advocate for good programming and localized programming, so that's why you're in the LPFM camp. So it's great to hear your perspective. Thanks again for being with us, and I hope you'll come back to us again.

Kevin: Love to do it. Thank you very much for having me.

Kirk: Chris Tobin, folks who want to reach you and your extreme engineering expertise can do so at what address?

Chris: At support@ipcodecs.com will do just fine. Extreme.

Kirk: Chris Tobin is just a whiz when it comes to making new technical systems work, especially in this day and age when we're using so much Internet and other IP connections to get signals, audio and video, and metadata from here to there, and Chris just understands how to make this stuff actually work.

Chris: [Inaudible 01:10:00].

Kirk: Hey Chris, you and I need to connect in the next day or two on a project in New York City that unfortunately is unpaid. But I'd like to get with you on it.

Chris: Oh, okay, pro bono work.

Kirk: I'll give you a call.

Chris: Yeah, that's fine.

Kirk: It's a show. We need to do some song and dance for some folks.

Chris: Oh. Song and dance. All right.

Kirk: Exactly. It's not on Broadway . . .

Chris: Cosby and Hope are on the road again.

Kirk: ...it's not too far away from Broadway.

Chris: Way off Broadway.

Kirk: All right, support@ipcodecs.com is where you'll find Chris Tobin. Thanks a lot everybody for being here on the show, and we appreciate all of you listeners and viewers very much. Tell your friends about This Week in Radio Tech. We'll have another exciting episode next week. Not sure where it's going to be from.

One of these weeks, it may be from the Kingdom of Nye. If you know what I'm talking about, you're going to enjoy it. All right, thanks to SunCast for producing the show and our sponsors, too. We'll see you next week on This Week in Radio Tech. Bye-bye.

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