From the Corner Office

Hello Everyone,

They call it the “Law of Unintended Consequences.”  That’s when the implementation of something that seems at first glance to be a good idea actually ends up working in exactly the opposite fashion and causes unexpected and undesired outcomes.

And so it is with the FCC’s recent Notice of Proposed Rulemaking on broadcast localism.  After two decades of radio consolidation, the Commission has suggested a variety of initiatives intended to promote the “local” part of “local broadcasting.”  The vast majority of broadcasters understand that, in order to be successful, they must be closely involved with and truly serve the listeners and businesses in their local communities.

So it was with both surprise and disappointment that I digested the FCC’s proposals.  Like many of you, I was taken aback by the retrogressive nature of several of the items, which would reenact policies and regulations that were discredited decades ago after thoughtful, comprehensive analysis.  Other items would impose a mountain of new paperwork on our stations without any obvious benefit.

One item in particular I want to focus upon:  the FCC has proposed a rule that would require each radio station’s main studio to be located physically within the station’s city of license.   At first glance (for those who don’t own radio stations), not a big deal, right?  But when you stop to consider the numbers of radio stations that are licensed to small towns or suburbs just outside the borders of their commercial market, and the numbers of stations that are located just over the line from their city of license for any variety of reasons, and the number of stations that have been co-located with sister stations in their local clusters, it quickly becomes a HUGE deal.  A license originally granted to a suburban community that is now part of a major metropolitan area would have to be located within that specific suburban area, period.  No matter how far it is from the business community, or whether the traffic pattern passed the city of license by, the studio has to be right there.

This rule assumes that, in order to best serve our local listeners, it is a better use of capital resources to disassemble the millions of dollars that have been poured into cost-efficient cluster facilities nationwide, and require broadcasters to relocate their operations to a geographical area that may or may not have meaning to the bulk of the station’s listeners – instead of focusing on delivering programming and community events that address the issues our listeners care about.  If enacted, this regulation would force four of Greater Media’s Philadelphia stations to move approximately 300 yards to be officially within the City Line.  Our Boston stations would require four different studio locations.  The amount of resources, both human and financial, that would have to be devoted to this effort would completely overwhelm our programming and promotions budgets, not to mention distracting everyone’s attention from the more critical task of serving the real needs of our listeners and advertisers.

Not only do our stations share broadcasting facilities, but they also share staff members, including managers, engineers, traffic directors, producers, on-air talent, and creative talent.  Are these individuals supposed to drive between various locations in order to do their work?  Am I supposed to hire completely redundant staff at each facility and reduce many of these employees to part-time as a result?  The unworkable nature of this proposal is just overpowering.

Greater Media would probably be able to weather this storm, although it would wreak havoc at every station and put us in a vulnerable financial position going forward.  But think for a moment about the numerous small broadcasters, the partnerships, sole proprietors and minority owners who do not have the capital to withstand this “back to the future” regulation.  It would clearly result in less diversity and more consolidation, as smaller owners would have to throw in the towel.  Not because of the recession, not because they are underserving their advertisers, not because of ratings issues, but because of overly burdensome governmental regulation.

As we try to focus on reinventing the radio business in a digital world, the last thing we need is counter-productive regulation that fails to address the underlying concerns.  Broadcasters need to speak up, and explain to the FCC and their elected representatives why these proposals are so unrealistic and unnecessary.  We need to tell all the untold stories about what we’re doing in our communities, from blood drives and pet adoptions, to Fourth of July celebrations and Earth festivals, to election coverage and disaster relief.  Local communities are our lifeblood, and we reciprocate in kind.  I urge all of us to step up our efforts – and our own self-promotion of those efforts.  We have nothing to lose, and much to gain for ourselves, our listeners, our advertisers, and all those unsuspecting trees.

Please feel free to e-mail me by clicking on the "Ask Peter" icon posted below. I would love to hear your feedback or answer any questions you may have.