I am the author of the petition for rulemaking which served as the model for most of the Federal Communications Commission's plan for licensing low-power FM stations. There has been some confusion on this issue and your article mentioned it: Micro radio is not low-power FM, and low-power FM is not micro radio.
I had originally asked for a power ceiling of 3,000 watts but am quite pleased with the 1,000 watts offered by the FCC. However, I would like to see the maximum antenna height raised from 60 meters to 100 meters, which will increase coverage by another 2.5 miles.
While I understand pirate radio's effect through raising awareness of the issue, I do not condone illegal, unlicensed broadcasting. Jesse Walker's article was accurate and well thought out on many points. However, letting each broadcaster choose his or her own frequency and then work out interference problems invites havoc akin to taking down stop signs and letting drivers work it out on their own.
I have worked in the broadcast industry for more than 35 years and owned low-power TV stations for the last 10 years. Your idea of reducing power so ten 100-watt stations could operate in the same area as one 1,000-watt station is flawed technically. This may work with lightbulbs, but not radio propagation.
We have many factions within the LPFM movement, but certain technical parameters must apply to all, unless we are to scrap AM and FM entirely. Our problem at present is to find a way to keep the big corporate broadcasters from stealing all the new LPFM channels. I proposed that applicants must live within 50 miles of the proposed station, but some within the FCC have told me that this type of rule could be struck down as unconstitutional, especially given decisions handed down recently affecting the criteria used by the FCC in comparative hearings in the past.
Skinner Broadcasting Inc.
Miami-Fort Lauderdale, FL
Were you out to lunch when "Radio Waves" was accepted for publication? Following are a few quotes from the article with my comments interleaved:
"A series of buyouts has swept through the industry, with the number of station owners shrinking by more than 700 in less than three years, leaving four corporations in control of more than 1,000 stations nationwide." Whenever I see numbers without sufficient data to evaluate or compare them, I'm immediately suspicious. Is that 700 (and 1,000) out of 7,000, or 70,000, or 700,000? I don't know whether to be concerned I'm being manipulated. Is it necessarily bad that conglomerates are forming, or is it merely the free market?
"The conventional wisdom blamed this on Docket 80-90, a Reagan-era rule change that had loosened the restrictions on how many operations could coexist in one market, opening the FM dial to 689 new outlets." This passage suggests that it doesn't take much to change the number of stations by 700.
"With 12,000 radio stations licensed in this country, broadcasters don't need to be told how congested the spectrum is." At first I thought that here was a number I could compare with the first one. But that was 700 station owners, and this is 12,000 stations. I still don't have a number to compare with the first one. This one (12,000) does relate to the number (689) of stations that opened as a result of Docket 80-90. That number is less than 6 percent. Hardly a fraction to be concerned about. Perhaps that's why the numbers were placed so far apart.
"So if our hypothetical station (let's call it KBIG) decides to sell itself outright to a chain (let's call it KRAP), it can. But if it wants to reduce its wattage and let an entrepreneur or civic group take over part of its previous coverage area, it will somehow have to guarantee to the buyers that the FCC will allow it to transmit to the space it has emptied."
When I read this statement, I thought I had accidentally picked up the Utne Reader instead of REASON. The author seems to believe that conglomerates are bad and small stations run by your neighbors are good. I thought that was for free markets to decide. In fact, the author's general prescription is not elimination of legislation, or even less legislation - just different legislation, perhaps tilted toward smaller business. The latter strikes me as favoritism.
Laurence V. Marks
I greatly enjoyed "Radio Waves" (June). I'm a 30-year broadcast veteran who preferred to find Internet-related employment when my last radio gig came to an end in 1994. I believe that deregulation and the elimination of local competition will be the last nail in the National Association of Broadcasters' coffin. I'll never be satisfied until the government tells these bastards that they cannot own multiple facilities in the same license class in the same signal area. What an outrageous perversion of the free market and what a shameless approbation of local media monopoly! The original Communications Act has been disgraced, and Congress, NAB, and most of the brain-dead American people all have dirty hands in this matter.
Your clear thoughts and well-researched writing is a genuine pleasure and much appreciated. Thank you for writing about the stuff that matters.
Jesse Walker replies: I never claimed, as Mr. Skinner asserts, that ten 100-watt stations could operate in the same area as a 1,000-watt station. I said that several stations of varying power levels could fit in the coverage area of a high-power station. How many would depend on topographical and other factors, and would vary from place to place.
Mr. Marks' claim that I advocate "not elimination of legislation, nor even less legislation - just different legislation" is simply weird. My article did not endorse a single new regulation. It did, however, call for eliminating a host of restrictions on starting new radio stations.
As for my figures, I was not using them to argue that four chains had a stranglehold on all broadcasting in this country, as Marks seems to imagine. (For one thing, there are more than four significant radio groups.) I was illustrating how rapid consolidation had become in recent years.
Is conglomerate radio "bad"? To my taste, it usually is. To the FCC's, it isn't. Should free markets decide? Sure, but what we have now is hardly a free market, as I spent much of my article explaining. Either I am a sloppy writer or Mr. Marks is a sloppy reader.
In "Crime Stoppers" (June), Jim Peron reflects a scary libertarian desideratum: protection of private property and, with it, insulation from the outside world.
According to Peron, enclaves called "resident associations" and "private urban management services" have been formed that provide their own security forces and virtually everything else an autonomous community requires. The before-and-after crime statistics cited by Peron are dramatic
The enclave creation, though in response to conditions in a newly democratic and struggling South Africa, could be proffered as real-life applications of Robert Nozick's philosophic communities in his book Anarchy, State, and Utopia, and it also picks up on Jack Kemp's initiative, when he was HUD secretary, of encouraging the establishment of resident councils in what remained of public housing. Local residents and businesses combining to serve their own interests is laudable - up to a point. HUD's resident councils targeted drug dealing and other activities directly affecting their projects.
By championing private enclaves, Peron is shutting his eyes to the plight of most South Africans - 40 percent of the blacks are unemployed - and to the enormous problems the government faces in converting from apartheid. Yes, individuals should be held responsible for their actions, including crime. But the society needs to be just and to mitigate the effects of poverty and oppression. This cannot be done by holing up and shutting out.
South Long Beach, CA
Keeping Up With the Forbeses
Jack Hirshleifer's review of Robert Frank's latest book, Luxury Fever, pointed out a few of the many flaws in his argument against materialism ("Purchase Disorder," June). Libertarians might be even better off if it turns out Frank is right. If relative standards of well-being do indeed matter more than absolute standards above a certain minimum threshold, then the fundamental microeconomic assumption of diminishing marginal utility will have to be reexamined. In that case, the rationale for progressive taxation disappears.
If individuals all along the wealth spectrum measure themselves against their peers, then each additional dollar available to compete will be valued just as highly by cohorts at each level of income. In standard absolute terms, a more wealthy person would ordinarily value a dollar less than those further down on the economic ladder because the items that dollar could purchase would be further down his priority list. In Frank's relative terms, however, any status item that a wealthy person buys helps maintain his relative position. Frank provides no reason to believe that the consumption competition is any less fierce at higher levels of wealth, so keeping up with the Forbeses is presumably no easier than keeping up with the Joneses.
Frank might respond that taxing everyone in a given cohort the same will leave them in position to compete on equal grounds. Thus progressive taxation would leave less money available for all competitors, which would be a positive good for Frank to the extent that consumption is bad. That reply would miss the force of the objection. At all levels of income, less income would enable less consumption competition. Unless Frank can provide a good reason why competition among the superwealthy is worse than that among those with moderate incomes, he no longer has a good theoretical basis for progressive taxation.
By overlooking this dramatic implication of the relative position argument, Hirshleifer misses an opportunity to put Frank's thesis to good use.
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|Date:||Oct 1, 1999|
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