FMC's Guide to the FCC's Localism in Broadcasting

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This is designed to help you craft a comment to file at the Federal Communications Commission on localism in broadcasting. The twelve topics below are a summary of just some of the many questions that the FCC poses to stakeholders and citizens in its "Notice of Inquiry" [PDF].

Feel free to give your opinion on as many or as few of the topics below as you like. Your opinion counts, but including facts, data, or experiential evidence where you can is even better. This is not a test – it is a guide. You do not need to fill in every box, just the ones where you feel like your personal experience will help the FCC to create better policies related to localism.

Once you've navigated the guide, press submit and you'll see all your comments merged into one letter. Then fill out the form on the next page and hit "file my comment" to send it to the FCC.

Remember that you're writing these comments to the FCC -- not to us -- so think about your audience as you type. Comments like "Clear Channel sux!" may be funny to type but are not helpful in crafting better policy, so try to make your critiques productive.

1. Introduce yourself First, it's important to give the FCC some information about yourself. Are you a musician or recording artist? A concerned citizen? A media consumer? A broadcaster? On-air talent? An academic or researcher? Tell them about yourself in a paragraph so they understand your connection with local broadcasting. type your comments in box

2. Include details about your life as a musician, recording artist or songwriter The Future of Music Coalition understands the vital role that radio plays in the lives of musicians, songwriters and performers, so it's important that performers let the FCC know about your specific experiences. Things to mention in your comment might include: number of songs written, or number of albums released number of hits, if any whether you're an unsigned musician, or signed to a label how often you play locally, nationally, internationally information about the size of your following in your local community type your comments in box

3. Musicians: talk about your personal experiences with local radio Clearly, musicians, performers and songwriters who rely on radio exposure are stakeholders in this proceeding, so tell the FCC about your experiences: Have you ever contacted a local station and sent them a CD for airplay? If so, what was their response? If not, why not? Do you ever hear your material on local radio? If so, on what kind of stations? Commercial, noncommercial, college, low power? Do any of your local stations host niche programs or shows that feature local talent? If so, which ones? If your songs aren't played on local radio, do you have any sense why? Do any radio stations in your area play the recordings of other popular local artists? Do you feel like the stations in your area are serving the local music community? If so how, and if not, why? type your comments in box

4. Should the FCC define "local programming"? The FCC's NOI poses a number of questions about how to define “local programming". Should the FCC continue to rely on market forces and the issue-responsive programming requirement to encourage broadcast stations to air community-responsive programming? Or should the FCC try to come up with a definition of local programming? type your comments in box

5. How the FCC should define "local programming" If you think the FCC should define local programming, what should it include? Should the FCC adopt a definition that measures “locally originated” or “locally produced” programming, or do either of these serve as an example of "local programming"? Should the FCC ensure that all programming decisions are made at the local station level? type your comments in box

6. What should count as local programming? Should the only programming that would count as local programming be programming in the traditional sense of news and public affairs, or should local programs of an entertainment nature – such as the broadcast of a local high school sports event or a local band hour – also count? What if a station plays the music of local artists? type your comments in box

7. Should station participation in local community activities count? Should stations be evaluated on non-programming efforts such as “participation in local community activities or sponsoring fundraisers?” What about sponsoring charity events, like a walk for a local hospital? Should this count towards their localism requirement, or should this just be considered an example of the same type of community goodwill that many banks, corporations and local businesses also engage in? type your comments in box

8. Payola Federal laws were passed starting in the 1960s that forbid the direct payment or compensation of disc jockeys or other radio staff in exchange for the playing of certain records unless such payments were announced over the air. Despite these rules, many news reports and artists have complained that payola still exists, but in a different form. See Eric Boehlert's article Pay for Play for details. See also this joint statement for more information on payola, voicetracking and radio concerts The FCC wants to know: What are the various types of payola practices today, and how frequently do they occur? If you have had any direct or personal experience with this, even better. Should payments made to radio stations via "indie promoters" be considered payola? If so, how should the FCC regulate the practice? For example, should they prohibit the proactive of accepting any payments from anybody that does music research, or makes programming suggestions? If an artist does a free concert for a radio station, either for a charity or not, should the FCC consider that a form of payola? Should record labels be allowed to buy ad spots on stations to play their band's songs as an announced ad? Are radio stations seeking payment for front and back announcing – that is, announcing songs and artist information either before or after a song is played? If so, does this practice violate the FCC's sponsorship identification rules? Are the existing rules in any way deficient in addressing the current practices? type your comments in box

9. Voice-tracking “Voice-tracking” refers to the practice of broadcasting entire pre-recorded air shifts that are customized to make it sound as if the DJs are actually local residents when, many times, they are not. Announcers spend one or two hours in a studio, recording announcements, liners and tags. Those shifts are broadcast later in other markets, without disclosing to audiences that the shows are neither live nor local. Voice-tracked programs are different from syndicated radio shows, where the audiences understand that the program airs on a nation-wide basis. But that’s not the only difference between voice-tracking and syndication—voice-tracking announcers are paid much, much less. For the broadcast station, the use of voice-tracking allows it to use technology to spend less on on-air talent, thus make it more competitive. However, according to AFTRA, “when a media company uses voice-tracking as a strategy to eliminate live broadcasts and local employees altogether, the connection to the local community can be hurt.” The FCC does not have rules that directly address this practice. What do you think of voicetracking? Is it a reasonable practice or is it inconsistent with a broadcaster's obligations to serve the local interest? What about broadcasts that mislead the public about where the broadcaster is located? What should the FCC do about it? type your comments in box

10. National playlists Another localism concern is the effect of “national” playlists developed by large corporate radio owners on the access of local talent to air time. It is argued that, unless you have access to the handful of gatekeepers that create these playlists, local artists are stifled and localism suffers. The FCC seeks comments on the prevalence of national playlists and their effect on localism. To what extent does the use of such playlists prevent local stations from making independent decisions about airplay, and thereby diminish the diversity and types of music heard on the radio, such as music performed by local artists? What steps if any does the FCC need to take in this area to protect or promote localism? For example, should it be required that all programming decisions are made at the local level? Should stations be required to play a certain percentage of local content? type your comments in box

11. Low Power FM Radio In 2000, the FCC created a new class of licenses called "low power FM". These are local, noncommercial FM licenses that allow citizens and groups to broadcast to a community at 100 watts or less. Since 2000, the FCC has sought to grant over 1000 applications. In this proceeding, the FCC is also seeking comment about how to promote and foster LPFM stations. What do you think about LPFM stations? Would you like to see more low power licenses available, especially in more populated areas? Do you think LPFM stations could benefit the music community? If so, how? type your comments in box

12. Conclusion Wrap it up by thanking the FCC for addressing this issue with a public proceeding. type your comments in box