I’ve been attending a lot of radio meetings these past years and one refrain I’ve heard over and over and over and over is that the power of radio is it’s “live & local.”
This week, the FCC voted along party lines 3 to 2 to eliminate the Main Studio Rule.
1934 Congress Establishes the FCC
The first regulatory body to oversee radio was the Federal Radio Commission (FRC) that was established by the Radio Act of 1927. The FRC was created to, among other things, insure that the public airwaves of America were used in the “public interest, convenience and/or necessity.” The FRC was given regulatory powers for licensing all radio stations and insuring the airwaves were assigned to broadcasters capable of providing quality broadcasts. The amateurs were assigned to another piece of the broadcast spectrum which today is known as Amateur Radio Service or Ham Operators.
Amateur Radio like AM/FM radio is regulated by the Federal Communications Commission which was established by Congress with the Communications Act of 1934.
Main Studio Rule
So, this week when the FCC voted to end the Main Studio Rule, what did that mean according to the FCC’s regulations that have been in place in 1934 (and per Gregg Skall) updated in 1988 to make them clearer? FCC attorney Skall wrote back in 1991 in his “Main Studio Rule and Staffing” memo:
The main studio rule as clarified in 1988 requires a station to maintain a main studio within its principal community contour “which has the capability adequately to meet its function…of serving the needs and interests of the residents of the station’s community of license.” That rule has now been further revised to allow a main studio to be located either within 25 miles from its community of license reference coordinates, or within the principal community contours of any station, of any service, licensed to its community of license. (See memo, Revised Main Studio and Public File Rules). Jones Eastern requires the station to maintain a “meaningful management and staff presence” at the main studio on a full-time basis during regular business hours.
You can read the full memo here.
LIVE RADIO
Since the introduction of automation systems, syndication, satellite delivery and computer voice tracking, the LIVE aspect of radio has been on the wane. Even in the #1 radio market in America, New York City, stations may or may not have a live operator behind the microphone when you’re tuned in.
When I was starting out in radio, we used to have to announce whether a program was live or pre-recorded so the listeners wouldn’t be deceived about the broadcast. In the early days of radio, virtually all radio was live and so it was the exception for something to have been recorded.
Today, it’s more likely what you are listening to is not live but syndicated, voice-tracked and pre-recorded.
LOCAL RADIO
With the Main Studio Rule, the goal was at least there would be a live person at the station and the studio would be in the community the licensee was licensed to serve.
Lance Venta writing on RadioInsight wrote “But what will it (elimination of the Main Studio Rule) mean in the short term? Probably not a lot. In the long term, be prepared for a much leaner broadcast facility.” You can read Lance’s entire article “The Radio Station of the Future…Today!” here.
The National Association of Broadcasters has been lobbying for the elimination of the Main Studio Rule, and its executive VP of communications Dennis Wharton said “We’re confident that cost savings realized from ending the main studio rule will be reinvested by broadcasters in better programming and modernized equipment to better serve our local communities.”
Brick & Mortar Presence
FCC attorney Scott R. Flick said that the Main Studio Rule was really a government mandate for radio to have a brick-and-mortar presence in an internet age. “Its existence hindered stations from evolving and adapting to the rapidly changing business strategies of their many non-broadcast competitors.”
It’s ironic that the biggest online retailer, Amazon, is now in the process of acquiring a brick-and-mortar presence as the radio industry appears to be moving in the opposite direction.
Public Safety
When a broadcaster doesn’t have a studio in the local community it serves, it delivers its programming through the internet, satellites, microwaves or wired lines. Broadcasters have been quick to point out how these forms of communication are first to go down in natural disasters.
What seems to be missing in this conversation, is a Black Swan event. Will radio be ready for a Black Swan?
Today’s Big Regulatory Difference
The big difference I see today for radio versus its toddler years is how it is regulated. The Radio Act of 1927 provided the foundation for all broadcast regulation right up until today. While more Acts were passed and made law over the years, the basics remain much the same as when they were first made law.
Some of the key provisions in the original Act that we’ve deviated from today are:
- Limiting the number of broadcasters to foster higher quality radio broadcasts versus having more stations of poor or mediocre qualities
- Radio broadcasters would operate in the “public interest, convenience and necessity”
- Radio would be a regulated medium to assure high quality and operating in the public interest
- Radio would be commercial and privately owned (a condition that made radio broadcasting in the USA different from every other country in the world)
Those who complain that radio isn’t like it used to be only need look at how broadcast regulations have been changed over the past century; the biggest change being the Telcom Act of 1996.
Make Radio LiVE & LOCAL Again
On May 24, 2004, the Federal Communications Commission (FCC) held a “Broadcast Localism Hearing” in Rapid City, South Dakota. The president, general manager and co-owner of KLQP-FM licensed to Madison, Minnesota (population 1,767) Maynard Meyer addressed the commission. He told them (I’ve edited his comments. The full text can be found here. )
“Localism in radio is not dead, but it is in dire need of resuscitation in many areas. I have been involved in the radio business in announcing, sales, engineering and management for about 36 years, all of my experience is in communities of 5,000 people or less. We personally live in the communities we serve so we know the ‘issues,’ we work to address them in our programming and have been doing so for the past 21 years.“
“A few years ago, many stations operated this way, but much of that has changed for a variety of reasons. I think the beginning of the end of local broadcast service started in the 1980s when the Federal Communications Commission approved Docket 80-90.”
Mr. Meyer went on to explain to the FCC how many communities that “on paper” had a local radio station actually found that the transmitter was being fed from another location tens of miles away. Mr. Meyer went on to say:
“I don’t think this is the best way to promote local radio service. From what I have seen through my personal experience, as soon as a hometown studio is closed and relocated, the local service is relocated as well.”
What do you think?
DickTaylorBlog 
Dick, Thank You for such extensive research to document the path of radio from:
(beginning- “to have a local presence &be The Voice if the Community(news, weather, sports, music, “Bulletins” (special, threatening, immediate notification of potentially Life-Threatenibg information, fund-raisers, etc. “Local People entertaining & informing Their Neighbors, co-inhabitants’.
Best Part: Growing New & Old ‘Local Businesses:Employers, that Hired Local People! That’s how it was in 1966 (my 1st DJ gig WLAU,Laurel, MS.
I loved what computers brought to our profession! Amazing Efficiencies & Possibilities! I left Radio in 2001 (45 wonderful years), because I saw the- more efficient way of operating radio: pay a voice talent for One Hours work, to record ‘voice liners’ for show than runs 3-4 hours. Listeners calling in, are welcomed with a brief message & intructions on how to leave a message for the statioor Air Talent. (Sales dept had direct lines to rep or secretary that answered.
Now, due to the ‘service provided’(live & local) taking a “backseat” to ‘efficiencie$, Voice-Tracking & Satellite Repeaters are the ‘norm’.
if you want “Live & Local” go to Wal-Mart.
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It means that the FCC have totally CAVED to the beancounters and have declared the PUBLIC INTEREST CONVENIENCE & NECESSITY on the radio totally & completely D-E-A-D.
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The elimination of the Main Studio Rule will have no impact on the broadcasters who live true local radio every day. Because we know that serving our communities is job one. It’s what we do daily. Being a force in our communities is what keeps us relevant to both our listeners and our advertisers. The Main Studio Rule in many cases meant a low paid person sat in an office with the public file from 9-5 on weekdays while the station operations were in an adjacent bigger city. How’s that serving the community? You either do local radio or you don’t. Ownership either gets it or they don’t. And have you noticed the stations that scream live and local the loudest are the ones who really aren’t? It’s a much over used and abused term.
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Thank You Mike for adding your thoughts. With respect to your comment about those who yell “live & local the loudest are the ones who really aren’t” is concerned, when any broadcaster deceives the listening public, it hurts us all. I learned that lesson from a local transmission repair owner back in my early sales days. What he told me then is just as true today. -DT
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The key take away is Serve the Area You’re Licensed to. If owners want to try that with smoke & mirrors it won’t amount to “Nuttin Honey.” We have many tools to work with. Connected content and strategic feeds make the difference. However, anyone allowed to take a pass on local service should be held responsible and taking liberties with community service is dumb. Minot had a local studio but there was nobody home.
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Wrong- they did have someone there (as an LP1 they’re required to.) It was in fact the Sheriff’s office that didn’t know how to use the equipment they had been given.
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That is correct Scott. The disconnect was local officials not having the equipment or understanding of how to utilize the system in times of emergency. -DT
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Dick, I have two stations in rural markets. We have to be tied down each week watching a studio phone that when, and if it rings is forwarded to my phone and I can help the individual instantly. It is crazy to have someone take a message (which many stations do) and say “No one is here now, can I take a message (so much for that main studio argument). I have two individuals that have looked at our FCC files at the stations I’ve been at involved with in 30 years. Both were from the FCC. I’ve had about 6 visitors this year at our main studio. 99% of our inquiries are via phone, text or email. My air staff has other obligations in this competitive world. They can voice track their show and still cover all the local news, sports, weather, lost dogs and update those track with breaking news and events in an instant. A brick and mortar presence doesn’t make a radio station. It is the time and effort that is spent putting content on the air. Today with technology that can be done at any location in the comfort of a home studio or other location. Most of the main studio elimination complaints are from those who long for the days of sitting behind turntables and talking after each record. That ended in the 90’s (and at some stations before that). Guess what, radio is still here. As a independent operator, a main studio has very little to do with the day to day operations at our stations. I’ve yet to have one listener mention or address it. I’m not a corporate station, or a bean counter. The elimination of the main studio will have no impact on many local stations. In fact, it might save a few stations who are just surviving. I consider this ruling optional. If doesn’t mean a station has to do away with it. Some will, some won’t.
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Damon, it comes down to the letter of the Main Studio Rule and the spirit of the Main Studio Rule.
Fred Jacob’s this morning shows the results of his research on this question with listeners of OTA radio. -DT
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One of the ways to make the new main studio rule work against the broadcasters who will use it to shut down local offices and studios is take the offensive to the local advertisers. Compile a list of all of the local advertisers on the stations that are abandoning their communities of license, go to those advertisers and urge them to reconsider their support of businesses that do not support and serve the community.
Take the time to explain to them that when the broadcaster abandons the community of license it means no one’s home when the next disaster strikes to bring vital life-saving information to the community. It means no one’s going to broadcast from the local supermarket for the annual Holiday Food Drive. It means no one will broadcast the local high school football, basketball games etc. It means there’s no weekly public affairs programming. It means national PSA’s will take the place of announcements focused specifically on the local community.
Go to your county office of emergency services, explain to them that station(s) XXXX owned by corporation XXXX no longer have a local presense, and that means they can no longer be counted on by his office to be a “first informer” during emergencies. Ask the OES to notify those offending broadcasters last and to provide them with the lowest level of official cooperation. Point out the broadcasters that maintain a studio presence in the community. Make it easy for these first responder officials to contact those stations and ask they contact them first when need arises to inform the public.
The broadcasters who maintain local offices and studios need to remind their listeners every day that they are there for the community. When you promote your local presence, be sure to mention in the same announcement that “…unlike our competitor (station XXXX) we here at station XYZ have a local office, studio and staff that is always ready to serve our community…” Keep hammering away at that message and eventually the drip, drip, drip of constant repetition of this fact will turn to a flood that will ultimately benefit your station and likely make it impossible for your now out-of-town competitor to do business in your community.
Those broadcasters abandoning their local communities are doing so to save a buck and nothing more. They think this cheapskate attitude will result in higher profits for them, but if they end not being able to sell airtime in the communities they’re abandoning, they really won’t be saving any money at all will they? And they will likely end up at some point either re-establishing their local studios or they will be forced to sell those facilities (at stick value let’s hope) to someone who will.
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Actually, I’ve seen local businesses stop their radio advertising when a local station moved out of their town based on the old rules for Main Studio that the FCC just eliminated.
Remember, local businesses are owned by local people who live and serve their communities in many ways.
Fred Jacobs this morning published some of his research on how important being local is to the OTA radio listener. -DT
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The truth is the majority of listeners and advertisers don’t know where the radio station studio is in our community. We are located in the center of town (at the post office), and no one really cares (no visitors). What they do is enjoy our programming and the local information we provide. I can provide this at many different locations. The truth is, if you are to survive in small market radio today, you better go to the community or the advertiser. The days of sitting in the glass castle (Main studio) and expecting the masses will come to you are over. I compare it to visiting Facebook’s office or actually engaging with the product. This week we will be at Halloween events, High School games, and festivals. That is how you stay relevant in today’s radio. Not sitting in a studio.
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Interesting perspectives – since I am no longer a member of a particular community – I love it when we land somewhere in the US with local news, weather and commentary. I understand that the ‘office’ can be anywhere but the commenters are correct, it is owner dependent. I love radio,
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Fred Jacobs blogs this morning about the FCC’s elimination of the Main Studio Rule. You can read his thoughts (and research) here: http://jacobsmedia.com/brick-mortar-radio/?utm_source=Jacobs+Media+Strategies+Blog&utm_campaign=68b4beb958-Blog_Daily_FullInfo&utm_medium=email&utm_term=0_5007ff924d-68b4beb958-166581705
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The FCC’s Republican majority claims that the change will produce cost savings that broadcasters can use to improve “programming, equipment upgrades, newsgathering, and other services that benefit consumers.” But Democrats say the change will instead make it easier for stations to abandon the cities and towns they serve.
Jon Brodkin’s article in ARS Technica…
https://arstechnica.com/information-technology/2017/10/fcc-rule-change-could-help-tv-and-radio-stations-abandon-local-communities/?utm_source=james.crid.land&utm_medium=email&utm_campaign=newsletter
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I commented on localism as quoted in 2004 and I feel the same way today. You cannot be an integral part of a community unless you are physically there. Being local is more than just providing a few PSAs or a ballgame on the radio. Elimination of the main studio rule will result in more hometown stations disappearing from the map while operations are moved to regional centers.
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Thank You Maynard, both for your original comments to the FCC and your reinforcement of those same opinions today. -DT
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About the only real change I see happening is the closure of sham “main studios” for rimshot stations where the actual sales office and studio are in the big city 50 miles down the road and the “main studio” is a STL feed coming into a small mixer in a rack in the corner of someone else’s station and going out to the tower and the 2 requisite employees also work for the station whose rack space you’re renting. Those docket 80-90 stations were long gone and not coming back whether the rule was there or not.
For those stations who can’t or won’t get turned into a rimshot, the way they make money is to live, work, and play in the town they serve. You’re not going to shut down the studio when it’s the center of all of your direct business. Maybe you won’t always staff it with two full time employees, though. People don’t come by the station to look at the station, but they do come there to conduct business with it. I suppose if I sat down and thought about it I could come up with some ways to create a virtual radio station and everyone works from home, but there has to be some place for the customer to drop off a check and by the time you build all of the back end for all of that you could have just paid the rent on the office space.
Voicetracking and technology aren’t evil. Even if you’re tracking with people from out of the market, if you’re concentrating on serving the people who live in your community, you’re providing something of value to them every day. You’re working your tail off for every dollar you sell, and my hat is off to you.
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Thanks John. You make some valid points. Thanks for sharing your perspective. -DT
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Great summary, thanks Dick. Mixed feelings here. The way people use radio has changed since the halcyon days of community-involved personality radio that many of us recall so fondly. And there are too many radio stations competing in all but the smallest markets for every one of them to succeed by embracing their communities.
Some succeed with music intensive formats targeting a specific demographic/psychographic. About the only thing they air that’s “local” are the commercials. An they are indeed an important local, and localizing, element.
The ones who succeed by embracing the community know they need a physical presence for business reasons, so they’ll retain local facilities. A few of those are still around, and are wildly successful, like WLNG,
I suspect most markets would support more of such payroll-intensive formats. Albany, as an example, has none. And for the others, what does it really matter where they program from? The NAB position may be a lie and a smoke screen, but regardless, debt service must take precedence over an investment in people to help insure survival until the next bonds come due.
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Thanks Dennis. I understand where you’re coming from. -DT
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