An open letter to all LPFM broadcasters

LPFM made a historic appearance at NAB Show... and LPFM, we need to talk... I mean, seriously talk.

REC releases the following statement from its founder, Michelle Bradley, CBT:

Today (Tuesday, April 8, 2025) was likely a very historic day in the history of the LPFM service. For the first time in either a long time or possibly in the history of the LPFM service, there was a session at the NAB Show in Las Vegas that discussed LPFM and featured a major LPFM stakeholder, myself. Since LPFM is over 25 years old now, I am not sure whether this was the first time it has ever happened, but it did happen today. The audience included several representatives from full-service broadcast stations as well as the presidents of several state broadcasters associations.

The discussion was about the new inspection guide for LPFM stations that was published by the Society of Broadcast Engineers (SBE) and the National Association of Broadcasters (NAB). This guide, which is available only to SBE and NAB members can be used to perform self inspections of stations looking at the things that would be looked at if an FCC field agent was to visit the station. This was the latest in a series of inspection guides released by SBE & NAB. The guides are being published because the FCC has not released a self inspection checklist publication since 2008. During the session, I had mentioned that about 10 years ago, REC released our own checklist and is being actively updated.

During the session, one of the representatives from SBE did speak of a Florida LPFM station that has been serving immigrant communities and was a vital link to the community. A very positive profile of an LPFM station.

During the session, the issue of LPFM compliance issues came up. The main issue in this topic was the subject of underwriting acknowledgement compliance and LPFM stations carrying “full blown” commercials. This did not surprise me, and honestly, I was very glad the issue was raised in the open.

I reminded the audience that the issue of underwriting is one of the biggest LPFM compliance issues right now at REC. I had mentioned that the issue of compliance was being addressed through our underwriting compliance training and that I am one of the strictest where it comes to evaluating underwriting copy. I had mentioned some of the concepts that I train on including the “business card” model that the late Donna Di’Bianco had used in her trainings. I had also mentioned the REC PACE Program that recognizes overall participation, availability, compliance and experience.

In my statements to the audience, I have told them that first and foremost, just because a radio station has an -LP suffix in their call sign does not mean they will have a “get out of jail free” card with REC. I told the broadcasters that if they have an issue with an LPFM station to first send me the information, including identifying the station and exact details about the copy of the allegedly offending underwriting messages. I pledged to attempt to contact the station myself to address the issue. If my attempts are unsuccessful or if the problem continues to persist, I suggested that they do file a complaint with the FCC. I think it is very clear that there are some out there who may think that just because there has been very little enforcement activity on LPFMs running commercials, the FCC just doesn’t care and that they will not do anything about it.

After the session, I had a very productive sidebar with several state broadcasters association presidents who were in attendance. During this time, they had mentioned some examples of what they are getting complaints about:

• In one case in a smaller market, the LPFM station was able to undercut a full-service station for the radio rights to carry local high school football and the LPFM station ran full-blown commercials.

• In another case, an LPFM station was an affiliate of a larger sports team network and was inserting their own local commercials.

This kind of behavior is unacceptable and it must cease now. In the past, even before Brendan Carr became Chairman, I had reminded LPFM stations to not “sound like NPR” in their underwriting copy. Now, with Carr in charge of the FCC, he is gong after NPR and their member stations. As I have stated in the past, based on what I hear on NPR’s national programming as well as on their member stations, Carr may have a solid case.

I remind LPFM stations again that noncommercial stations, including LPFM were originally intended for schools and colleges, which have substantial funding (at the time) to support broadcast education programs, as well as well-established civic organizations with sufficient funding to build and sustain the station, as well as well-funded faith based organizations. Those have started stations from scratch without the backing of any of the above have a massive uphill battle for funding and times are very tough. However, the solution is not to veer out of your lane and engage in commercials.

This is why LPFM cannot have good things (such as LP250).

I also remind your station to consider joining your state’s broadcasters association. Annual dues run about $150~$250. Despite what you may have heard about the early history of the relations between some state broadcasters associations and LPFM, many of these state associations are now more welcoming to LPFM members as many have proven themselves to be responsible sharers of the FM spectrum. In the past, some LPFMs have expressed concern as to why LPFM stations are only considered “associate members” as opposed to full members. This is very common that broadcasters other than full-service commercial stations are considered associates. This also includes full-service noncommercial and LPTV stations. The only real difference between an associate member and a full member is that the associate members cannot elect leadership in the association. I have been assured by these state associations that associate members will still have a voice in the association.

Interestingly enough, LPFM stations can even join NAB as an associate member at $350 annual dues. I have not yet discussed with NAB as to how much of a voice an LPFM would have if they decide to join. While I think that for LPFM stations, joining NAB may be a novel idea, I would strongly suggest membership in your state’s broadcasters association.

As a part of REC’s “NAB Common Ground Project”, I have been working closer with the NAB to better educate the organization and broadcasters on the positive aspects of LPFM and while we still have a way to go before we can declare a much fuller common ground, I am making progress and I value my “olive branch” and “open door” relationship with the NAB. Today, I feel that we can have a similar “common ground” relationship with the state broadcasters associations.

I will be blunt here. If your station is engaging in these types of commercials, it must STOP immediately. Period. No excuses. If you are not making revenues to support the station expenses, perhaps you need to look at your station’s programming and how compelling it is. If the station’s programming is compelling enough and you are serving the community, there will be underwriters out there that want to be associated with the station.

Also, please make sure your station’s contact information is correct with the FCC. I have heard many stories about broadcasters having a difficult time contacting stations because their contact information in the FCC records is outdated. This can easily be done by filing an Administrate Update in LMS.

As always, if you have any questions, need any advice or want me to review your underwriting copy, please email me (lpfm at recnet dot com). Also, it is very important to remain “connected” with the rest of the LPFM community through resources such as the LPFM group on Facebook.

In the best interest of the LPFM service and for the medium of radio in general, I strongly suggest you heed my advice.

I am sorry for the bluntness, but it had to be said. Thank you for reading and for your understanding.

Michelle Bradley, CBT
Founder, REC Networks