Document text
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of:
Elimination of Outdated and Unnecessary Regulations in the Broadcasting
Industry
GN Docket No. 25-133
Comments of the LPFM Advocacy Group (LPFM-AG)
I. Introduction
The LPFM Advocacy Group (LPFM-AG) submits these comments in support of proposals to
modernize underwriting policies and ownership limitations for Low Power FM (LPFM) and
Noncommercial Educational FM (NCE-FM) stations. These proposals are designed to ensure
that nonprofit licensees—especially independent, community-based LPFM stations—can remain
financially viable and sustainable in a shifting media and funding landscape.
We also write to address public concerns raised by other LPFM advocates who have expressed
opposition to reform, particularly around underwriting content and market transactions involving
LPFM licenses. While well-intentioned, we believe those concerns can be addressed through
existing FCC rules and do not justify keeping outdated restrictions in place that place LPFM
operators at a structural disadvantage.
ll. Preserving Nonprofit Ownership While Modernizing Underwriting
All LPFM licensees are, by definition, nonprofit organizations or public entities. That
foundational requirement remains unchanged in our proposal and provides sufficient protection
against commercial exploitation or corporate takeover. The LPFM-AG does not support allowing
for-profit entities to hold LPFM licenses, and we do not support eliminating the nonprofit
requirement.
However, we strongly urge the Commission to revise its interpretation of underwriting rules to
allow LPFM and NCE-FM stations to broadcast enhanced underwriting announcements that
may include promotional content such as calls to action, comparative references, pricing, or
qualitative descriptions—provided that total sponsored content remains limited to ten minutes
per hour. This maintains the stations' nonprofit status and public service mission while giving
them access to the same type of support that commercial broadcasters rely on.
The current limits on underwriting language are overly vague, subjective, and unevenly
enforced. More importantly, they hinder financial self-sufficiency, especially for LPFMs or those
unaffiliated with larger institutions. LPFMs typically do not receive any funding from the Center
For Public Broadcasting (CPB.) Allowing limited commercial content under a time-based cap
would align with past FCC precedents on enhanced underwriting and would not require the
reclassification of LPFM as a commercial service.
Ill. Two-Station Ownership for All Nonprofits
Currently, Native American tribes are the only LPFM applicants allowed to own more than one
station. We propose expanding this eligibility to a// nonprofit LPFM applicants, with a maximum
of two stations per organization. This modest change preserves LPFM’s hyper-local mission
while recognizing the legitimate need for some nonprofits to serve adjacent communities or
operate regional services sustainably.
A strict one-station limit is no longer justified in today’s media environment. It prevents efficient
use of resources and creates artificial barriers to community growth. A two-station cap balances
scale with equity.
IV. Allow Fair Market License Transfers Within the Nonprofit Sector
Unlike NCE-FM or LPTV licensees, LPFM operators are currently barred from selling their
stations at fair market value—even if the buyer is another nonprofit. This restriction penalizes
nonprofit LPFM operators who have invested years of work and resources into their service.
We recommend the FCC eliminate this limitation and allow LPFM stations to be sold at fair
market value, provided the buyer remains a qualified nonprofit licensee. This aligns LPFM with
other public service broadcasting categories and provides greater long-term sustainability and
accountability. The nonprofit requirement itself is a sufficient check against spectrum
speculation. It further encourages LPFM licensees to be high quality public servants.
V. Concerns Publicly Raised by Other Advocates
Some LPFM advocates have publicly warned through the years that permitting commercial-style
underwriting could lead to the erosion of LPFM’s public interest mission or open the door to
corporate consolidation. We respectfully disagree.
First, as long as ownership is limited to nonprofits and time-based ad caps are in place, there is
no path for commercial broadcasters to enter the LPFM space. Second, the ability to sell a
station to another nonprofit is a reasonable right afforded to nearly all other broadcast licensees.
LPFM should not be the exception.
VI. Conclusion
We urge the Commission to take bold but measured steps to modernize LPFM and NCE-FM
policy by:
e Permitting expanded underwriting content, capped at 10 minutes per hour.
e Allowing all nonprofits to hold up to two LPFM licenses.
e Removing restrictions on license transfers between nonprofit entities.
These reforms will preserve the core values of the LPFM service—localism, diversity, and
nonprofit control—while ensuring that stations have the tools they need to survive, grow, and
serve their communities into the future.
Respectfully submitted,
Dave Solomon
LPFM Advocacy Group (LPFM-AG)
PO Box 25222
Greenville, SC 29616
April 8, 2025