FAQ: Can an LPFM station carry “syndicated” programming?

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It depends on what you consider as “syndicated” programming.

While there are some who feel that LPFM should be strictly about “local” programming, there are many justifications where “importing” programming from non-local sources can help meet local community needs.  This includes programming that touches on national and international current events, educational programming, cultural programming and for minority expat communities, a “link to home”.

Keeping it noncommercial

Care must be taken to assure that programming that is carried is “non-comm friendly”.  You must avoid programming offered by commercial programming sources unless you take the time to remove all commercial announcements and all references to commercial sponsors (which can be sometimes embedded in the programming and not in delineated commercial breaks).  Carrying commercial syndicated programming may not be an option without paying a much higher rate to the program producer. Most LPFM stations don’t have that level of funding.  Since commercials are prohibited on NCE (LPFM) stations, it would not be practical to have a “barter” agreement (carrying the national commercials in exchange for carrying the program).

Avoid time brokerage opportunities

Likewise, you need to be careful with programming or network offerings where the station will be paid for carrying a program.  For example, Immaculate Heart Radio (IHR) offers the Catholic network Relevant Radio to NCE stations. In return, depending on how much airtime is devoted to the network on a local station, the network will compensate the station based on a portion of “pledge drive” revenue.  While this is legal for full-service NCE stations, it may not be for LPFM stations.  This is due to a rule (§73.860(e)), that is unique to LPFM, that LPFM stations are unable to enter into any kind of an operating agreement, time brokerage or management agreement with a full-service broadcast station.  IHR (now operating as Relevant Radio, Inc.) is the licensee of dozens of full-service broadcast stations across the country.  For Catholic programming, EWTN may be a safer alternative.

Free programming is out there

With that, many LPFM stations are carrying national syndicated programming.  Programming like “Democracy Now!” is available free for all noncommercial stations.  Additional free block programming is available directly from program producers and from aggregation sites like Radio4All.net.  Some program producers also offer their programming free to LPFMs.  In many cases, they just want to hear their voices in other cities.  A good resource is the Radio Program Syndication, Imaging and Voice Overs group on Facebook.

Pacifica Network is your best option

Several dozen LPFM stations are affiliated with Pacifica Network.  Pacifica operates AudioPort, which includes a large assortment of talk and music programs that are available for affiliates to use throughout the day.  These programs are non-comm safe.  For LPFM stations, an annual Pacifica membership runs about $500/year, but with the vast assortment of programming available, it can be worth it.

Local programming pledges and syndicated programming

A small number of LPFM stations that, during the 2013 filing window, directly used their preference points to eliminate other applicants are obligated by their pledges to carry a minimum of 8 hours of local programming per day.  A list of those stations can be found on the Pledge List at REC.  Even for stations on that list, it does not stop what they do in the other 16 hours of the day (within all of the other rules, of course).  For LPFM stations not on that list, you have no specific restriction on carrying nonlocal programming, even though the station made a specific pledge on their application to do so, the station did not need to use that pledge in order to gain the station and therefore, they are under no obligation.

LPFM program content/station operations/noncommercial nature
Answer Date: 
Saturday, October 3, 2020