Statement of REC Networks

In order to protect the integrity of the LPFM service by preventing commercial influence through speculation and “shadow ownership” (control of a station by an undisclosed third party), REC has filed Informal Objections against applications where it was supsected that speculative behavior was taking place. In other words, a single party filing for multiple facilities with the intention of either building a radio network or to sell the permits to other parties for a profit. 

It is important to remember that LPFM does have a national ownership cap of one station (with exceptions for tribal entities and public safety agencies).  REC supports the national ownership cap and we will defend it from speculators and others who choose to abuse the system.

In the 2013 LPFM window, REC filed informal objections against hundreds of applications including a large group that was originated through the same person with corporations formed just prior to filing, all filings in the same state and all with similar sounding names. Many of these stations used names that gave them the appearance of Hispanic Christian organizations. 

Throughout the proceedings that followed the filing of the applications and our original objections, in responsive pleadings and objections to subsequently filed applications, REC was painted by opposing counsel as an organization that hates Hispanics and hates Christians.  In a separate proceeding for Foundation for A Beautiful Life, REC was painted as anti-Asian.  We find that strange since we have been programming Asian music for over 20 years on a noncommercial basis in order to promote cultural understanding and appreciation. 

It is important to realize that while a large number of the applicants for which REC filed objections against in the 2013 window had cookie cutter names that sounded like Hispanic Christian ministries, we never targeted any race or religion.  It is important to remember that REC also filed objections against applicants who were not Hispanic and proposed secular names and educational statements. We only cared about how they filed, not where their ancestrial hertiage is from nor what god they worship.  This is not how REC operates.  Yet, some are very quick to play the race card when they have nothing else to hold on to.

In cases where we filed an objection and then was able to verify the parties to the application, we would withdraw the objection to permit the grant and in some cases, those stations would turn to REC for further assistance.

As a result of the objections filed against these applications, we have uncovered attempts to sell stations under the table in Miami, Costa Mesa CA and other places.  We identified applications where no facility was ever built.  We called attention to the issue of this kind of filing that goes against the spirit of the LPFM service.  These filings also influenced the Commission to investigate these applicants and as a result, change the rules on site assurance after it was independently determined that many of the speculative applications never obtained assurance from tower owners and were aribtrarily dropped into locations. 

Unresolved applications and objections remain in Charlotte, Albuquerque, Baton Rouge and Norfolk, VA.  Today, the license application for a station outside of Pittsburgh was dismissed after it was shown by someone local that the facility was never built. 

As we go forward to another window sometime in the next 2 years or so, we need to be aware that some of the same “players” who were in the 2013 and 2000/2001 LPFM windows may be back to try again.  The FCC can only do so much within the confines of the law, but now, they will be more aware of it.

In the next window, the local community needs to get involved. The applications that got the most action taken on them in light of objections were those where there was local involvement. Local testimony carries weight at the FCC.  I am not prepared to say what REC’s involvement will be in the next window on this front, but we are watching and we are developing tools to assure that our “one to a customer” rule that we have in LPFM is properly followed.

REC has a policy of working with stations regardless of their language, heritage of the parties, religion or political views.  Where we draw the line is when the spirit of the rules are being compromised, no matter who is doing it.