Advisory Letters

Revised April 22, 2021

This Advisory Letter is a reminder to LPFM (and for that matter, full-service noncommercial educational station [NCE]) licensees regarding various activities that can be considered an “advertisement” in respect to the language of the Communications Act.

Section §399b of the Communications Act (47 USC 399b) states:

(a) “Advertisement” defined

This REC Advisory Letter is to advise LPFM licensees of a pending rulemaking proceeding before the FCC.  This is an overview of the proceeding and our initial analysis of the impacts to LPFM and potential positions that will be taken by REC Networks in respect to this proceeding.  As with any proceeding, REC always welcomes the input from LPFM licensees, including those that REC has not worked with in the past to provide input. 

“Relevant Radio” is the brand name of a radio service operated by Immaculate Heart Radio (IHR).  Relevant Radio is a 24-hour Catholic programming service that provides a noncommercial programming source to affiliated stations across the country as well as through digital delivery.  IHR, operating as Relevant Radio, Inc. owns several dozen full-service AM and FM broadcast stations and has been commended in the past by REC for preserving the legacy call letters of the stations that they acquire, including the infamous KHJ, Los Angeles.  A couple of years ago, IHR had converted their stations from noncommercial educational to commercial and in their markets have been selling time.  This, while maintaining a noncommercial stream for affiliated stations not owned by IHR.