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The proposed low power radio service gives the Commission what may be its last and best chance to reintroduce a locally-based, locally-produced program service, and thereby meet its statutory mandate of localism, embodied in Section 307(b), that has been at the heart of the Communications Act's public interest goals. To ensure that low power radio does not become a replica of currently-existing services, UCC, et al. call upon the Commission to require that half of each low power radio station's programming be locally originated. UCC, et al. also insist that the Commission adopt ownership limits that will ensure that the low power radio service can add diverse and independent perspectives to the marketplace of ideas. The Commission must also limit one license per entity. To this end, UCC, et al. propose noncommercial attribution policies to complement the commercial attribution rules, thereby ensuring that the ownership limitations the Commission adopts for noncommercial stations are not easily thwarted. The Commission should also adopt strict anti-trafficking rules.

The Commission cannot exempt low power radio stations from the public interest requirements of the Communications Act. As such, the Commission must adopt simplified rules that require low power licensee compliance with the public interest standard as well as the political programming and sponsorship identification requirements of Section 312, 315, and 317 of the Act. EEO rules, ownership reports and other basic information disclosures, such as maintenance of public files, must also be applied to low power licensees.

UCC, et al. strongly support a noncommercial low power radio service. In addition, while UCC, et al. also support creation of a commercial low power service, UCC, et al. do not believe that the need for commercial stations outweighs the need for noncommercial stations. It appears that successful commercial stations may require the stations of the highest power, the LP1000 stations. Given that insufficient room for even one LP1000 station may exist in many large cities, UCC, et al. believe that smaller, noncommercial stations should receive priority. Thus, if the Commission chooses to authorize a fully noncommercial low power radio service, it should not limit noncommercial low power stations to the reserved spectrum.

To be eligible for a low power license, UCC, et al. propose two discrete criteria. First, a noncommercial low power applicant must certify that a majority of its board of directors resides in the station's service area. Second, an applicant must demonstrate that it is tax exempt under the federal tax code.

To allocate low-power licenses, the Commission should adopt a plan that balances between assigning licenses to organizations that will promote broad community access to the airwaves and allowing all applicants a fair chance to obtain a license. The Commission should adopt a two track allocation approach. The first track would include non-profit organizations such as churches, schools, libraries, colleges, and community access organizations, using a simplified comparative point system to select among these applicants. The Commission should then distribute remaining licenses using lotteries that incorporate the statutorily-mandated preference for entities controlled by minority groups.

Finally, the Commission cannot rely solely on an electronic application process. The communities that will be most in need of a low power radio station may be the least likely to have access to computer technology. The Commission cannot exclude the communities and individuals most in need of low power radio from even filing an application.

UCC, et al. does not address the technical aspects of the low power radio proposal here, because we will do so in its reply comments in this proceeding.

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