Russ Edmunds wrote:
> --- kevin redding <[EMAIL PROTECTED]> wrote:
> 
>>> No it isn't. It will put the small local guys out of
>>> business.
>> I am interested in this statement.
>>
>> How will it put stations out of business if they go SP from 0000 to  
>> 0500 local?
>>
>> Seems like this is a little dire to me. I will be the first to say  
>> that I am not in the radio business and don't know how it really  
>> works, so I ask the question above.
> 
> I think he meant manning the station 24/7 would do that. But I agree
> with Patrick - if they're that marginal and they're making no money
> being on 24/7 anyway, then do an SP...

Before Kevin accuses me of having a dog in this particular hunt, let me 
say off the bat that my part-time employer, WXXI(AM), maintains its 
"control point" downstairs in the master control of our sister station 
WXXI-TV, which is already staffed 24/7, so this rule would have no 
effect on our present NSP operation, as best we can make out.

That said...

Overnights in the contemporary world of radio are a strange beast. I 
don't think there's a station out there, even the biggest, that makes 
any significant amount of money from its overnight programming. And I 
say that as an alumnus of one of the few stations (even when I worked 
there, more than a decade ago) that spends a significant amount of money 
actively and locally programming the overnight hours. That would be WBZ, 
of course, which has live, local talk all night long.

It's a pretty good bet that whatever money BZ makes from selling ad time 
during its overnight hours (less than you'd think) is pretty well eaten 
back up again by the salaries of the hosts (a full-timer during the 
week, a part-timer on the weekend, and fill-ins as needed) and the 
producer. This is especially true because the midnight-6 AM time period 
is essentially unrated by Arbitron; one can pull out very sketchy 
ratings data out of Arbitron's Maximiser software, but nobody really 
bothers to do so.

So why keep BZ or WINS or WFAN or KGO - or my local WBEE-FM, the only 
station here that's live overnight - humming along with live overnight 
programming?

Much of it has to do with the morning show. As people begin commuting to 
work earlier and earlier, and as the number of people working overnight 
shifts inches up, anything that will give your station even a slight 
edge in the lucrative morning-drive hours is worth pursuing. So the 
theory is that if someone is up at 4 AM for whatever reason, they'll be 
more likely to have your station dialed in two hours later (when ratings 
and revenue kick in) if you give them a reason to tune in during the 
otherwise unprofitable overnight hours.

For everyone else who's gone 24/7 in the last few decades, whether 
through satellite programming or automation, the rationale is actually 
quite similar: even if they're not doing anything live and local during 
the overnight hours, and even if they're not selling any local ad time 
during those hours, they'd still rather have you hear SOMETHING if you 
happen to flip the radio on at 3 AM (or set your alarm for 4:45, or what 
have you) than to have you encounter static and tune somewhere else.

Which brings us to the question Kevin posed above - "how will it put 
stations out of business if they go SP from 0000 to 0500 local?"

By itself, it won't. But aside from those of us in the DX community, for 
whom the benefit would be obvious, there are a lot of potential 
negatives here that add up to bad news for radio as a whole.

Consider: for the big group-owned stations, this rule is truly No Big 
Deal. Any cluster of three or four or six stations in even a 
medium-sized market can absorb the cost of one overnight caretaker with 
relative ease - heck, just have one of the production guys work until 1 
or 2 AM, and by then you've got a morning-show producer or news guy in 
house to watch the needles move until the morning show starts at 5 or 5:30.

It's the smaller stations that will get hurt by this rule. There aren't 
many one-man stations left out there (hey, Paul Walker! howdy, Bob 
Bittner!), but there are plenty out there that make a go of it with 
staffs of fewer than five people. A surprising number of them are not 
only moderately profitable, but are providing local service to small 
towns that wouldn't have it otherwise. (I'm thinking here of stations 
like WHLM in Bloomsburg, PA, or Dennis Jackson's WRIP in Windham, NY, or 
Michael Richard's KEVA in Evanston, WY.)

Even these stations probably *could* find some way to reassign staff to 
keep a warm body in the building overnight, but at much greater relative 
expense than the big guys. (I'm not even touching here on some of the 
other new re-regulatory proposals, for things like community advisory 
boards, that will add even more burdens to the workload of small 
broadcasters.)

Instead, it's likely that they'd sign off, some of them perhaps as early 
as 9 or 10 at night...which instantly makes them second-class stations 
by comparison with the big-city, big-group operators that can stay on 
all night with ease. Is that the message the FCC is trying to send?

And (again, aside from DXers), how is the public really thus better 
served? If my grandmother can't sleep in the middle of the night and 
enjoys listening to the (voicetracked) standards on WLGZ 990 - as indeed 
she does - how is radio's service to her improved if WLGZ instead signs 
off at 11? (Especially when other competitors, whether it be satellite 
radio or webcasters or what have you, can keep going 24/7 without the 
additional regulatory load.)

Getting back to WXXI for a moment, one reason I haven't been able to get 
a DX test scheduled on 1370, much as I'd like to, is that we have a 
small but intensely loyal band of insomniac listeners who value our 
overnight BBC World Service programming, and management doesn't want to 
shock them out of their near-slumber with sweep tones and code and 
military marches. As noted above, we're covered in the event of a 24/7 
mandate anyway, but there's no way we'd be staffing overnights if we 
didn't already have someone in TV master control. There are plenty of 
standalone public radio stations I can think of that will assuredly be 
going dark overnight if these rules become reality. That doesn't seem 
like an improvement in public service to me.

It's not even clear to me how or why the FCC thinks this requirement 
would improve the dissemination of emergency information. By definition, 
a station that's off the air can't disseminate any emergency information 
at all. The technology has improved dramatically, just in the last few 
years, to allow local emergency officials to work together with 
broadcasters to get urgent messages on the air with no human 
intervention at the radio station's end. Why make that harder to 
accomplish by reducing (perhaps dramatically) the number of signals on 
the air to broadcast those messages?

You can't, in the end, change programming through legislation, and that 
seems to be to be the thrust of these proposed rules changes, especially 
some of the ideas about restoring the old main-studio rules.

The more efforts are made to tweak the rules to get to the desired 
result, the greater the risk of unintended consequences. Let's say, for 
instance, that the FCC decides to make the overnight-staffing rules 
apply only to stations with 6 or more full-timers...you'd better believe 
there will be a bunch of people suddenly losing jobs at stations with 7 
or 8 employees!

There was a great article about this in the NY Times Magazine last weekend:

http://www.nytimes.com/2008/01/20/magazine/20wwln-freak-t.html

Sorry to have rambled a bit here - this is a topic that's been on my 
mind (and on the minds of a lot of people in the business) over the last 
few days. At a time when radio, and especially small radio, needs all 
the competitive help it can get, this looks very much to me like the FCC 
moving backward. It will be interesting to see what kind of comments 
come in once the comment period begins!

s






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