This document contains Chris Ichabod Murrays review of LPFM radio for the Oregon Country

Fair, as well as answers and response from the LPFM task force that has been working on the project.
Chriss commentary below is in black type, response from the Task Force is in green type. Chriss
comments are addressed below each question or section of questions. There are general points of
clarification, and the intent and philosophy of the KOCF effort, located at the end of the document.
Ichabod:
I would suggest that the board gets this information and put it out to the radio partners and have those
radio proponents answer them to the board at the next board meeting in February
Managing a Radio Station or Who does what
This is a list of what is required to manage and run a FCC licensed radio station. It is to inform and
advise the board of directors and management of the OCF as to whom will be the responsible parties. It
is divided into finance, programming, public affairs, and technical.
Task Force:
Many of these questions are based entirely on the paradigm appropriate to the traditional not-for-profit
(npr-type) station. These stations run at 10 thousand watts or more, and cover a geographic area many
magnitudes larger an lpfm radio station that runs at only 100 watts.
While at the core, there are many similarities, in that content is either being created, or Public Domain
content assembled and then transmitted over the public airwaves the entire organizational model upon
which most of these questions is based have little relevance to a small 100 watt station with a very
small broadcast footprint. This is a critical distinction that must be understood.
It is very similar to using the operational/business model of a commercial enterprise such as
Lolapalooza or Bonnaroo and requiring the Country Fair to follow that model before selling any tickets
to the public.
Ichabod:
FINANCE (according to the plan submitted in the November board meeting)
1.The radio station will earn income by fund raising. This is done by over the phone pledge, on line
pledge and paid by check or credit card. This is usually done two to four times per year.

Task Force:
This is an outdated model.
In reality, many lpfm's rely on on-line donations, with all fund-raising activity driving traffic to its
website and with commonly used on-line systems available for the contributions.
Even full power stations (i.e KPLU and KUOW in the Puget Sound region) with phone drives are
in fact gaining the vast majority of their income directly via web contributions hence the

actual revenue being derived from the dreaded phone campaigns has become less and lessrather, the on air efforts are being used to drive listeners/supporters to the web site.

That noted:
Ichabod:
a.Who will be answering the phones
b.Where will the phone lines come from?
c.Who will do the follow-up on pledge calls?
d.Who will mail out the pledge requests? (billing)
e.Who will process the credit card data submitted?
f. Who will be responsible for the accounting of the final amount of money raised during the
fundraiser?

Task Force:
This will be handled by a Fund Raising Committee, made up of community members with
an interest and aptitude for developing the entire, fund raising system in a wholistic
manner once there is a clear assurance that the OCF Board will not reverse its position
and pull the entire rug out from under the project.
Under no circumstances should any organization ever offer false hope to a community,
which putting this committee into place would do if it was then forced to shut down.

Ichabod:
2.Crowdsourcing
a.Who will be responsible for collecting money submitted on line.
b.Who will process those contributions that are done by credit cards?
Task Force: Please see above.
Ichabod:
3.Underwriting
a.Who will be responsible for going out into the Veneta Elmira community and selling
underwriting announcements? This will be a salesperson.
b.Who will schedule those announcements on the program log?

c.Who will responsible for accounting that the spots as scheduled aired at the time they were
scheduled.
d.Who will be creating the invoice and mailing it.
e. Who will be doing the accounting for payables and receivables?
f.Who will do the collections if they do not pay?

Task Force:
As with any ongoing fundraising effort (a member of the task force personally raised
among other things- a little over $400K for a state environmental initiative, $2.8M for a
HUD Grant to build a long term nursing facility, and approx. $7.2M for a presidential
campaign), the task is broken into clear sections so as to make each task less
intimidating and more prone to success.
To identify by name the individuals who will be handling each task at this juncture would
amount to folly, but under the large umbrella of fund raising will come specific areas such
as crowdsourcing, memberships, sponsorship, capital /operational earmarking, etc.,
separated for both accounting purposes as well as to follow the letter of current IRS
regulations.
It is hoped that the person who crafted these excellent questions can be counted on to
volunteer his time in the ongoing KOCF fund raising efforts.
Ichabod:
PROGRAMMING
As yet nothing has been discussed about programming. If you are going out to the community at large
by crowdsourcing, underwriting announcements, and fund raising you need to define the product you
are selling. You are competing with other public radio stations for the same share of them pie.
Task Force:
Again this statement is based on a paradigm very appropriate to a full power station, but not so a 100
watt station serving a much smaller area.
Furthermore, to get people excited and engaged in programming before the technical issues have been
resolved and there exists an assurance of continued organizational support, it would represent the
height of arrogance to invite high school kids or local storytellers to plan programming only to have
such yanked away.
Upon issuance of a broadcast license, there is a multitude of free content immediately available, from
organizations such as the Northwest Community Radio Network (and others) to satisfy the immediate

need for content as other parts are finally able to come into play and the community fully engaged with
the programming it wants.

Ichabod:
Broadcasting is about content. You cannot raise money on a concept that this is the fairs station
therefore it deserves support. You have to have content.
Task Force:
In fact the Fair, in its official capacity, has indicated it wants very little to do with the project, so it will
be left to the neighboring community, hopefully with positive support from the OCF to make
recommendations as to that content.

Ichabod:
Before the station signs on the air in June you will need to have a list of programs that will fill an 8
hour day, five days a week. Thats 40 hours of programming each week, 52 weeks a year. What is your
product?
Task Force:
It is strongly suggested that anyone presenting questions to the Task Force become fully acquainted
with the actual Construction Permit and the details within it, as well as with the original application as
approved by the Board of Directors prior to its submittal.
In fact the obligation as per the Construction Permit is for 5 hours of programming per day - none of
which needs to be locally produced or live it can literally be canned product and may well be for the
first few months of operation due to the delays the Task Force continues to encounter which is
preventing any active outreach/programming, even that related to the thousands of hours of internal
material owned by the OCF.

Ichabod:
1. Has any research been done to determine what type of programming will be aired and if the
local businesses in the area support that type of programs and would be willing to underwrite it?
2. If programs will be provided by volunteers has enough interest been created to determine if there
are enough volunteers to provide the necessary programming to fill the time?
3. if the programs are to be provided by outside parties have contracts been created for providing
those programs?

4.

Has a program schedule been created and distributed such that interest can be created for
specific contents?

5. Who will be responsible for ensuring programs get on the air (program director)?
Task Force:
It is expected that a Program Committee will be established, made up of community members and
to hopefully include representatives of the OCF, to oversee the programming issues being
raised.
However, due to the delays and uncertainty of the basic organizational support essential before
going very far into the community this element, like so many others, has not been able to be
pursued in good faith.
The question of 'filling time' is more an issue for the full power station required by the FCC to
produce local programming a situation that does not apply to this station, as per the approved
application and Construction Permit-both of which need to be understood so as to have a
productive dialog.
To address the often alluded to but unstated question of programming that some OCF members
might not like - it must be remembered that as a true community radio there may well be things
not everyone approves of (the first amendment remains content neutral) but with an active
Programming Committee, such situations can be kept to a minimum.

Ichabod:
PUBLIC AFFAIRS
The FCC requires all radio stations to ascertain from the community ascertain the issues and problems
confronting the community. Then air programs to meet these issues and problems. It is called the issues
problems list.
1.Stations must interview members of the communities at large, community leaders both public and
private and have them list what they think are the most issues and problems to be aired.
2.From these ascertainments, a list is created. Usually ten issues/problems are on the list.
3.Programs are created to address these issues and or problems.
4.The list of issues, the accounting of the airing of these programs, issues discussed, time and date
of the program, title of the program are to be documented.
5.Four times each year, the list and the programs are collected and placed in the stations public file.
This file needs to be available for public inspection a minimum of 7 hours daily, 5 days per
week. The dates are January 10, April 10, July 10, and October 10.
Who will be responsible for insuring that issues are collected, these programs are aired and the
documentation placed in the stations public file?

Task Force:
Again, a careful reading and understanding of the FCC Form 318, the original application submitted to
the FCC which resulted in an awarding of the Construction Permit (CP), will be most useful.
The OCF chose to gamble and NOT seek the local community production option, or the open studio
option thus eliminating this entire issue as presented. Had there been another application for the
same frequency that had chosen to take those options and the corresponding points they would
have received the Construction Permit and not the OCF.
The permit applied for, and CP granted, is literally the 'transmitter in a closet' option- this allows for
canned programming throughout the required day- with any additional program to be produced at our
option and on our time frame. This is far different than a full power not-for-profit station that needs to
comply with a set of regulations far different than those established for a low power FM especially an
LPFM that applied for, and was granted, the 5-hour day option.

Ichabod:
TECHNICAL
Who will be the Designated Chief Operator? This is the person who must review the station Logs
and be available of the station is to be inspected by the FCC. They are divided into two files.
Station Logs contain the following; (Available anytime for FCC inspection)
1.A record of all EAS receptions signed and dated.
2.A record of all EAS transmissions signed and dated.
3.If the station does not run 24/7, them notations of sigh on and sign off times.
4. A monitoring of transmitter output power needs to be inspected every 3 hours and notations
made of transmitters operating over or under licensed power. (90 105%)
5. Maintenance records made of remote control calibrations and frequency checks.

Task Force:
This IS required of any LPFM, with operational responsibility falling to the Station Manager (and
no as for the many reasons already stated, that person has not been identified)
For general information, the Chief Operator can be and often is the same person as the Station
Manager not to be confused with the Chief Engineer.

Ichabod:
Public Files contain the following; (Available to the public during all public working hours)
1.Public and Broadcasting a procedural manual
2.Ownership reports (Includes board members and officers)
3.License and coverage maps
4.EEO reports (if the staff is over 5 members)
5.Contracts
6.Letters from the public
7.List of Donors to the station.
8.Issues and Programs (Public Affairs)

Task Force:
This is simply a boilerplate list as to be found in any radio guide and is material generally stored
in an office or studio - under the control of the Station Manager or her/his designee NOT accessible 24 hours a day, but accessible with a reasonable appointment just as are
the records and similar material pertaining to the Oregon Country Fair available to anyone
at the OCF Office.
The only divergence, as discussed earlier, is the requirement for the Issues and Programs
document. However, even though not required, it can be expected that such will be
maintained as a standard part of the file.

Ichabod:
Who will be responsible for maintain the public file, and who will be designated chief operator that
reviews the station logs each week.
Task Force:
These will be the responsibility of the Station Manager and/or her/his official designee - a person
whose service has not been sought as yet due to the ongoing delays and general uncertainty of
continued organizational support of the Oregon Country Fair.

Ichabod:
If the station operators have a Local Management Agreement (LMA) with the Oregon Country Board
then all these questions listed above need to be agreed to in that agreement. The board will need to

review these items from time to time to insure the license holder (The OCF) is protected. Any variance
of non-compliance issues that arise can be cause to cancel the agreement.
If the station is operated without any management agreement then the management of the station
resorts to the officers appointed by the Board. In other words;
Station Manager, Charlie Ruff?
Designated Chief Operator, Tony C. ?
Receivables Norma ?
Accounting Hilary?
Program Director ???
You are asking the staff of the Oregon Country Fair, in whose name the license is under to take on the
responsibility of managing and running a radio station. Before this project goes forward I would
strongly ask those proposing building a radio station answer these questions.
It is one thing to have a license and have an opportunity for volunteers to come up with clever
programming that will capture enough of an audience in the area to be successful. It is another to
manage a station and take care of all the required legal work that it takes to run a station.

Task Force:
A similar arrangement was proposed over 2 years ago to have the OCF act as the fiscal agent for a
state non profit (entirely permissible by both IRS regulations and the OCF Bylaws) with all the usual
financial/operational firewalls in place to effect precisely what an LMA would do to address the
issues of staff time, other organizational responsibilities and the simple fact that the organization has a
fair to produce and it was felt there was no need to place any additional strain on current capacity.
That suggestion/proposal was squashed by senior staff before ever reaching the Board.
An LMA is an alternative, and one that should be put into place either before the license is issued, or as
soon after as possible.
In reality, because of the very limited broadcast requirements of KOCF, it can be legally operated as an
audio placeholder running freely available, packaged content from the source already identified, or
others until the LMA is crafted and approved effectively removing ALL the people named in the
question from any responsibility whatsoever, as has been the desire of the Task Force all along.
Ichabod:
If the OCF signs on a station remember you will be competing with 6 other public stations. All these
stations serve the Elmira/Veneta Community over the air. They Are;

KWVA 88.1 from the EMU/U of O

KQFE 88.9, Family Radio (Many of their contributors live in Veneta/Elmira)
KLCC 89.7, LCC
KWAX 91.1, U of O
KRVM 91.9, 4J
And the Oregon Peace Works will be signing a LPFM station this year as well.
You have a lot of competition. You had better have a killer format.
ICHABOD (signature)
Task Force:
This is all understood and has been since before the final Form 318 was issued, completed and
submitted, and in fact was understood immediately upon the passage of the The Local Community
Radio Act of 2010 when the possibility of a Country Fair LPFM was first broached with fair
management to a warm reception.
A few points of Clarification Oregon Peace Works was granted a CP, but it is very unlikely they have the internal capacity
(volunteers or funding) to actually go on the air. The Task Force has been in regular communication
with them initially seeing opportunities for collaboration, which may still happen, but it is not
looking favorable.
The college radios and the NPR stations have their well-established niche in the radio market. It should
be noted that a number of current and former staffers at both KVRM and KLCC have offered their
strong endorsement for KOCF, as well as having offered to volunteer in many capacities when the
future of KOCF looks secure and no longer subject to random distractions or obstacles that could
destroy the opportunity before it can flourish.
The entire philosophy behind the national LPFM movement was - and remains - to offer LOCAL
opportunities to LOCAL residents to make media using an area of the radio spectrum that (contrary to
the National Association of Broadcasters and NPR's decade-long argument) in no way interferes with
the transmission of full power stations, or negatively affects the revenue stream of the not-forprofit/NAB stations. However, as LPFM stations increase their offerings the bigger not-for-profit (as
well as for-profit) stations may find it advantageous to provide more content people want as opposed to
what their corporate sponsors demand!
The Oregon Country Fair is not a community college or state university; it is not a religious
organization, or a commercial entity answerable to its shareholders, nor is it affiliated in any way with

National Public Radio or the National Association of Broadcasters the two main opponents of LPFM
since the original bill came before congress in 2000! Rather, OCF is a loose affiliation of people
sharing a common set of values and ideals that exists in a semi-rural area of farms and homes that are
increasingly occupied by people sharing many of those ideals. We can not hope to change/save the
world if we can not talk to - and with - our neighbors, and share many of those ideals we have lived
with all our lives. This, at its core, is what KOCF is all about.
We invite you, the entire board and staff to join us....even as we agree to do all the work!