In the Matter of CARRIER-CURRENT RADIO SYSTEMS OPERATING PURSUANT TO SECTION 15.7 OF THE COMMISSION'S RULES AND LOW-POWER COMMUNICATIONS DEVICES OPERATING PURSUANT TO SUBPART E OF PART 15 OF THE COMMISSION'S RULES
Docket No. 19092
FEDERAL COMMUNICATIONS COMMISSION
28 F.C.C.2d 357
RELEASE-NUMBER: FCC 71-312
April 9, 1971 Released
Adopted March 24, 1971
BY THE COMMISSION: COMMISSIONER HOUSER CONCURRING AND ISSUING A STATEMENT IN WHICH COMMISSIONERS BURCH, CHAIRMAN, ROBERT E. LEE, AND WELLS JOIN; COMMISSIONER BARTLEY NOT PARTICIPATING; COMMISSIONER JOHNSON DISSENTING AND ISSUING A STATEMENT.
[*357] 1. Notice of Inquiry and Proposed Rule Making in the above entitled matter is hereby given.
2. There presently exist under Part 15 of the Commission's Rules provisions permitting the operation of restricted radiation devices on standard broadcast frequencies with low strength signals, subject only to the technical operational limits set forth in the applicable sections of Part 15 of the Commission's Rules. One type of device is the carrier-current system which is operated pursuant to Section 15.7 (47 CFR § 15.7) n1; these self described "college radio stations" have been chiefly popularized and used on college campuses, although we are informed that many high schools as well as other institutions operate such stations. Another group, categorized generally as low power communications devices, are miniature transmitters operating under Subpart E of Part 15, and our recent experience indicates that these devices have been operated mostly by hobbyists who emulate broadcast station formats.
n1 The operation of carrier-current devices is described more fully in para. 4, infra.
3. In both of the foregoing types of operation, the Commission has assumed that the low power restrictions provided in Part 15 would ensure that prospective recipients of the radiated signals would be confined to those in close proximity to the transmitting source, thus limiting the impact of such operations on the general public and conventional broadcast stations. However, the Commission has become aware of various designs to expand the coverage of both types of operation, the expansion to be effected through interconnection methods. [*358] One development involving carrier-current radio occurred in October 1969, when the Commission was approached by carrier-current radio systems WJC, Juniata College, and WFIB, University of Cincinnati, with requests for authority to expand their respective activities beyond the area of the immediate college campus. In the case of WJC, the system proposed to have its signal picked up by a local CATV system and distributed to the general public. n2 In the case of WFIB, the system proposed to feed the signal of its station, via AT&T lines, to other college radio systems throughout the country, thereby establishing a carrier-current radio network. n3 Another illustration of carrier-current system proposals in seen in an article in the February 28, 1970, edition of Billboard Magazine (p. 34) which described the proposal of WBCR, the carrier-current radio system of Brooklyn College, to locate interconnected carrier-current transmitters carrying the programs of WBCR over a large area in local businesses, banks, etc. In the area of low power communication not involving carrier-current systems, the Commission was advised of the efforts of one group to organize a 25 station (or more) network of restricted radiation devices which would simultaneously transmit programs throughout the New York City area. Thus, we have seen Part 15 devices of several types develop into integrated communication facilities capable of reaching significant numbers of listeners.
n2 FCC 69-1138, 20 FCC 2d 447.
n3 FCC 69-1137, 20 FCC 2d 287.
4. At this point, we believe it would be useful to briefly describe the history of carrier-current radio. A carrier-current radio system is one which is authorized to operate as a low power radiation device pursuant to Section 15.7 of the Commission's Rules. The station signal, a modulated RF signal, typically is conducted along power distribution wires to buildings on a campus or other institution; and systems using this technique are required, under Section 15.7, to use the minimum power necessary to accomplish this purpose. n4 Carrier-current systems were originally permitted to operate in this manner under the Commission's 1938 Low Power Rules -- the forerunner of Part 15. While the Commission recognized that these stations would operate in the frequency bands allocated for licensed broadcast stations, it was of the view that carrier-current operations meeting the specified minimal power and radiation limits were in the public interest, since such systems were intended to function as training laboratories for students interested in the communications arts and signal reception was generally limited to the campus or comparable area on which the system was located. It was felt that under these restrictions, such systems would not cause interference to, or have any significant impact upon licensed broadcast stations or the general public.
n4 Because of the physical laws attendant to this technique, some radiation from the conductor is inevitable and the signals "leaked" in this fashion allow receivers in close proximity to the conductor to pick-up the signal without actually being attached to the distribution system.
5. Over the years, the Commission has several times reviewed the conditions under which carrier-current systems operate. In 1949, the Commission issued a Notice of Proposed Rule Making which looked toward the licensing of such systems and permitting them to operate [*359] in accordance with the general rules governing broadcast stations. n5 The Commission received many comments regarding the proposed rules from persons in favor of permitting the continuance of carrier-current radio systems but who were apprehensive about the formalities of licensing procedures. Thereafter, in 1954, the Commission issued a Further Notice of Proposed Rule Making, abandoning the licensing plan and proposing to allow carrier-current systems to continue to operate under power and radiation limitations similar to those imposed by the original Low Power Rules. n6 Carrier-current systems thus continued to operate according to those strictures and, in 1964, the Commission terminated its proceeding in Docket No. 9288, noting:
n5 In the Matter of Amendment of Part 15 of the Commission's Rules Governing Restricted Radiation Devices, Docket No. 9288, FCC 49-459, April 13, 1949, 14 F.R. 2033. In part, the proposed 1949 rule reads as follows:
"1. Because of the social impact of broadcasting upon the general public and the responsibilities of the Commission in regard to the regulation of broadcasting; and
"ii. Because of the probability of interference being caused to reception in the standard broadcast services by the operation of devices in this band in view of the number of broadcast receivers and transmitters now in operation:
"A. Broadcasting on these frequencies will only be permitted in compliance with such rules and limitations covering eligibility, licensing, technical standards and other subject as may now be found in the Commission's Rules Governing the Standard Broadcast Services, or as they may hereafter be amended."
n6 Further Notice of Proposed Rule Making, Docket No. 9288, FCC 54-502, April 15, 1954, 19 F.R. 2319. The proposal therein reads, in pertinent part, as follows:
"15.104 Carrier Current Systems Operating Above 425 kc.
* * *
"(a) The following provisions shall be applicable after the effective date of these rules to all carrier-current systems which operate on frequencies between 425-1605 kc for the purpose of distributing programs to more than one broadcast receiver, provided, however, that until June 30, 1955, existing carrier-current systems in this band shall be required in the alternative to meet the radiation limit of 15 microvolts per meter at a distance from any radiating source of 157,000 feet divided by the frequency in kilocycles:
"(1) radiation shall not exceed an intensity of 40 uv/m at distances of 100 feet or more from any radiating source, provided, however, that such radiation shall not exceed 15 uv/m at the border of the property exclusively under the control and for the exclusive use of the owner and operator of the system."
The remaining, still unresolved area in this proceeding deals with the conditions under which carrier-current systems (including campus radio systems) should be operated. These systems are presently regulated by the general provisions in § 15.7. The problems involved in devising new regulations for such systems have not been resolved nor does a solution appear to be imminent. Moreover, the data pertaining to carrier-current operations submitted in this proceeding are now out of date.
Having accomplished the bulk of its objective in this proceeding, and since § 15.7 appears to be reasonably satisfactory in regulating the operation of carrier-current systems, the Commission is of the opinion that the proceeding in this docket should be terminated. If it should appear that further regulation of carrier-current systems is required, the Commission will institute a new proceeding. n7
n7 Fourth Report and Order, released on April 17, 1964, 29 F.R. 5399.
6. Since the termination of the above proceeding, the number and scope of carrier-current systems, particularly on campus, has steadily increased, reflecting not only the very substantial rise in the size of college facilities and populations, but also a growing interest in such systems as important communications vehicles. We have also noted the present character of these operations as depicted in a recent survey of radio on campus conducted under the auspices of the Corporation for Public Broadcasting (CPB) and the Ford Foundation. n8 Among other things, the CPB Study points out that the average carrier-current campus system (1) has a capital investment of $5,654; [*360] (2) is exceptionally well equipped, and has a staff of 46 persons (virtually free of faculty supervision); and (3) is commercial with advertising income averaging $5,344 annually. Advertising is sold by the operator directly or through one or several national representatives for college radio operations and other marketing enterprises.
n8 Vincent M. Badger, The College Radio Study: Report on Student Operated Stations at Colleges and Universities (July, 1969).
(7. Not only have the dimensions of the individual systems continually increased but, over the past several months, the Commission has been receiving requests from carrier-current systems, such as those from Juniata College and the University of Cincinnati seeking permission to expand service beyond their respective campuses. In light of these requests for expanded service and the data set forth in the CPB Study, we believe that additional information about overall contemporary carrier-current system operation is necessary. Not reported on in the CPB Study and of particular concern to the Commission are the present policies and practices of campus carrier-current systems in such areas as the equal opportunities requirement attendant to political programming, personal attack and fairness doctrine, cigarette advertising, sponsorship identification and the like as well as programming source and distribution activities of such stations.
8. Accordingly, in connection with this inquiry, there is attached hereto a questionnaire which all carrier-current systems operating pursuant to Section 15.7 of the Commission's Rules and receiving this survey are instructed to complete and return to the Commission within 30 days of receipt thereof. Since the great majority of sizeable carrier-current operations are located on campus and since the Commission has access to the addresses of such stations, it is to those operations that the questionnaires are initially being sent. The questions generally relate to technical and programming matters. Also included are several questions relating to the commercial activities of the systems and we wish to stress that the responses thereto will be used solely for analytical and related purposes by the Commission -- such financial data will not be available for public inspection under Section 0.457(d) of the Commission's Rules. In addition, the Commission invites comments and information relevant to this proceeding concerning both carrier-current systems and low power communication devices from all interested persons and organizations, including non-commercial and commercial broadcasters, advertisers and educational institutions. Any such comments and other materials should be filed with the Commission by June 4, 1971.
9. Additionally, this Notice shall also constitute Notice of Proposed Rule Making looking toward the imposition of certain broadcast programming operational requirements on those carrier-current systems engaging in interconnection of two or more systems or interconnection of a system with other electronic media such as broadcast stations or CATV. The proposed programming operational requirements would be substantially similar to those imposed on WJC n9 concomitant with its authorization to interconnect with a CATV system. The imposed conditions require compliance with the following: Section 73.123 of the Commission's Rules (equal opportunities for political candidates and related requirements); Sections 315 of the communications [*361] Act of 1934, as amended, and Section 73.123 of the Rules (fairness, personal attacks, political editorializing); Section 317 of the Communications Act and Section 73.119 of the Rules (sponsorship identification); 18 U.S.C. § 1304 and Section 73.122 of the Rules (lotteries); 18 U.S.C. § 1464 (broadcasting obscene, indecent, or profane language); and, 18 U.S.C. § 1343 (fraud by wire and radio). Although exact wording is not proposed at this time, we do express tentative intent to embody the foregoing limitations on interconnected carrier-current systems contingent, of course, on responses to this inquiry and proposed rule making.
n9 See, Letter to Juniata College, of October 16, 1969, 20 FCC 2d 447.
10. Authority for the inquiry and proposed rule making instituted herein is contained in Sections 3, 4(i), 301, 303, 307 and 403 of the Communications Act of 1934, as amended.
11. In accordance with the provisions of Section 1.419 of the Commission's Rules, an original and 14 copies of all comments, pleadings, briefs, and other documents shall be furnished the Commission.
FEDERAL COMMUNICATIONS COMMISSION, BEN F. APLE, Secretary.
CONCURRING STATEMENT OF COMMISSIONER THOMAS HOUSER IN WHICH COMMISSIONERS DEAN BURCH, CHAIRMAN; ROBERT E. LEE, AND ROBERT WELLS JOIN
I personally hope and expect campus carrier-current radio to grow and add diversity to our method and content of information. I would hope college students could appreciate our awareness of their growing importance. I am confident that my colleagues will not undertake any regulatory action of campus radio unless clearly warranted by the facts which are being solicited.
This matter was initiated by the staff many months ago before this writer was on the Commission. Indeed, the Commission as far back as 1949 began a rule making proceeding (Docket No. 9288) that contemplated licensing these stations. On termination of that proceeding in 1964, the Commission confirmed the continued operation of carrier-current systems as restrictive radiation devices, but also noted that the data base was stale and stated, "... [If] it should appear that further regulation of carrier current systems is required, the Commission will institute a new proceeding." Thus two things are clearly apparent, viz (1) institution of a proceeding is not necessarily a guarantee that the proposed or any new rules or policies will be adopted; and (2) the Commission clearly provided for a continuing review of these systems if the facts indicate such a course. In 1969, the Commission received the first of a number of requests to permit extension of the "service areas" of these systems through interconnection techniques via networking or CATV. Far from seeking to restrict or repress the development of these carrier-current systems, the Commission unanimously voted to approve these extension requests, just as it has approved similar subsequent requests.
The proceeding is primarily a fact finding inquiry to gather facts to gauge the "state of the art" on campus. The need for this inquiry appears to have arisen because of several requests by carrier-current radio stations for expanded service areas through connection to a CATV system, which would give a service area far beyond the area originally contemplated by the Rules. This also gives them at least some of the attributes of a licensed radio station that is carried on the CATV system. Also there has been at least one request by a system to transmit its signal via common carrier to other college campuses in a networking type operation. Under these circumstances the Commission can do no less than attempt to be reasonably up to date on developments in carrier-current radio.
In an incredibly political statement, Commissioner Johnson dissents from today's action. The Commissioner suggests that the present inquiry "emerged somewhat mysteriously from the bureaucracy" and that he is unable to dispel inevitable speculation that "the real motivation [*364] behind the Commission's sudden interest in campus radio is related to a desire to control a medium which is run by a generation of students who have become politically vocal..." Initially, it should be noted, that according to the most reliable information at my disposal, the inquiry is the unanimously recommended product of the various Commission divisions charged with the responsibility of overseeing broadcast operations of this kind. I suggest that it is unfortunate to characterize the genesis of this proceeding as "mysterious", when it appears that Commissioner Johnson can offer no factual support for such a characterization. Secondly, one wonders whether "inevitable". Speculation as to Commission motive will result from the Commissioner's dissent rather than from the straight forward presentation contained in the inquiry.
Finally, and most important, the dissenting statement is replete with words and phrases chosen to attract and excite a selected constituency in this country. By innuendo and by the Socratic technique of leading questions, Commissioner Johnson engages in the precarious task of ascertaining the intent and motives of his colleagues. The clear implication of his words is that the majority is engaging in a politically inspired conspiracy to suppress the radio voice of college students. Commissioner Johnson seeks not to disagree with his colleagues but to dishonor them before his constituency. In this endeavor he has abandoned his judicial role to become the advocate.
We as Commissioners are charged with the overwhelming, yet challenging, task of regulating the nations wire and radio communications. It is my view, that the keystone of our effectiveness as a regulatory agency and the cornerstone of our "believability" as an independent arbiter of public and private interests, is the equality of treatment we accord to the various entities subject to our jurisdiction. Would not a dissent from Commissioner Johnson have been appropriate when the Commission embarked on its far more exhaustive and financially burdensome inquiry of "conglomerate" ownership of broadcast stations? (Docket No. 18449) Our motivation there is precisely the same as our present concern. We seek no more than information; without such data we cannot hope for enlightened regulation.
DISSENTING OPINION OF COMMISSIONER NICHOLAS JOHNSON
In today's Notice of Inquiry and Proposed Rule Making, the Federal Communications Commission takes the first step towards regulating carrier current radio stations, the vast majority of which are operated on college campuses, by students, for the college community. These systems, which put a "radio" signal through the electric power line, are now not regulated by the FCC because they are (generally) extremely low power, and designed for a limited "audience" (often no more than a single student dormitory).
A few campus carrier stations have been so successful in their programming, however, that they are attracting audience and advertising dollars -- and the ire of some embarrassed commercial broadcasters with powerful transmitters. (One of the major reasons we encouraged the unregulated operation of campus carrier stations in the first [*365] place was their function as a training opportunity. Apparently it's working.)
I also recognize, of course, that a few campus stations have requested permission to go off campus via cable, have increased power, or are interconnecting. Conditions have changed in some isolated cases. I would have no objection to a Commission examination of such instances -- although I think we have more important things to do.
But neither broadcaster revenue nor a handful of cases provide any excuse whatsoever for the launching of this general investigation of student-operated campus carrier radio systems.
So what's up? The proposal to begin an inquiry into carrier current campus radio emerged somewhat mysteriously from the bureaucracy. My inquiries could not uncover precisely why, or when this project began, or who initiated it, Given the fact that this Commission is overburdened with, and understaffed for, numerous momentous issues literally affecting the way of life of every citizen -- cable television, domestic satellites, AT&T's rate increase, and so forth -- the decision to single out these insignificant student-operated stations for thorough overall federal scrutiny would be highly questionable even as an allocation of limited staff resources. Moreover, it will be noted that, not-withstanding their 30 years of operation, not a single complaint is cited by the majority, for the simple reason that virtually no complaints have ever been filed with the FCC regarding campus carrier current radio systems.
Inevitably there will be those -- especially students -- who will wonder whether the real motivation behind the Commission's sudden interest in campus radio is related to a desire to control a medium which is run by a generation of students who have become politically vocal, often in opposition to Establishment wars and other values. I would like to be able to put such speculation to rest; unfortunately, however, I cannot.
In our original consideration of this issue, an article from the May 18, 1970 issue of Newsweek was brought to the Commissioners' attention as an appendix to the staff memorandum -- along with some other similar news stories. The article reported the activities of campus radio stations during the nation-wide demonstrations against the invasion of Cambodia by U.S. forces. The Newsweek article begins:
Should revolution over come to New York University, the NYU campus probably won't look much different than it did late last week... [The] voice of their [the students] discontent was going out to the nation. Moratorium Radio Network (MRN) -- which defiantly proclaimed itself "radio for college students and by college students" -- was on the air.
"The idea just grew like the student strikes," said Howard Doyle, 19, the news director for WNYU. "We felt that the professional media weren't getting the facts to the people."... WNYU served as strike headquarters...
The FCC staff now claims that this article was brought to the Commission's attention -- not as evidence of the need for and rationale behind action -- but for the sole purpose of illustrating the fact that the Commission could not have acted at the time of these articles, but had to wait until later, because it might otherwise have been charged [*366] with being ideologically motivated. I frankly find this explanation somewhat flimsy.
Another article which the staff brought to the Commission's attention is the "Intelligence Report" from Parade Magazine, of May 31, 1970, which states, in part:
The "underground" newspapers appearing on campuses and in cities throughout the nation may soon be joined by a new and powerful medium: Carrier Current Radio [which is] moving off the campuses and into communities, primarily minority and low-income areas... [The] possibility of misuse for propaganda purposes will have to be faced by the FCC. (Emphasis added.)
I find the packaging of this information with the staff recommendation a little unsettling, at best.
For this nation's seven million college students, it will be difficult indeed to believe that this decision, and the now-notorious FCC action outlawing rock music "tending to... glorify the use of... marijuana" and other drugs, released less than three weeks ago, are not aimed at their ideas, ideals, and life-style. n1
n1 See Licensee Responsibility to Review Records Before Their Broadcast, Public Notice, F.C.C. 2d , FCC 71-205 (March 5, 1971)
I am particularly disturbed by the fact that the questionnaire being sent to campus carrier stations is not in any way limited to interconnection, or increases in coverage, which the staff claims is the real concern here. Thus, why should campus stations throughout the country, which have no intention of interconnecting, have to answer a questionnaire which asks them to indicate (1) the type of program carried, (2) the number of hours devoted to each type of program listed, (3) a list of a representative sample of editorial topics, * (4) the source of program and type of program originated at other colleges, with a list of the names of the colleges (as well as other sources of outside origination), (5) whether they carry any political programs, and (6) how their revenues are distributed. I see no relationship between this information and the interconnection issue if a station does not intend to interconnect. Even if a station did intend to interconnect, I cannot conceive of any justification for requiring a representative list of editorial topics. Given recent cases of overzealous federal agencies gathering in formation on civilian activities, I am most unhappy about the breadth of this Inquiry. n2
* Since the preparation and distribution of this opinion the General Counsel's office has informed me that an "editorial change" has now been made in the questionnaire, deleting (or in some other way altering) the reference to editorials on campus carrier current stations. Needless to say, I do not find this change to affect in any significant way the thrust of my concern.
n2 See, e.g., J. Herbers, "Senator Ervin Thinks the Constitution Should Be Taken Like Mountain Whiskey -- Undiluted and Untaxed," New York Times Magazine, Nov. 15, 1970, reprinted 116 Cong. Rec. S20067, Dec. 14, 1970 (daily ed.); R. Halloran, "Richardson Says: Data Banks Must Be Controlled," The New York Times, March 16, 1971, reprinted 117 Cong. Rec. H1591, March 16, 1971 (daily ed.); "No Place for the Military," (editorial) Kansas City Star, March 5, 1971, reprinted 117 Cong. Rec. H1674, March 17, 1971 (daily ed.).
The article on Senator Ervin reports: "At present he is attacking, through the Constitutional Richts subcommittee he leads, a massive surveillance system being put together by the Government, including computerized files on citizens who have engaged in 'political dissent' or 'civil disorders.'" Herbers, loc. cit. supra.
Recently some of my colleagues have bemoaned what they view as "regulatory overkill" in actions by this Commission. See Chairman Burch's statement in the Final Decision in the Computer Inquiry, F.C.C. 2d , FCC 71-255 (1971). It is mystifying that my colleagues [*367] always seem to find "regulatory overkill" when the Commission is dealing with large regulated utilities or inquiring into conglomerate ownership patterns -- taking actions that have been recommended both by its staff and the Department of Justice -- while finding it perfectly appropriate in the Commission's order of priorities to regulate rock music and student-operated college carrier current radio stations.
FEDERAL COMMUNICATIONS COMMISSION WASHINGTON, D.C. 20554
To: Carrier-Current System
The Commission has adopted a Notice of Inquiry and Proposed Rule Making in an effort to ascertain current information with respect to low power radiation devices and carrier-current systems which operate pursuant to Part 15 of the Commission's Rules.
In this connection there is herewith attached a questionnaire relating to carrier-current system operation and it is requested that the operator of your system answer the question set forth to the fullest extent possible and return the questionnaire, by May 4, 1971, to the Federal Communications Commission, Washington, D.C. 20554. If additional space is required for the answer to any question, the information should be included on a separate sheet of paper.
Thank you for your cooperation.
FEDERAL COMMUNICATIONS COMMISSION, BEN F. WAPLE, Secretary.
CARRIER-CURRENT RADIO SURVEY
A. General Information
1. "Call letters" system presently employs
2. Name of institution (e.g., university, college, etc.)
3. Address of institution
4. Address of system if different than above
5. Name of system manager, faculty advisor or other person responsible for supervision
6. Number of students on campus
7. Number of buildings on campus on which signal is received
8. Areas other than immediate campus served by carrier current lines
(a) Number and location of auxiliary transmitters on and off campus
(b) Estimated number of persons receivings signal off-campus
9. Number of students on staff
B. Technical Information
1. How is signal distributed
2. Mean operating power output of each transmitter in system
3. Radiated field strength in uV/m at feet (specify location at which measurement was made)
4. How were above measurement made
6. Is your signal carried by other media such as other carrier-current system, CATV system, etc. If so, identify (stations) and (systems) and number of subscribers if carried by CATV
7. How many other radio station signals (AM or FM) can be routinely received on campus
(The answers to the following questions should reflect the programming practices of the past year except where otherwise indicated. Where precise answers are unknown, approximate figures should be given).
1. Daily hours of operation am. pm. to am. pm.
2. Summertime operation if different than above. am. pm. to am. pm.
3. Check the program types carried by your system during a typical week and list aggregate weekly time (in hours) devoted to each.
News (exclusive of campus events)
4. Do any of your programs originate at sources other than your studios. Yes No
If so, indicate source and type of program.
Source of program Type of program
a. Commercial Radio Stations (list call letters).
b. Network (list network).
c. Transcribed Programs (list sources).
d. Other college radio operations.
5. Does your system carry any political programs or devote time to political candidates for public office. (Does not include campus elections) Yes No
6. If answer to question 5 is Yes, is equal opportunity afforded to opposing candidates. Yes No
7. Does your system carry editorials or programs relating to controversial issues of public importance (as contemplated by Section 73.123 of the Commission's Rules). Yes No
8. If answer to question 7 is Yes, is opportunity afforded to persons having opposing views. Yes No
9. Does your system maintain program logs or other record of programs carried. Yes No
10. Does your system sell commercial time. Yes No **
** Responses relating to financial matters will be used solely for analytical and related purposes and will not be available for public inspection. (See Paragraph 8 of Notice of Inquiry).
11. Is time sold by: 1. Your staff ; Sales Representatives ; Others .
12. What percent of advertising revenues are derived from local ; regional ; and national sources.
13. Total revenues from sale of commercial time ; total revenues from other sources (list) .
14. Does your system require that commercial messages contain sponsorship identification. Yes No
15. Net income after operating expenses .
16. How are revenues distributed .
17. If your system has a schedule of commercial rates, attach to back of this page.
Name of person completing form
Title (if any)