relevance of cities of license

[oldiesfunhouse]

I was originally going to post this in the Easy 99.1 thread but then I thought it might be enough of a discussion topic to warrant its own thread.  I mentioned that Easy was giving KJMY HD2's COL as Centerville, rather than Bountiful, and refered to it as a "little discrepancy".  CAwasinNJ said, "I have to disagree. Giving the COL as Centerville is not a little discrepancy. You could argue that adding something non-compliant like "-AM" or "in" would be de minimis since it does accurately convey the required information even though it doesn't technically meet the rules. Bountiful and Centerville are two completely different cities. Would you accept Salt Lake as the COL? Denver? Of course someone has to complain for anything to be done." To answer the question, would "I" accept Salt Lake or Denver as the city of license?  Probably not Denver.  That would be weird but Salt Lake … yes. When I lived in West Jordan and I met people from other parts of the country and they asked me where I lived I would tell them Salt Lake City or sometimes a suburb of Salt Lake City called West Jordan. Now 979 does ID themselves as "KBZN Ogden," but then their jingle singers come in and sing "Now 979, Salt Lake City." So they say what they have to to keep the FCC happy but they obviously want to identify with Salt Lake City rather than Ogden.  My point with all this is, in today's day and age, are cities of license even relevant?  Does KZNS FM have any connection with the community of Coalville other than the fact that's the city they're licensed to?  KEGA to Oakley, KYMV to Woodruff, etc? To KALL's credit, I have heard them give a community calendar for North Salt Lake, their city of license. But I would hazard a guess that they don't do that out of this major sense of tie in with the city of North Salt Lake.  I don't know. Maybe that isn't fair. I get that it's a pet peeve kind of like mine when I find out that hotels call their thirteenth floor the fourteenth floor.  It's one of those things that most people don't care about that drives me nuts.  And rules were put there for a reason.  I used to think that your city of license was supposed to be the place where a station's signal was the strongest.  But I doubt KUDD's signal is any stronger in American Fork than other places.  I think I could somewhat safely argue that if someone who was not a radio person like us found this discussion, they would agree with me that the reference to Centerville rather than Bountiful was a little discrepancy, unless the person was a lawyer. If I have come across as disrespectful at all, please forgive me. My point here was to give a different perspective and, hopefully, generate some discussion, which is the whole point of this group, anyway, right?

[CAwasinNJ]

This is a good topic. There are actually a couple of interrelated topics here. The first thing we need to start with is what the community (it's not city anymore) of license is actually for. To put it simply, in exchange for the right to use the public airwaves a station is required to serve the public interest, convenience and necessity. To promote fairness, the FCC assigns a specific community that the station is supposed to direct that effort toward. The specific requirements have changed from time to time but the general requirement remains and is taken seriously by the Commission, especially when a station requests to move closer to a large city at the expense of a smaller one. The Commission doesn't want smaller communities to be left with little or no local radio and to a great extent that would be what would happen. More listeners = more money = more profit. As a man wiser than me about the business of radio always says, Follow The Money. So yes, the COL is relevant insofar as to who the station is required by the Commission to serve.

But that brings us to the separate but related topic of whether a COL, or legal ID in general, needs to be audibly transmitted. Back in the 1930's when these regulations were being set up the answer was yes. Radio was coming out of a wild west period where pretty much anything went and it was a complete mess. You needed to be able to figure out who was who if there was a problem. Without an ID of some kind that was difficult. Even today anyone who DXes knows how hard that can be and we have the vast resources of the internet to help. For the most part though in today's world we have other options. Boosters and translators need to give legal ID's too, but almost always they do so inaudibly. I know, boosters and translators are much lower power than full service stations and are much less likely to cause a problem, but there is a solution. Broadcasters have been arguing for years to do away with the audible ID requirement and considering how hard it is to catch the ID at some stations there's evidence already that it's probably not needed anymore. I tend to agree that the industry should explore the idea of doing away with the current system. Considering how much Chairman Pai is willing to tie himself into a knot to help big business I wouldn't be surprised if that happens.