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Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, DC

In the Matter of

MM Docket No. 97-234
Implementation of Section 309(j) of the Communications Act -- Competitive Bidding for Commercial Broadcast and Instructional Television Fixed Service Licenses

GC Docket No. 92-52
Reexamination of the Policy Statement on Comparative Broadcast Hearings

GEN Docket No. 90-264
Proposals to Reform the Commission’s Comparative Hearing Process to Expedite the Resolution of Cases

To: The Commission

TABLE OF CONTENTS

JOINT COMMENTS OF NPR, INC., NFCB AND THE CPB

INTRODUCTION AND SUMMARY

1. The Balanced Budget Act of 1997 Does Not Authorize The FCC To Use Auctions Where An Applicant Proposes A Noncommercial Educational Broadcast Service

2. Subjecting Public Broadcasters To Auctions Would Limit The Diversity Of Voices Represented On The Airwaves By Closing A Substantial Portion Of Spectrum To Public Broadcasters

1. Access By Public Broadcasters To Frequencies Outside of the Reserved FM Band Is Often Essential To Extend Or Maintain Service

2. Most Radio Frequencies Outside of The Reserved FM Band Will Be Closed To Public Broadcasters If They Must Compete In Auctions For The Frequencies

3. Without Access To Frequencies Located Outside of The Reserved Band, The Diversity Of Voices And Programming Available To The Public Will Be Diminished

3. Subjecting Public Broadcasters To Auctions – And Thereby Taking Back Government Funding Through Auction Payments – Contradicts Both Logic And A Long History Of Support For Public Broadcasting

4. Where a Public Broadcaster Is An Applicant For A Frequency Outside Of The Reserved Band, The Commission Should Use A Modified Selection Process That Preserves The Public Interest In Diversity

5. CONCLUSION ". . .NPR, NFCB and CPB respectfully urge the Commission to reject the use of auctions to resolve mutually-exclusive broadcast applications where one or more of the applicants is a public broadcaster and to implement an alternative selection process which furthers universal public radio service, promotes diversity and localism, and does not harm existing public radio stations.

JOINT COMMENTS OF NATIONAL PUBLIC RADIO, INC.,
NATIONAL FEDERATION OF COMMUNITY BROADCASTERS
AND THE CORPORATION FOR PUBLIC BROADCASTING

National Public Radio, Inc. ("NPR"), the National Federation of Community Broadcasters ("NFCB") and the Corporation for Public Broadcasting ("CPB") respectfully submit these Joint Comments in response to the Notice of Proposed Rulemaking, dated November 26, 1997, in the above-captioned proceedings (the "NPRM"). For the reasons set forth in these Joint Comments, NPR, NFCB and CPB urge the Commission to abandon its proposal to use a competitive bidding system for mutually-exclusive broadcast applications when one or more of the applicants is a public broadcaster. Instead of using auctions in these cases, the Commission should implement a selection process which furthers universal public radio service, promotes diversity and localism and does not harm existing public radio stations.

NPR is a non-profit membership organization of more than 590 noncommercial educational radio stations nationwide. NPR produces and distributes such noncommercial educational programming as All Things Considered, Morning Edition, Talk Of The Nation, and Performance Today. NPR also operates the Public Radio Satellite Interconnection System and provides representation and membership services to its member stations.

NFCB is a non-profit grassroots organization of noncommercial educational public radio stations characterized by community support, control and programming. NFCB’s 85 Participant Members and 95 Associate Members reflect the diversity of the United States: 40% of the members serve rural communities and 35% are minority radio services.

CPB is the private, nonprofit corporation authorized by the Public Broadcast Act of 1967 to facilitate and promote a national system of public telecommunications.

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