From Matthew Lasar in Lasar's Letter on the FCC:

Presidential hopeful and U.S. Senator Barack Obama has asked the Federal Communications Commission Chair Kevin Martin to rethink its proposed timeline for revising the agency's media ownership rules. "According to press accounts, you intend to present specific changes to existing rules in November with a Commission vote on that proposal —whatever it may be—on December 18, 2007," Obama wrote to the Commission today. "I believe both the proposed timeline and process are irresponsible."

Last week The New York Times and Associated Press both ran stories suggesting that Martin wants to fast track a vote on the FCC's media ownership rules. Up for grabs are caps limiting how many newspapers, TV stations, and radio stations a single entity can own. Martin has long favored relaxing restrictions that would prevent an entity from owning a newspaper and a TV station in the same city.

The AP article reported that Martin plans to propose new media ownership rules soon, likely at a hearing on October 31. The public would be allowed to comment through mid-November and some of December. The Commission would vote on the proposal at a meeting on December 18. The Commission would also hold its last hearing on its media ownership provisions in Seattle on November 2nd, according to the story.

Obama's letter to the FCC said that he found it "disturbing" that the FCC is considering these changes. "It is unclear what your intent is on the rest of the media ownership regulations," he wrote. "Repealing the cross ownership rules and retaining the rest of our existing regulations is not a proposal that has been put out for public comment; the proper process for vetting it is not in closed door meetings with lobbyists or in selective leaks to the New York Times."

The statement calls for the FCC to create an independent panel to explore ways to further media ownership diversity, something that FCC Commissioner Jonathan Adelstein, a Democrat, has proposed. "In closing, I ask you to reconsider your proposed timeline, put out any specific change to the rules for public comment and review, move to establish an independent panel on minority and small business media ownership, and complete a proceeding on the responsibilities that broadcasters have to the communities in which they operate," the letter concludes.

The 10th La Superette is this December, and an open call is now going out for participation. For the 10th Anniversary of La Superette, it is expanding into a full arts festival to take place over the first three weeks of December organized by Ignivomous Inc., and hosted by chashama. For a look at our guidelines and to sign up go to: http://www.lasuperette.org/call.php. The deadline for online submission is November 18, 2007. More information through lasuperette@gmail.com.

Stars Like Fleas' new record, "The Ken Burns Effect," is out now on the French label Talitres. It would probably be highly recommended no matter where the New York-based band recorded, but part of it comes from a Stars Like Fleas performance in 2006 at Wave Farm. SLF played two sets at Campfire Sounds, one on the stage near the ponds, and one around the large tree in the forest. The opening track, "Hoax's Head," contains a snippet from the beginning of the Wave Farm show, and the fifth track, "Early Riser," is a full song recorded at the forest stage. free103point9's Brooklyn program director Tianna Kennedy also plays cello throughout the CD.

From Radio World:

The battle over low-power FM and possible resulting interference has been off the front page for a while, but it’s simmering on Capitol Hill.

Speaking before the House Committee on Small Business last week, FCC Chairman Kevin Martin said the agency is considering an order that would guarantee low-power FM stations will “have reasonable access to limited radio spectrum.”

He said this in the context of describing how the commission is providing opportunity for small businesses in radio with the advent of the LPFM service.

We recently reported that attorneys in a legal session during the NAB Radio Show said the FCC is holding up some major modification applications for full-service FMs if the changes would result in taking lower-power stations off the air — a big change in policy, considering LPFMs are licensed as secondary services.

free103point9 Online Radio is seeking field recordings and acoustic ecology tracks for airplay. free103point9 Online Radio airs a "Field Recordings" show every Sunday at 10 a.m. ET, and also incorporates submitted performances throughout regular programming. CDs, LPs, and other formats sent for airplay will be stored in the Wave farm Study Center Library and available to the public. In addition, free103point9 is planning a series of field recordings performances in the summer of 2008 and looking for possible performers and presenters.

Please send recordings for airplay consideration to:
free103point9 Wave Farm
5662 Route 23
Acra, NY 12405

In collaboration with T.O.W.A.R. [http://thereoncewasarebellion.org], Gallery5 will host Repressed 3, a show dedicated to socially conscious works. This event will take place March 7, 2008 and will be the precursor to a workshop series. Gallery5, located in Richmond, Virginia, is currently seeking workshop proposals, performers, artists, and volunteers. For more information and proper forms go to:
http://www.gallery5arts.org/repressed3packet.pdf

Radio Astronomy is an art and science project which broadcasts sounds intercepted from space live on the internet and on the airwaves. The project is a collaboration between r a d i o q u a l i a, and radio telescopes located throughout the world. Together we are creating 'radio astronomy' in the literal sense - a radio station devoted to broadcasting audio from our cosmos. (Image at right: Very Large Array [VLA], NRAO, New Mexico, USA.)

Listeners will hear the acoustic output of radio telescopes live. The content of the live transmission will depend on the objects being observed by partner telescopes. On any given occasion listeners may hear the planet Jupiter and its interaction with its moons, radiation from the Sun, activity from far-off pulsars or other astronomical phenomena.

Radio Astronomy correlates the processes associated with broadcast radio - the transmission of audible information, and the processes of radio astronomy - the observation and analysis of radiated signals from planets, stars and other astrophysical objects. The work synthesizes these two areas. The signals from planets and stars are converted into audio and then broadcast on-line and on-air. The project is a literal interpretation of the term, ³radio astronomy². It is a radio station broadcasting audio from space.

free103point9's Tom Roe appeared on Norman Keyser's "In Progress/Left of the Dial" show on WRPI (91.5-FM) in Troy, New York two recent Mondays from 10 a.m., playing a variety of transmission art, Wave Farm performances, and other recordings. Here are the playlists:

Oct. 1, 2007
Transmaniacon MC, "Radio4" from Radio Action I
Tom Roe, "Tropospheric Wave" from forthcoming The Worst Hour of the Year
Dymaxion, "The Haunted Radio" from Radio Action I
Radio Ruido, "False Rosetta" 7"
Melissa Dubbin + Aaron S. Davidson, "Every Spy Has Their Numbers" from Radio Action I
The Dust Dive, "Postcards of Real Worlds" from forthcoming Claws of Light
Tom Roe, "Superfund Stories" for The FM Ferry Experiment
Michelle Nagai, "Soundwalking at Night through milkweed Au Grand Bois, Quebec, Summer 2002" from Tune(In)))
Neptune, "Marconi's Belief" from Radio Action I
Gregory Whitehead, "Song for a Headless Apache" from Songs for coverage of RNC 2004 protests
United States of Belt, "Ping Pong Holiday" from Ping Pong Holiday

Oct. 15, 2007
Melissa Dubbin, "Music from the First Karate Lesson" from Dado Blade
Matt Mikas, "Silent Weapon Technology" from Interactive Audio Response Kit
Matt Mikas + Brad Truax + Tony Flynn + Jeremy Glover, "Orifice of Strategic Information" from Radio Action I
Latitude/Longitude, "Solar Filters" 7"
The Dust Dive, "Cut the Day with a Steak Knife" from Claws of Light
The Dust Dive Flash, "Can't Stop This Feeling" from Tens of Thousands
Matt Bua + Matt Mikas + Tom Roe, "Dub The Bridge"
Stars Like Fleas, "Hoax Head" from The Ken Burns Effect
Stars Like Fleas, "Karma's Hoax" from The Ken Burns Effect
Sabers, "Bene Gesserit" from Radio Action II
Stars Like Fleas, "Early Riser" from The Ken Burns Effect
Tom Roe + Kelly Benjamin, "New York Rebuilds" from Constructive Engagement
Sybarite, "Secropia" from Tune(In)))
Radio 4x4: Gabriel Burh-Murian + David Matorin + David Galbreath + Andrew Neumann
Michelle Nagai, "Drone in key of d 60 bmp" for Scape 2
Scanner, "ElectroPollution" from Tune(In))) The Kitchen

From Regine in We Make Money Not Art:

Messy notes from the fascinating talk that Tatiana Bazichelli gave at City of Women, a festival running until October 13 in Ljubljana, Slovenia. Her talk was an overview of Extra Gender, the last chapter of Tatiana's book "Networking. The Net As Artwork," which gives a snapshot of the history of artistic networking in Italy, through an analysis of the realities which during the past twenty years have given way to a creative, shared and aware use of technologies, from video to computers, contributing to the formation of Italian hacker communities....She started her overview of hacktivism in the 70s with the birth of Radio Alice (studio pictured), an experience in free independent radio in Bologna. Radio Alice was also an art experiment where languages was played with and explored in a dada-ist way.

From Tony Canonico in Neural:

Jeff Feddersen, author of EarthSpeaker, is an artist with a well rounded background, mainly specialised on the dynamics (nowadays pretty blended) between music and informatics. His favourite subjects of research are nature and the technologies developed around energetic sustainability. EarthSpeaker is a set of outdoor installations (sculptures) which interact with and within the environment by grabbing solar energy during daytime and releasing sound emissions from sunset on. Feddersen's project is at free103point9's Wave Farm in Acra (New York), and the first prototype of EarthSpeaker was built in 2006 at Eyebeam Center labs. Thanks to his 'nocturnal audio sculptures,' he seems to put up a sort of robotic representation of life-environment interaction and its seemingly simple cybernetic cycle. Just like the vegetal system, EarthSpeaker absorbs solar power thanks to the built-in solar panels and releases amplified VLF (very low frequency) sounds coming from outer space lightening and human generated waves (i.e.: geophones) by its own integrated speakers. A complete input/output cycle exploits the invisible and infinitesimal capabilities of our environment, redefining at the same time its semiotic borders through new representations of life.

Call for papers: Why Live? Performance in the Age of Digital Reproduction. Downloads and file exchanges have altered the economics of music of consumption, but have they also rendered the concert hall obsolete? Or have the isolation of ear buds and the ephemerality of digital files actually served to highlight the social significance and sweaty substantiality of live performance? Or are we witnessing the birth of a new “live” virtually social but vitally sweat-free? For LMJ 18 we solicit writing on the significance or irrelevance of contemporary performance practice and its alternatives.
Deadline: 15 October 2007. Rough proposals and queries to Nicolas Collins, Editor-in-Chief, at ncollins[at]artic.edu. More info: http://leonardo.info/.

From Matthew Lasar in Lasar's Letter on the FCC:

Everybody had something to tell the Federal Communications Commission about so-called "white space" or "unlicensed" devices last week, including Cox Communications and the "Open Mobile Video Coalition."

The chatter culminated in Friday's decision by the FCC to initiate a new round of tests of the machines: cognitive receivers that can tap into unused television frequencies, or "white space," and use them for broadband purposes: video, streaming audio, extended LANs or "community mesh networks."

"The Commission is committed to working with all parties to continue the process of investigating the potential performance capabilities of TV white space devices in an open and transparent manner," the agency announced on October 5. "To that end, the Laboratory will be conducting additional laboratory and field testing of prototype devices."

The prototypes come from Microsoft and Phillips, big boosters of the technology and leaders of the "White Space Coalition," which also includes Google, Hewlett-Packard, and Intel.

Their FCC filings promise that "unlicensed devices operating in the TV band will offer longer transmission ranges using the same power, less risk of signal attenuation or harmful interference, and less power consumption at the same range than Wi-Fi."

TV broadcasters, on the other hand, have roundly denounced the technology, likening it to a potential epidemic spread by signal interference laden "germs . . . with the ability to attack the TV receivers in people's homes, apartments, hotel rooms, hospital rooms, dormitories, etc."

On September 21 Microsoft and Phillips submitted the results of their latest unlicensed device tests to the FCC. Their tests confirm that it is feasible for white space devices to pick up TV signals at a signal strength "that is far too weak for a television set to produce a broadcast television picture," their filing concluded.

But the broadcasters aren't letting up on this issue. The Open Mobile Video Coalition's October 2nd comment urges the FCC to test unlicensed devices for interference with mobile receivers [eg, cell phones], and "not to permit unlicensed devices to operate in the DTV spectrum unless there is fully effective protection against interference to the mobile broadcast service from mobile devices."

The filing is signed by reps from Tribune, Cox Television, Telemundo, Media General, Gannett, and Fox, among other broadcasters.

Independent of this group, Cox submitted several statements to the FCC on the same day, arguing that the "state of these cognitive radio technologies - as demonstrated by the [FCC's] laboratory tests - is too immature to ensure protection of broadcast and cable services."

AV Festival 08 is providing creative practitioners with an opportunity to contribute ideas to the programme. In the next two months, we will announce a series of opportunities for artists, musicians, filmmakers, DJs, VJs, designers, theorists, technologists, scientists, philosophers and others to contribute to the festival.

The first of these are now online, and include the call for artists’ proposals for AV Festival 08 at Sunderland Museum & Winter Gardens, a project Manager for Middlesbrough and also for young people to get involved with AV Festival 08 through the evolve volunteer and envoy scheme.

In the coming weeks, we will also call for proposals from artists and producers who want to get involved with our radio stations, filmmakers who want to create a new work for the festival, and critics and philosophers who want to contribute to our conferences.

Waygood Amateur Radio Club two-way radio communication

Artists, writers, performers, sound artists and musicians who are interested in working towards an amateur radio license and producing work for a new arts amateur radio club as part of AV Festival 08 are invited to contact Waygood Gallery & Studios for further information. Please send your contact details to helen@waygood.org by 31st October 2007.

Call for Artists’ Proposal for AV Festival 08 at Sunderland Museum & Winter Gardens

AV Festival 08 and Sunderland Museum & Winter Gardens seek to commission a new site-specific audio artwork for the Sunderland Winter Gardens as part of AV Festival 08. Deadlines not specified on web site; festival is in March, 2008.

From Cory Doctorow in boingboing:

The FCC's war on dirty words is having a chilling effect -- even WBAI Pacifica, the radical radio station in NYC, is scared of airing Allen Ginsberg's magnificent poem, Howl.

"Why, 50 years later after a judge ruled that children could read this poem, people are afraid the courts will say that their ears shouldn't hear it," said Ron Collins, a constitutional law instructor and First Amendment advocate who is leading a small group of authors, broadcasters and free-speech advocates pushing to broadcast the poem eventually. "Yet they can go on the Internet and see far, far worse things."

Another irony: WBAI, the Pacifica Foundation station in New York that plans to post "Howl" online, is the same station that took on the FCC more than 30 years ago over the right to air George Carlin's comedy routine featuring the "seven dirty words." The challenge led to a 1978 Supreme Court decision governing what naughty words can be broadcast and when.

Pacifica's attorney for FCC issues, John Crigler, thinks airing "Howl" would be "a great test case" in the current environment. But he understands why WBAI won't broadcast "Howl," even between the hours of 10 p.m. and 6 a.m., the hours the FCC has cordoned off for rougher language.

WBAI program director Bernard White fears that the FCC will fine the station $325,000 for every one of Ginsberg's dirty-word bombs. If each Pacifica station that aired the poem - and possibly repeated it - were to be fined for airing "Howl," it could mean millions of dollars in fines.

Daniel Carter, Matt Mikas, Tony Flynn and Tom Roe at free103point9 Project Space, Brooklyn, 03.12.05:
[youtube=http://www.youtube.com/watch?v=_J0TQB07-fA]

The new free103point9 web site is up now. We're sure there are still some kinks to be worked out, but there's also many new features that are working fine. Lots of new audio and video files of past events, made possible, in part, through a Digitization grant administered by the New York State Council on the Arts, a state agency. You can also add your event to the calendar, to get listed among many other great radio art and experimental events from around the world. Please let us know if anything doesn't work in the comments.

free103point9 Online Radio
October 2007 Top 40

1. Mammal, Lonesome Drifter (Animal Disguise)
2. Bruce Eisenbeil Sextet, Inner Constellation (Nemu)
Bruce Eisenbeil + Jean Cook + Nate Wooley + Aaron Ali Shaikh + Tom Abbs + Nasheet Waits.
3. Temperatures, Ymir (Heat Retention) LP
4. Phantom Limb & Bison, Phantom Limb & Bison (Evolving Ear)
5. Timeless Pulse Quintet, Timeless Pulse Quintet (Mutable)
6. Shelf Life, Ductworks (Public Eyesore)
7. David S. Ware Quartet, Renunciation (Aum Fidelity)
8. The Kevin Frenette 4, Connections (Fuller Street Music)
Kevin Frenette + Andy McWain + Todd Keating + Tatsuya Nakatani.
9. Alabrecht Maurer Trio Works, movietalks (JazzHausMusik)
10. Beardtongue, untitled (self)
11. Chris Forsyth + Nate Wooley, The Duchess of Oysterville (Creative Sources Recordings)
12. William Parker + Hamid Drake, Summer Snow (Aum Fidelity)
13. Tripwire, Looking in My Ear (Creative Sources)
14. Willing, Brotherhood of the Backwards Handshake (Evolving Ear)
15. Phil Minton + Yagihashi Tsukasa + Sato Yukie + Higo Hiroshi, Nippara * Tokyo (Austin Record)
16. Vampire Hands, Virgin Dust American Life (Freedom From)
17. Cadaver In Drag, Raw Child (Animal Disguise)
18. Giraffe, Hear Here (self)
19. William Parker + Hamid Drake, First Communion/Piercing the Veil 2xCD (Aum Fidelity)
20. Ting Ting Jahe, 18(16) (Winds Measure Recordings)
21. Jeff Arnal + Dietcich Eichmann, LP (Broken Research)
22. Thick Wisps, Thick Wisps (self)
23. If Bwana, Radio Slaves (Monochrome Vision)
24. Felix Werder, Electronic Music (Pogus)
25. David Watson, Fingering an Idea (XI Records)
26. MV & EE with the Bummer Road, Green Blues (Ecstatic Peace)
27. Duane Pitre/Pilotram Ensemble, Organized Pitches Ocurring in Time (Important)
28. Destructo Swarmbots, Clear Light (Public Guilt)
29. Robert Ashley, Now Eleanor's Idea (Lovely Music)
30. Ironing, Pocket Almanac (Hymn)
31. Meri von KleimSmid, Have a Spinach Salad (Latibulum)
32. Annea Lockwood, Thousand Year Dreaming/Floating World (Pogus)
33. Harm Stryker, Harm Stryker 3" CDr (Public Guilt)
34. The Peeesseye, Mayhem in the Mansion (Evolving Ear)
35. Various artists, ...a tidal wave of air & a subtle shift in landmarks (Passive Consumer)
36. Joseph Nechvatal, Viral Symph0ny (iea)
With Matthew Underwood, Andrew Deutsch, and Stephane Sikora.
37. Jonas Braasch, Global Reflections (Deep Listening)
38. Seejayno, Sedainty (Shinkoyo/Here See/Skulls of Heaven/BOC Sound Laboratories)
39. Albrecht Maurer + Norbert Rodenkirchen, Hidden Fresco (Nemu)
40. Eliane Radigue, Jetsun Mila (Lovely Music)

To submit CDs, LPs, CSs, etc. for consideration of airplay on free103point9 Online Radio, mail to:
free103point9
5622 Route 23
Acra, NY 12405

From William Hanley in Rhizome:

Former Whitney Museum of American Art Curator and current dean of the California College of the Arts, Lawrence Rinder has organized a small, three-artist show of television-influenced video work at San Francisco’s Silverman Gallery. Taking the narrative conceits of the medium as a common thread, TV Honey connects work from two generations of artists by playing up their similar engagements with the desiring mechanics of viewing. A wonderfully bizarre and infrequently screened 1974 work by Lynda Benglis, ‘The Amazing Bow Wow,’ tells the story of a human-size hermaphroditic dog, who becomes the main attraction in both a traveling freak show and ultimately a violent Oedipal romance. The “can’t look away” factor in her work is complemented by Joan Jonas’s ‘Vertical Roll.’ Made in 1972, the artist plays two self-consciously alluring characters in a video that persistently short-circuits the viewer’s engagement with the TV drama as the video frame continually “rolls” vertically off the screen in visual hiccups that recall an ancient television set with the v-hold knob turned slightly. Representing the contemporary progeny of these foundational television-focused video works, the show also features Oakland artist Desiree Holman’s 2006-07 video ‘The Magic Window.’ The three-channel projection–exhibited here with a group of related drawings–emulates the sitcom trope of a family watching television together, but like Jonas’ work in which the artifice disrupts the viewer’s typical relationship to the narrative, the familiarity of the scene is interrupted by strange masks worn by the characters. Opening October 11th, the most striking similarity to emerge between the decade-crossing works, however, may be the shared sense of D.I.Y. chaos that runs through each of them–all three contain dance sequences that could prove to be particularly hilarious viewed side by side.

From Marcus Estes via WFMU Beware of the Blog:

A community of computer geeks representing the forces of good (you know the type: politically liberal, swift to anger over unjust copyright laws, likely bearded, into Linux, bikes, beer) are working on a new project that could change the way that we use of one of the fundamental forces of nature: radio waves! Open source radio? What a great idea, right? But what is it?

Well, that's a long, slightly complicated story. The leading software project in the open source radio world is called GNU Radio. GNU refers to a software movement started in the '70s by a proto-hippie-geek by the name of Richard Stallman. Stallman was the first software developer to publicly espouse the "free love" approach to software copyrights that lead to such modern marvels as Linux. (The computer hosting this webpage runs Linux, and Linux will be bringing you almost every other webpage you visit today. Thanks, free software!)

GNU Radio operates under a similar philosophy as Linux -- let's all build it together and give it away to anyone who wants to use it. If you want to add to it, cool, but here's the trick: you have to give it away free as well. This has proved incredibly disruptive to a lot of powerful, evil corporations who would like to make sure that everyone has to pay for the ability to use a computer. First the free software movement brought us a computer operating system. As its next trick it built much of the infrastructure that powers today's internet.

Now they're working on radio. And we're not just talking AM/FM. These little open source radios can work with all radio, including TV, cell phone transmissions, and even microwaves. I guess. That's the thing, it's all a little mysterious at this point, to the uninitiated.

In a article for Wired magazine on this project, one of the inventors began by showing off what one these little puppies can do.

"Here," he explains, "I'm grabbing FM."

"All of it?" I ask.

"All of it," he says.

So there's one answer: Coupled with a proper radio antenna and receiver, you could listen to every radio station on the planet. At the same time. Why, you ask? Let's not worry about whys just yet. These fellas are working on more of a, "if it's possible, let's do it," sort of philosophy.

The original inspiration for the project was political. Congress has for years threatened to pass a law called the broadcast flag that would prevent anyone from making hardware that could record digital television shows. Because these software-powered radios can also work as TV tuners, software developers are working to make sure than giant electronics corporations are not the only ones in control of the technology. Beyond TV and radio, people have been using this work to do all sorts of wacky things, like hacking together super-local GPS systems and more.

If the notion of "turning the digital modulation schemes used in high performance wireless devices into software problems" seems confusing to you, there's probably not much fun to be had with an open source radio device just yet. You'll have to wait until somebody creates something more easy to use. (Or if you're into radio tech, C++ and / or Python coding, visit Ettus, a vendor that sells "Universal Software Radio Peripherals.") But with technology that's playfully rewriting the rules for such a fundamental natural phenomenon as radio waves, it's bound to give birth to some really interesting toys sooner or later. As one of the inventors said, "We're bringing the free-software ethic to radio, who knows what's going to come out of it?"

From Broadcast Law Blog:

During a panel at the NAB Radio Show, FCC Audio Services Division Chief Peter Doyle was asked a question about the processing of FM applications filed under the new simplified process for upgrades in their technical facilities and for changes in their cities of license (see our post here for details about that process). The question dealt with rumors that the processing of certain FM applications were being delayed if the proposed upgrade would cause interference problems to any LPFM stations which would threaten their existence. We have written about our concerns that such a policy was possible, here. According to the response yesterday, these delays are indeed taking place - meaning that LPFM stations that are supposed to be secondary services which yield to new or improved full-service stations are now blocking improvements in the facilities of these full-power stations.

Doyle explained that, at the moment, there is no policy of denying the full-service station's application - but these applications are being put on hold if they would impede an LPFM's ability to continue to operate in order to study options as to how the LPFM service might be preserved through a technical change or through agreements to accept interference. While no final determination has been reached as to what will happen to the applications if there is no available resolution to the LPFM interference issue, he pointed to the pending rulemaking (pending for almost two years) that would give LPFM's higher status, and in effect allow them to preclude new or improved full-service operations. There was some indication that these actions were being taken pursuant to the potential policies set out in that Notice of Proposed Rulemaking - even though these policies were simply proposals advanced for public comment and have not yet been adopted by the full Commission.

This seems to be a troubling case of the Commission adopting rules and policies before formal rulemaking proceedings are completed. In some cases, ad hoc policy changes may benefit broadcasters, but in cases like this, they may harm them and effectively impede the full implementation of a Commission decision that was long in the making. And this change is in a policy that was fundamental when the FCC first authorized LPFM - that low power FM stations that serve limited areas, and which have great potential for preclusive effects on large stations serving much larger populations, would be secondary to the greater service provided by the full-power stations. While the Commission can always change that policy, it would seem that they should do so in a reasoned rulemaking process, analyzing all of the pros and cons in the change in policy, through a resolution of a rulemaking proceeding like that which they started two years ago. Obviously, we have to see how the application process plays out (and it indeed may just be an attempt to help the LPFM stations in a benign fashion that will not affect the upgrades of the full service stations) but if these processing policies do indeed result in denial or permanent limbo for some full-service station applications, this certainly would look like the prejudgment of an important issue without an analysis of all of the legitimately-raised counterarguments that have been submitted to the Commission in its rulemaking proceeding.