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Author Topic:   Future local LPFM radio being threatened by Calvary Chapel
RECNetworks
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posted 12-26-2002 06:24     Click Here to See the Profile for RECNetworks     Edit/Delete Message Reply w/Quote
.. This is what I posted to the tao radio list..

Calvary Chapel of Twin Falls, Inc., the licensee of KAWZ and KEFX FM in Twin Falls and over 300 satellite-fed translators across the country has proposed to the FCC to allow of satellite-fed translators to be able to use frequencies in the "non-reserved" (92-108 MHz) portion of the FM Band.

Current FM rules allow for satellite-fed translators in the reserved (88-92) band. The translators must be owned by the same entity as the primary station they are relaying.

When the FCC originally created this rule, it was intended to provide additional options into areas that are underserved and where feeding a translator using traditional means (receiving the signal of another FM station or translator) is not possible.

Calvary sites that reserved band spectrum is getting scarce in many areas. They also cite that current translator rules preclude FM translators in the reserved band in close proximity to TV Channel 6 stations.

In our comments, we stated that local stations, such as LPFM should have priority in the non-reserved band. We asked for the FCC to either deny the proposal or at the minimum: (1) define a distant translator as a translator with a primary station in a different state and at least 400km away, (2) allow distant translators but with a "sub-secondary" status meaning that they can be bumped-off if the channel is needed for a local LPFM station and no other channels are available to the LPFM applicant.

National Public Radio has already chimed in. They share our concerns about the proliferation of these nationwide satellite fed translator networks. They propose that satellite fed translators should only be available to primary stations that are close to the translator site. NPR provides different concepts for determining area where a local NCE station can apply for a satellite fed translator. These include: (1) a fixed distance that varies based on the class of the station (for example: a class C would be 200km), (2) using the station's 30dBu service contour (for example: a class C running full facilties: 193km) or (3) in the same state however stations near state boundaries can also apply in the adjacent state (NPR did not elaborate qualifications).

REC feels that if Calvary Chapel is able to get the rules amended as they proposed, it will result in every nook and cranny of what's left of the non-reserved band spectrum being eaten-up by satellators. The reserved band in many metro areas are already in a logjam because of these satellators. It's only going to get worse.

REC is asking everyone in the Radio Activism movement to file comments with the FCC on RM-10609. Read Calvary's proposal and read NPR's comments. We would appreciate if based on what you read if you would support one of the following three positions:
- Not allow satellite translators at all in the non-reserved band.
- Allow satellite translators but distant translators can be bumped if the channel is needed by LPFM.
- Support NPR's position that satellite-fed translators may only be operated by local primary stations. If you support this position, please help us by supporting that the definition of "local" is primary stations within the same state as well as stations that are out of state but within 400km of the translator. (If you think 400km is too far, propose a smaller number, please do not make it under 200).

A public notice was released (#2584) but was never posted on the FCC website. If you wish to file comments, I would hurry up and do it.

The FCC's Electronic Comment Filing System is at: http://www.fcc.gov/e-file/ecfs.html
(Proceeding: RM-10609)

Our LPFM website as it http://www.recnet.com/lpfm

Please help protect future LPFM operations from this band threat.

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Modern Populist
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posted 12-26-2002 06:47     Click Here to See the Profile for Modern Populist   Click Here to Email Modern Populist     Edit/Delete Message Reply w/Quote
I agree.

Calvary Chapel is a SERIOUS threat to LPFM stations -- and to OTHER small broadcasters.

Cavalry has claimed MUCH more than their Fair Share Of The Pie for FAR too long. It's time they learned that even THEY have limits.

Calvary's continuing greed for even MORE spectrum is incredible -- but true. Based on its past successes, Calvary's latest threat should be taken VERY seriously -- by ALL of us.

****

REC NETWORKS, you take the lead on this and I'll follow!!

And I bet I won't be the only one.

Write up some good draft Comments for this Docket ... I'll sign on ... I'll offer a Motion for THE AMHERST ALLIANCE to sign on ... and I'll bet others will be willing to do the same. Just let us all know when the draft Comments are ready for a "look-see"!! Then interested parties can sign on to your Comments -- and/or file their own Comments.

Yours,

Don Schellhardt

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Modern Populist
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posted 12-26-2002 07:06     Click Here to See the Profile for Modern Populist   Click Here to Email Modern Populist     Edit/Delete Message Reply w/Quote
PS. REC NETWORKS -- Do you know the filing deadline for this Docket?

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Modern Populist
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posted 12-26-2002 10:39     Click Here to See the Profile for Modern Populist   Click Here to Email Modern Populist     Edit/Delete Message Reply w/Quote
UPDATE:

I just re-read the initial posting by REC NETWORKS.

I read it too quickly the first time and thought that REC was discussing the content of PROPOSED Written Comments that it PLANS to file. In fact, however, REC NETWORKS has ALREADY FILED Written Comments in RM-10609.

These Written Comments, along with Written Comments by NPR and the Cavalry Chapel proposal itself, can be found in the RM-10609 Document File of the FCC's Electronic Comment Filing System (ECFS). The ECFS is located at the FCC's Web Site: www.fcc.gov

I will be proposing to THE AMHERST ALLIANCE that we should file brief Comments in Docket RM-10609, generally endorsing the points raised by REC NETWORKS. However, I will not propose that Amherst should join REC in endorsing microwave transmissions as an alternative to more satellators. I believe we already have more than enough of both.

Sincerely,

Don Schellhardt

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RECNetworks
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posted 12-26-2002 14:10     Click Here to See the Profile for RECNetworks     Edit/Delete Message Reply w/Quote
We have dropped the whole microwave thing from our reply comments.

We are more inclined to lean towards NPR's method of only allowing satellators X miles away from the primary station. This preserves local translator services. Remember, NCE translators already exist in the non-reserved band.

If Amherst wants to take a more harder line approach and say NO satellators, period. Then I will welcome that.

Draft REPLY COMMENTS are being worked on right now. I just want to see who else from the 'big broadcaster' camp decides to chime in on this.

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WKJCE RADIO
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posted 12-26-2002 20:32     Click Here to See the Profile for WKJCE RADIO   Click Here to Email WKJCE RADIO     Edit/Delete Message Reply w/Quote
quote:
Originally posted by RECNetworks:
We have dropped the whole microwave thing from our reply comments.

We are more inclined to lean towards NPR's method of only allowing satellators X miles away from the primary station. This preserves local translator services. Remember, NCE translators already exist in the non-reserved band.

If Amherst wants to take a more harder line approach and say NO satellators, period. Then I will welcome that.

Draft REPLY COMMENTS are being worked on right now. I just want to see who else from the 'big broadcaster' camp decides to chime in on this.


Hi REC we are intrested in those draft reply comments although we are not a big broadcaster but well known at the FCC lol
thnaks

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Modern Populist
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posted 12-27-2002 01:38     Click Here to See the Profile for Modern Populist   Click Here to Email Modern Populist     Edit/Delete Message Reply w/Quote
Dear REC NETWORKS, Christopher Maxwell and Other Members of THE AMHERST ALLIANCE:

Check your Mailbox. I have sent BRIEF draft REPLY COMMENTS to the Amherst Membership for approval!!

Yours,

Don Schellhardt

PS. Interested non-Am'sters can always contact me at pioneerpath@hotmail.com

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bryan27
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posted 12-27-2002 14:25     Click Here to See the Profile for bryan27   Click Here to Email bryan27     Edit/Delete Message Reply w/Quote
Isn't it interesting that at first NPR hated us and now we partially agree with them on this issue. Perhaps this will issue will bring peace between LPFM and NPR.

I do like NPR's limiting of satellite fed translators to the 30dB contour. I would take it one step further though and limit satellite fed translators to the 30dB contour on both the Reserved and Non-Reserved bands. In addition no translators no matter how they are fed outside of the 30dB contour of a full-power station (feeding a translator from a translator serves no purpose).

I agree with NPR's localism issue. These translators serve absolutely no local purpose. What local purpose does the Gulf Area Weather reports on WPCS serve to the residents of Wheeling WV? The purpose of these satellite network translators is to brainwash and convert the masses.

Further I agree with some of REC's comments. Because of their local purpose LPFM should be permitted to bump a non-local translator.

I may be dumbfounded at times, but aren't translators intended to bring FM service to unserved or underserved areas? If so I would hardly call the Wheeling WV radio market an unserved or underserved area, which has 8 commercial stations, 3 NCE stations, and 1 LPFM.

When we have finished our comments I'll let everyone know.

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Modern Populist
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posted 12-27-2002 16:11     Click Here to See the Profile for Modern Populist   Click Here to Email Modern Populist     Edit/Delete Message Reply w/Quote
Bryan --


Please check your Mailbox. I have just sent you a private E-Mail Message on this subject.


Yours,


Don

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RECNetworks
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posted 12-27-2002 19:20     Click Here to See the Profile for RECNetworks     Edit/Delete Message Reply w/Quote
quote:
Originally posted by bryan27:
I do like NPR's limiting of satellite fed translators to the 30dB contour. I would take it one step further though and limit satellite fed translators to the 30dB contour on both the Reserved and Non-Reserved bands. In addition no translators no matter how they are fed outside of the 30dB contour of a full-power station (feeding a translator from a translator serves no purpose).

I am against the use of the 30dBu contour basically for the reason that out west and in Alaska, there are a lot of truly underserved areas where there is no full power within 30dBu. For example, some areas of northern Nevada are outside the 30dBu contours of stations in Reno and Las Vegas but should be able to receive services from those stations without any restrictions. This is why we are pushing the same state/400km out of state guideline for determining if a station is local.

quote:

Further I agree with some of REC's comments. Because of their local purpose LPFM should be permitted to bump a non-local translator.

We do feel that satellators should be bumped however past policies would more likely favor grandparenting existing satellators below 92 and new satellators applied for after a specific date (such as the NPRM) would be subject to displacement if an LPFM, local translator or displaced Class-D can make a showing that no other channel is available for use. It's not the way we really want to do it but it is good (easier to sell to the FCC) policy.

quote:

I may be dumbfounded at times, but aren't translators intended to bring FM service to unserved or underserved areas? If so I would hardly call the Wheeling WV radio market an unserved or underserved area, which has 8 commercial stations, 3 NCE stations, and 1 LPFM.

What is not on ECFS is Calvary's reply to our comments. In those comments, they state that "REC has mischaracterized the meaning of "unserved and underserved". Just because a certain geographic area has an abundance of radio stations, it does not mean that all of the programming niches are represented there." "FM translators such as Calvary... provide primarily religious oriented programming, and they do so in a way that the commercial and collegiate broadcasters fail to do. In many major radio markets, religious broadcasters do not have the financial wherewithal to purchase a full power AM or FM radio station. That being the case, Calvary (and others) should not be disparaged by their attempt to reach the major broadcast markets via the use of FM translator stations. (Footnote: When the Commission created the FM Translator Service in 1970, it was clearly decided that "(b)ecause we recognize that community sponsored FM translators will be requested only where there is a real public demand, we will impose no restriction on the location of the areas they will serve. Id. 20 RR 2d 1538 (1970) para 6

[This message has been edited by RECNetworks (edited 12-27-2002).]

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Modern Populist
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posted 12-27-2002 20:00     Click Here to See the Profile for Modern Populist   Click Here to Email Modern Populist     Edit/Delete Message Reply w/Quote
Re the concept of geographical areas which are "unserved or underserved" in terms of niche programming alternatives:

It seems to me that national evangelical "chains", like Calvary Chapel, are competing with local RELIGIOUS programming AS WELL AS local secular programming.

I KNOW that "homegrown" religious radio stations because I've heard them On The Air. Here in Central Connecticut, which is my temporary abode, WIHS appears to be both popular with evangelical Christians and independent. (WIHS stands for "We're In His Service") Ironically, the station operates out of Middletown, which is also the home of my Left-leaning undergraduate alma mater: Wesleyan University.

Further, I personally know several current or aspiring LPFM licensees who offer, or want to offer, truly local religious programming. These include RABBI BRYAN FRENCH of West Virginia, BILL SPRY of Ohio, IMMANUEL EPISCOPAL CHURCH of Virginia (which I attended for 2 years) and SCOTT TODD of Minnesota.

In short:

We don't need outfits like Calvary Chapel to assure the availability of religious programming on the airwaves.


Yours,

Don Schellhardt

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bryan27
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posted 12-27-2002 22:47     Click Here to See the Profile for bryan27   Click Here to Email bryan27     Edit/Delete Message Reply w/Quote
Don, got your e-mail. I'm working on my draft. Someday I'll join up with the Alliance

REC, may I use some of your translator maps for my Exhibit? And that Calvary responce doesn't hold water.

This is the make up of the Wheeling FM radio market:

89.9--WVNP-NPR
91.5--WGLZ-College Variety
91.9--WPHP-High School Variety
93.5--WBNV-Adult Contemporary
94.1--WVJW-Jewish/Public
95.7--WEEL-Oldies
96.5--WRKP-Christian Contemporary
97.3--WKWK-Soft Rock
98.7--WOVK-Country
100.5-WOMP-Top 40
105.5-WVKF-Urban
107.5-WEGW-Classic Rock

Now this is ADI#233, look at the variety, and it has a locally owned Christian station!!!!

The Pittsburgh market is a major market and has these Christian stations!

101.5-WORD--Religious
730---WPIT--Religious
1080--WWNL--Gospel
1150--WGBN--Gospel
1510--WPGR--Gospel

Looks like 5 religious broadcasters could afford to put up stations. The thing Calvary want's to do is put up stations that cover 100% of the US regardless if the public want's the station or not. And what does it matter if a niche is not represented in an area if there is no one to hear it. For instance in an area where the population is 100% Jewish you wouldn't need to have Calvary Chapel represented with a station because no Christians are in the area.

[This message has been edited by bryan27 (edited 12-27-2002).]

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Modern Populist
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posted 12-28-2002 12:22     Click Here to See the Profile for Modern Populist   Click Here to Email Modern Populist     Edit/Delete Message Reply w/Quote
Bryan --


Those Charts in your posting make a good case!! BE SURE TO INCLUDE THEM in your RM-10609 Comments!!


Shalom,


Don

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bryan27
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posted 12-28-2002 12:38     Click Here to See the Profile for bryan27   Click Here to Email bryan27     Edit/Delete Message Reply w/Quote
Don, they will have nothing on me. I'm going through Radio-Locator and will place every Full Power FM station listed as Gospel, Religious, and Christian Contemporary on a map showing that there is no unserved area.

I can't believe this, not only does Calvary Chapel have the gaul to snatch up frequencies, but they have the gaul to say it is their right to serve an area when they are 1000 miles away and have never been there. That is what makes me really angry. I think I know a bit more of what the public in this area wants than someone in Twin Falls ID.

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Modern Populist
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posted 12-28-2002 02:23     Click Here to See the Profile for Modern Populist   Click Here to Email Modern Populist     Edit/Delete Message Reply w/Quote
Mazel Tov!! Way To Go!!


Don

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RECNetworks
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posted 12-28-2002 03:10     Click Here to See the Profile for RECNetworks     Edit/Delete Message Reply w/Quote
quote:
Originally posted by bryan27:
REC, may I use some of your translator maps for my Exhibit? And that Calvary responce doesn't hold water.

That's one reason why these maps and other services exist. Feel free to use them!

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RECNetworks
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posted 12-28-2002 03:14     Click Here to See the Profile for RECNetworks     Edit/Delete Message Reply w/Quote
Here, this should help you...

KEFX "The Effect" - Calvary Chapel of Twin Falls: http://www.recnet.com/cgi-bin/lpfm/fmq.cgi?input_type=facid&facid=8432

KAWZ "Calvary Satellite Network" - Calvary Chapel of Twin Falls: http://www.recnet.com/cgi-bin/lpfm/fmq.cgi?input_type=facid&facid=8414

WAFR "American Family Radio" - Tupelo, MS - American Family Assoc. http://www.recnet.com/cgi-bin/lpfm/fmq.cgi?input_type=facid&facid=1592

KEAR "Family Radio" - San Francisco, CA - Family Stations, Inc. http://www.recnet.com/cgi-bin/lpfm/fmq.cgi?input_type=facid&facid=20897

KCZO - Carrizo Springs, TX - Paulino Bernal Ministries (possibly now Centro Cristiano de Fe, Inc.) http://www.recnet.com/cgi-bin/lpfm/fmq.cgi?input_type=facid&facid=51959

WPCS - Pensacola, FL - Pensacola Christian College http://www.recnet.com/cgi-bin/lpfm/fmq.cgi?input_type=facid&facid=52230

KILA - Las Vegas, NV http://www.recnet.com/cgi-bin/lpfm/fmq.cgi?input_type=facid&facid=20528

KTLW - Lancaster, CA - The Living Way Ministries http://www.recnet.com/cgi-bin/lpfm/fmq.cgi?input_type=facid&facid=37813

Here are some of the satellator primary stations. Run the "Super Satellator View" when bringing up the queries.

[This message has been edited by RECNetworks (edited 12-28-2002).]

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chuxgarage
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posted 12-28-2002 18:43     Click Here to See the Profile for chuxgarage   Click Here to Email chuxgarage     Edit/Delete Message Reply w/Quote
That's quite a set of maps, REC. Thank you for making them available. They make me wonder if some of these guys have gotten together to divide up satellator territories.

Any way you shake it, they are bad news for local radio.

Chuck

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Modern Populist
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posted 12-29-2002 03:14     Click Here to See the Profile for Modern Populist   Click Here to Email Modern Populist     Edit/Delete Message Reply w/Quote
Yup.


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bryan27
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posted 12-29-2002 03:29     Click Here to See the Profile for bryan27   Click Here to Email bryan27     Edit/Delete Message Reply w/Quote
Rec, Thanks for the maps! Sometimes it is difficult to find who the largest ones are. The GIS has been invaluable for my map creation. This is what I have so far. It's just the Gospel and Christian Contemporary stations. I haven't got to the 800+ Christian Religious stations. BTW these are just the Full Power FM stations.
http://wvjw.info/rel-con.GIF

In another map I will show the location of all the Christian stations with the Calvary Translators (another color of course) which will show that Calvary's translators are in areas already served by other Christian stations.

What we want is CC to slip up by saying what it really wants. Which we know is 100% coverage of the country.

Our comments are comming around. Another thing I will add to it is that the petitioners say this proposal won't expand the translator service since there is a freeze on translator applications, but they fail to show how they or anyone else will limit expansion if this goes through and a freeze is lifted. Hey, I taking this from all angles and ripping it to shreads.

REC, I also forgot. I know you don't like the 30dBu proposal, but think of it this way if a translator is operating outside of the 30dBu contour it would only be bumped if an LPFM needed the frequency. So an area may lose a translator, but it would gain a local station. That's what my thinking is by limiting translators to the 30dBu contour.

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jegrant
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posted 12-29-2002 08:38     Click Here to See the Profile for jegrant   Click Here to Email jegrant     Edit/Delete Message Reply w/Quote
Don't forget the satellators of the Bible Broadcasting Network.

I can't find a primary station, because they don't make it clear on their website which station their satellators originate from. Update: I did some listening to the satellator feed (which I receive via DBS) and the primary station is WYFG - GAFFNEY SC US. Sure enough, when that call sign is put into REC's handy dandy FM Query http://www.recnet.com/fmq/ , a long list of translators comes up, including the map for Super Satellator View.

There is also an extensive list available at: http://www.bbnradio.org/bbn/stations_and_ways_to_hear/us_map_of_stations.htm

Although I do not find fault with their purpose of religious freedom and expression, I can agree that the national expansion of these satellator networks is distorting the original intent of the regulations. It's obvious that what they want is nationwide coverage, not just reasonably sized networks.

Something else to consider when making maps, should be the number of full power stations that many of these groups hold, mainly Class A's but also other classes of full power. If you look at the portion of the country and/or population that gets a distant but listenable signal from a full power or satellator of each group, I bet it would rival the big TV networks.

I think these nationwide satellator nets should be encouraged to move to satellite radio, with the nationwide coverage they want, and phase out the FM channels they occupy, leaving them for local (or less distant local) usage.

To be honest, I wouldn't even mind if local religious stations decided to carry one of these satellator networks (most of whom have or could easily create a version that would be legal for LPFM carriage) during part of their day, because the control in programming decisions would be local, and the frequency wouldn't be forced to carry the national network 24 hours if there were other things the local community wanted to hear at various times.

[This message has been edited by jegrant (edited 12-29-2002).]

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RECNetworks
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posted 12-29-2002 14:55     Click Here to See the Profile for RECNetworks     Edit/Delete Message Reply w/Quote
quote:
Something else to consider when making maps, should be the number of full power stations that many of these groups hold, mainly Class A's but also other classes of full power. If you look at the portion of the country and/or population that gets a distant but listenable signal from a full power or satellator of each group, I bet it would rival the big TV networks.

Yes, we were seeing a trend of Class-A's popping up all over the place. When it comes to full powers, there really is a "big two". American Family Association with over 100 (full power) stations and Educational Media Foundation (operates "K-Lord", "K-Love" and "Air 1") with about 50.

The interesting thing about AFA is that some of their full power stations operate as full satellites of WAFR, Tupelo with main studio waivers while others, such as KBIE here in Fountain Hills AZ actually originate locally originated programming.

BTW.. A big thanks to everyone out there who is doing their own independent research to try to knock this band threat to it's knees.

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bryan27
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posted 12-29-2002 14:59     Click Here to See the Profile for bryan27   Click Here to Email bryan27     Edit/Delete Message Reply w/Quote
jegrant, you got it. I don't find anything wrong with their freedom of expression.
But what I have fault with are statements frpm Calvary like:

quote:
Just because a certain geographic area has an abundance of radio stations, it does not mean that all of the programming niches are represented there.

A niche is normally not represented in an area because there is either not enough bandwidth to add a station, or there is not enough population in an area to support every niche.

This statement can come back to haunt them. Let's say our station gives up it's LPFM and gets a Class A. Well according to CC I have the right to put our Jewish radio niche in every market regardless if there is anybody in a market that is in that niche group.

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bryan27
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posted 12-29-2002 15:29     Click Here to See the Profile for bryan27   Click Here to Email bryan27     Edit/Delete Message Reply w/Quote
Here is what we have in our discussion for the FCC so far:

Translators are intended for Underserved or Unserved areas.

Petitioners state that their proposal would provide quality FM service to underserved and unserved areas (1). However, it has been shown that many of the translators owned by the petitioners are actually in areas well served by Full Service FM broadcast stations (2). If a NCE broadcaster has to find a non-reserved frequency to place a translator it is obvious
the area is well served by other NCE stations.

(NOTE: We will add more to this point and add the maps as exhibits that CC has translators in areas already served by full power Christian stations.)

Translators are not intended to create a National Broadcast Network.

The Commission's Translator Service is intended to provide FM service to areas where Full Service FM is difficult to provide an acceptable signal (IE: stations blocked by Mountains), not to provide FM service to an area that is hundreds and sometimes thousands of miles from the translator's main Full Service Station. Calvary Chapel of Twin Falls however, uses the translator service to provide a nationwide FM network, instead of local stations (3).

(NOTE: This is where our exhibit are the maps provided by REC shows evidence)

The Proposal will hamper the growth of LPFM in an already congested FM Band.

Nearly all LPFM stations reside in the Non-Reserved Band. By their very nature LPFM stations are locally owned and operated, and provide a localized voice. The FM Translators owned by the petitioners retransmit the signal of FM stations usually many hundreds of miles away thus removing the frequency from local LPFM service (4).

Alternative Modes of Reception are already possible instead of the use of valuable FM Bandwidth for translators.

In addition to the plethora of translators owned by Calvary Chapel of Twin Falls, their main station, KWAZ-Twin Falls, is the backbone of CSN (Calvary Satellite Network) and it's national translator network. CSN is available nationwide on Sky Angel DBS (5) channel 9762. The numbers of households currently listening to CSN on Sky Angel DBS are most likely larger than those listening to the FM translators owned by Calvary Chapel of Twin Falls. In addition all Sky Angel DBS subscribers living in an area served by one of those translators has no real need for the translator.

Distant Translator Status.

Kol Ami Havurah feels that public service would be better served if translators operated by NCE stations outside of the reserved band be given a Distant Translator Status that are subject to displacement by LPFM stations if the translator is operated outside of the 30dBu contour of the Full Service FM parent station.

Translators Serving No Purpose.

The petitioners admit that they are using translators as "fill-in" to reach a desired location (6). However, the petitioners do not indicate, nor does it appear that they will give or are willing to give these "fill-in" frequencies back to the Commission if this petition is granted.

Growth of Translator Service.

Although petitioners claim they are not asking for an expansion of the translator service and that no expansion is possible with the current freeze on new translators they fail to address the possibility of fast growth in the event the current freeze is lifted. If the petition is granted translator service will quickly expand, most likely by the petitioners themselves as they will no longer be hampered by the requirement of over the air reception.

(NOTE: I'm still working on this one, the exhibit will show how satellite fed translators have expanded translator service to far flung areas in the NCE band 100's of miles from the primary station)

Let me know your thoughts.

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RECNetworks
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posted 12-29-2002 18:00     Click Here to See the Profile for RECNetworks     Edit/Delete Message Reply w/Quote
Kol Ami Havurah feels that public service would be better served if translators operated by NCE stations outside of the reserved band be given a Distant Translator Status that are subject to displacement by LPFM stations if the translator is operated outside of the 30dBu contour of the Full Service FM parent station.

quote:
Kol Ami Havurah feels that public service would be better served if translators operated by NCE stations outside of the reserved band be given a Distant Translator Status that are subject to displacement by LPFM stations if the translator is operated outside of the 30dBu contour of the Full Service FM parent station.

I hope I understand what you are trying to state here. From the way I read this, you actually want Calvary to be able to put distant translators in the non-reserved (92-108) band but be subsecondary.

REC and NPR are asking for no distant translators, period, in the non-reserved band.

In addition, REC is asking that all new distant translators in the reserved band (88-92) would be subsecondary, subject to displacement by either local LPFMs or local NCE translators.

We continue to oppose 30dBu as written but would be more likely to support it if an exception is made for translators physically located in the same state as the primary station (This was one of NPR's other proposals too). This will give the western states and Alaska the ability to use intra-state satellite fed translators in the non-reserved band.

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bryan27
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posted 12-29-2002 19:02     Click Here to See the Profile for bryan27   Click Here to Email bryan27     Edit/Delete Message Reply w/Quote
That's the gist of it. Sure they can put up translators, but if the translator is outside of the 30dBu contour it would be subject to displacement by an LPFM.

This way satellite fed translators for state wide NCE networks could be used in places out west, such as Alaska, outside of the 30dBu contour, but they would be subject to displacement by local LPFM.

You have to also think about the East, where spectrum is rare because of 3rd adjacent rules. Going out to 400Km would be of little help to LPFM in the East. AFR just converted one of their translators near here to a little 125w Class-A, the 400Km proposal would give them free range for translators in this area:
http://wvjw.info/400km.gif

but the 30dBu contour limit would only give them this:
http://wvjw.info/30dbu.gif


It's kind of a middle ground position.

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RECNetworks
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posted 12-29-2002 20:15     Click Here to See the Profile for RECNetworks     Edit/Delete Message Reply w/Quote
I can understand where you are coming from. Unfortunately, we have a different situation out west. I know that 400km can do a lot of damage in the east.

I have footnoted the comments that I am going to submit stating that if the industry feels that 30dBu would be better, we will support it as long as translators located within the same state, regardless of distance are not considered "distant" translators. This will protect Alaska and the western states.

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RECNetworks
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posted 12-30-2002 04:55     Click Here to See the Profile for RECNetworks     Edit/Delete Message Reply w/Quote
REC's Reply Comments have been sent to ECFS. You can view them at:
http://www.recnet.com/fcc/RM10609r.pdf

Thanks to everyone for your input. Please remember to post your comments at the FCC, even if they are not formal. Every little bit helps.

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Modern Populist
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Posts: 184
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posted 12-30-2002 05:53     Click Here to See the Profile for Modern Populist   Click Here to Email Modern Populist     Edit/Delete Message Reply w/Quote
Dear FRNers,

I have been "floating" DRAFT Reply Comments, in FCC Docket RM-10609, for review (and possible modification) by active Members of THE AMHERST ALLIANCE.

Our deadline for Member comments has not yet come and gone. However, we have already heard from many of our Members -- and it LOOKS, at this point, as if Amherst will endorse:

(A) A definitional threshold of 60 miles (100 kilometers) in "W Call Sign Territory" (East of the Mississippi River);
And
(B) A definitional threshold of 120 miles (200 kilometers) in "K Call Sign Territory" (West of the Mississippi River), and perhaps an even higher threshold in Alaska.

Our ESTABLISHED position, as developed and expressed in April of 2002, has called for a 60-mile (100-kilometer) definitional threshold for "distance translators" NATIONWIDE. So REC NETWORKS, with support from some other Western Am'sters, has definitely had an impact on the thinking of the Amherst Membership as a whole.

Yours,


Don Schellhardt

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Scott Todd
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posted 12-30-2002 14:27     Click Here to See the Profile for Scott Todd   Click Here to Email Scott Todd     Edit/Delete Message Reply w/Quote
REC wrote

>>We do feel that satellators should be bumped however past policies would more likely favor grandparenting existing satellators<<

Grandparenting!! Damn, but you're into PC-speak. But the male of the species is expendable, especially white, heterosexual, Christian males. Actually I do agree with much of the thread, otherwise, even though my two contract stations are both K-Love satellators. (I needed the extra $$ and experience.)

I also discouraged my church from building its own radio station since they would be duplicating formats to an existing station.

BTW, Don, I've pretty much given up on LPFM. If I do anything, it'll be on AM in stereo. I'm fighting this stupid, band-killing "HD Radio." I appreciate the Amherst Alliance comments on it. I was hoping to have filed my own by now, but time hasn't allowed for it so far.

Scott Todd
now CE at KKMS/WWTC/KYCR

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bryan27
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posted 12-30-2002 15:50     Click Here to See the Profile for bryan27   Click Here to Email bryan27     Edit/Delete Message Reply w/Quote
Rec, what's the policy on filing for this RM?
Is electronically okay, or does it have to be filed by mail to all parties and the FCC, or both?

I should be done with ours by Friday. This latest chart I'm working on will burst the petitioner's bubble. It lists the translator and the Full Power Christian stations in the area covering the translator with a 60dBu or better signal.

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Modern Populist
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posted 12-30-2002 16:43     Click Here to See the Profile for Modern Populist   Click Here to Email Modern Populist     Edit/Delete Message Reply w/Quote
Bryan --

The Commission strongly PREFERS electronic filing (although it's OK to send hard copies as a "backup").

Here's an illustrative story:

On December 20, in FCC Docket MM 99-325 (IBOC Digitalization), I filed a 36-party Reply to the Glen Clark & Associates. Later, I found that the document had been posted on the ECFS, but couldn't be opened by anyone. (For reasons unknown)

So I did The Next Best Thing: I FedExed an original and 10 copies on December 23.

Well, the FedExed document STILL hasn't been posted on the FCC's ECFS. When I E-Mailed the ECFS people to inquire, I received a brief response stating that "paper filings" now "require 5 to 7 days for processing".

The moral of the story:

Everything goes a lot more smoothly if you file electronically.

Yours,

Don Schellhardt

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Modern Populist
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posted 12-30-2002 16:46     Click Here to See the Profile for Modern Populist   Click Here to Email Modern Populist     Edit/Delete Message Reply w/Quote
Scott --

Good to hear from you!! I hope you're happy and healthy.

There IS some action afoot on Low Power AM. So maybe you'll have your own station yet.

Yours,


Don

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WKJCE RADIO
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Posts: 257
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posted 12-30-2002 18:05     Click Here to See the Profile for WKJCE RADIO   Click Here to Email WKJCE RADIO     Edit/Delete Message Reply w/Quote
Rec great work on your comments..
now the hard part Julie and I want to file something as well, even though yes I am still a active member of the Amherst Alliane
and she hasnt decided or really know what any of this is about , just knows her girl friend is very active in the LPFM radio scene and some consider her a pioneer ..

however even though she dosnt understand it
she agrees that there are already too many "christian" stations on the air..
Yes Shes even a christian but cant belive what some of what they preach .. "this country was founded on christian foundation and we need to get back to god" ...
she was brought up in a very close minded "christian home" much like I was however something opened my eyes about this garbadge...
and shes beginning to too ...

I just keep wounderering since iam part comanche indian how was this country founded on christian princiaples - lol
we were here before them ...

anyway
we just cant figure out which comments we should use yours or amherst alliance ..
Poor Don usally makes up drafts but i understand he may not have the time ...

oh oh time for focus on the family ...
...gets up to turn the channel ....
1
2
3
Whew made it lol I rather listen to Gender talk any day over that lol

thanks
oh yes we do carry Gender Talk radio on our live365 stream as well as some of our other programs .. if no one has gotten to listen I would encourage at least one show
thanks
-Joanne Lynn
WKJCE GLBT RADIO http://www.pennswoods.net/~jsjb/WKJCE/index.htm

Ps thank you to John Cruzan for the redirct pages from the FRN...

------------------
=================================
======================================================================
WKJCE GLBT RADIO pages www.frn.net/wkjce/
======================================================================
May the voices in the wilderness be heard through Low power radio ......

[This message has been edited by WKJCE RADIO (edited 12-30-2002).]

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bryan27
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posted 12-30-2002 23:04     Click Here to See the Profile for bryan27   Click Here to Email bryan27     Edit/Delete Message Reply w/Quote
Well, here it is. All I have to do is finish the research to fill in the numbers and add/complete the exhibits.
http://wvjw.info/10609.doc

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RECNetworks
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Posts: 203
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posted 12-31-2002 12:49     Click Here to See the Profile for RECNetworks     Edit/Delete Message Reply w/Quote
Bryan..

excellent comments.

You can use the Electronic Comment Filing System (ECFS) to submit your comments.

Go to: http://www.fcc.gov/e-file/ecfs.html

Submit a filing. Remember to use proceeding RM-10609.


JoAnn:

Let's try not to make this a religious issue. Let's say that Calvary Chapel was really Calvary Jazz Soceity and they set up 300 translators across the country in the reserved band to play jazz music with no localism at all (except if you lived in Twin Falls). We would still be fighting this.

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Modern Populist
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posted 12-31-2002 01:34     Click Here to See the Profile for Modern Populist   Click Here to Email Modern Populist     Edit/Delete Message Reply w/Quote
Dear Joanne, aka Garf --


Please check your Mailbox. I just sent you something you might find helpful.


Yours,


Don Schellhardt

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hawkfm
Mental Patient

Posts: 303
Registered: Jan 99

posted 12-31-2002 05:31     Click Here to See the Profile for hawkfm   Click Here to Email hawkfm     Edit/Delete Message Reply w/Quote
Hi, everyone. I know it's not a lot but, I thought I'd add a little tidbit that someone might be able to begin building upon as a means of demonstrating that these goons will do whatever they can to establish their "satellators" nationwide at any possible power level:
http://www.fcc.gov/eb/Orders/2002/DA-02-2336A1.html

------------------
Terry Keith Hammond
President/Technical Director

http://www.MonsterFM.com

MonsterFM.com/KBKH-FM P.O. Box 688
Shamrock, TX. 79079

(806) 256-1221

Exemplary Technical Services for the Broadcast Industry. Well, as "Exemplary" as the owners are willing to pay for...

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WKJCE RADIO
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Posts: 257
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posted 12-31-2002 07:15     Click Here to See the Profile for WKJCE RADIO   Click Here to Email WKJCE RADIO     Edit/Delete Message Reply w/Quote
quote:
Originally posted by RECNetworks:
Bryan..

excellent comments.

You can use the Electronic Comment Filing System (ECFS) to submit your comments.

Go to: http://www.fcc.gov/e-file/ecfs.html

Submit a filing. Remember to use proceeding RM-10609.


JoAnn:

Let's try not to make this a religious issue. Let's say that Calvary Chapel was really Calvary Jazz Soceity and they set up 300 translators across the country in the reserved band to play jazz music with no localism at all (except if you lived in Twin Falls). We would still be fighting this.


hi REC we agree however this isnt Calvary Jazz Soceity its Calvary Chapel..
a org at one time we were trying to help out with a radio station in phx az ..
but looks what is happening now and we cant support what Calvary Chapel has been tring to do knowing what it could mean for the rest of us ...

Even if Bush tried this We would fight him as well - no we dont like him either and never will ...
Hes very bad for this country... amd has been doing alot of damage to our rights and freedoms as we once knew them ....
-joanne lynn

[This message has been edited by WKJCE RADIO (edited 12-31-2002).]

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Scott Todd
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Posts: 304
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posted 12-31-2002 14:12     Click Here to See the Profile for Scott Todd   Click Here to Email Scott Todd     Edit/Delete Message Reply w/Quote
quote:
Originally posted by WKJCE RADIO:
Yes Shes even a christian but cant belive what some of what they preach .. "this country was founded on christian foundation and we need to get back to god" ...


Well, D. James Kennedy has had numerous broadcasts where he's read from the actual founders' documents, and I'd say she has no reason to be astounded those preachers would make such a statement. Our second President, John Adams, once said that our Constitution was made for a "moral and religious people. It is wholly unsuited to the governing of any other." I'll bet your friend attended the government schools since she's so ignorant of our national history. Sounds like she's soon to be brainwashed out of her heritage. The only "freedom" and "diversity" we seem to have in this country anymore are sexual and racial. All other thoughts must conform.

Scott Todd

Borders, language, culture, family.
(hooray for Michael Savage.)

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WKJCE RADIO
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Posts: 257
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posted 12-31-2002 18:05     Click Here to See the Profile for WKJCE RADIO   Click Here to Email WKJCE RADIO     Edit/Delete Message Reply w/Quote
Hello,
For you information, I am NOT being brainwashed!! I am a person who has her own beliefs! Excuse me for being ignorant and not knowing the complete history of this so-called country. But yes, I am christian and I dont believe everything I hear, it's called personality. I hope you learn to ask a person before trying to judge them. It would be nice for them to be able to defend themselves. Thank you!
Julie- Joanne;s girlfriend

Admin

WKJCE RADIO
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Posts: 257
Registered: Dec 98

posted 12-31-2002 18:19     Click Here to See the Profile for WKJCE RADIO   Click Here to Email WKJCE RADIO     Edit/Delete Message Reply w/Quote
quote:
Originally posted by Scott Todd:
Well, D. James Kennedy has had numerous broadcasts where he's read from the actual founders' documents, and I'd say she has no reason to be astounded those preachers would make such a statement. Our second President, John Adams, once said that our Constitution was made for a "moral and religious people. It is wholly unsuited to the governing of any other." I'll bet your friend attended the government schools since she's so ignorant of our national history. Sounds like she's soon to be brainwashed out of her heritage. The only "freedom" and "diversity" we seem to have in this country anymore are sexual and racial. All other thoughts must conform.

Scott Todd

Borders, language, culture, family.
(hooray for Michael Savage.)


Hi Scott I seen my gf posted ..
I have to say the woman has backbone and is very smart ..
No her parents dont like the facy we are living together as a Transgender -lesbian/bi couple but hey its not thier life its her desiscion I dont force anything such as belifes or etc on her
she has her own belifes and is very aware of whats going on in this messed up world ..
and is a actisist to help change things ..
She has helped with the PA Hate Crime Bill http://www.eriegaynews.com/news/200301pahatecrimebill.html

as well as a few other GLBT issues, I hope she will ask question about what i do LPFM and takes to our side on this mess lol

I was going thru some old stuff off the personal expressions server -looking for graphics and etc for some sites i want to try to bring back online like the amherst alliance home page when i came across this its old but its still intresting...

A new Religious Right bill that is Dangerous....

Hello everyone. We recieved this message and felt that it was important
enough to pass along. We strongly urge all US citizens to read the following
message and take the appropriate action by getting in touch with your
representatives and demanding that they vote against this obviously
unconstutional bill.

If this bill passes, the implications are everything that we are
against. It will allow people to hide behind religious "freedom" in order
to discriminate against people, forcing minority groups, specially the GLBT
community who has been specifically targeted by this bill, to live in
poverty, shame, fear, and secrecy. This bill would, while claiming to
protect "religious rights", in effect descriminate against those who hold
religious beliefs which include non-discrimination, sacred homosexuality
(i.e. some pagan/Native beliefs which include the concept that same sex
couples maintain a more balanced male/female energies or ying/yang) and
respect for other people's lives, privacy, and ability to survive in a
world without being forced to live with fear that they will be targetted by
these religous zealots!

This is a clear cut case of the government giving in to hateful agendas
while ignoring the Constitution which guarantees that ALL people are to be
equally protected by the law and given the freedom to "the pursuit of
happiness" without being subjected to any one else's religious beliefs. It
is exactly for this reason that our forefathers created the seperation of
church and state, clearly stating that the government shall NOT make any
law which gives preference to any one religion over another or which
entitles one religion's followers more rights or freedoms than followers of
any other religion, a fact that our current representatives have choosen to
ignore in order to give in to the religous right's demand to be allowed to
legally discriminate and even to force others to discriminate based upon
their religious beliefs all to further their religious agenda of forcing
everyone to abide by the "morals" as defined by the few elite men in
religious power.

If this bill passes, it will not only be a miscarriage of justice, it will
be a sure indication that The United States of America is no longer
"united" or a "democracy" as we will all be governed by the religious views
of others while ignoring the right of the many tax paying, law abiding
citizens who do not agree with legally allowed biogtry. Because of that, I
beg each and every one of you to read the following message and take
action! Let your representative know that we know that what they are doing
is unconstitutional and that we demand that the rights of ALL people be
protected equally.


Religious Liberty Protection Act (RLPA) - HR 1691

Hey everyone,

We of the GLBT community facing a crisis right now. Some SERIOUS STUFF is
going to happen to us if we don't act now to stop the Religious Liberty
Protection Act (or at least have it amended with the Nadler Amendment). If
you're receiving this alert, it is probably because you are a contact
member for a GLBT organization. It is vital that you distribute this
information to your members ASAP, so that we can act as a community to stop
this bill from shredding what few civil rights protections we now have!
Dianna Cicotello explains the bill better than I.
-Sarah Fox, QUILL Chief Administrator

Imagine this scenario:
A coworker tells the company - your boss/supervisor - that they object to
you, your sexual orientation, your crossdressing, your gender-role...that
they object to *you* because you are GLBT, and that there is a Federal Law
which would require the employer to therefore fire you, or your landlord to
evict you because of this objection. There is such a law now working its
way through Congress.

Jay Sekulow, Chief Attorney for the Christian Coalition (Pat Robertson) and
head of a group called the ACLJ, brags openly that this law would enable
Christians to rid the workplace and our schools from the "gay agenda"; that
"employers would not be able to violate [Christians] firmly held religious
beliefs." ... that a Christian who was offended by the presence of a GLBT
or perceived GLBT coworker would be able to have that person fired.

There's a bill speeding its way through Congress that would shred much of
the protection against discrimination provided by the dozens of local and
state GLBT civil rights laws. It carries the title - Religious Liberty
Protection Act (RLPA)--and it prohibits states from "placing a substantial
burden upon a person's religious exercise." Conservatives like the RLPA -
whose author is GOP pit bull Charles Canady of Florida - because it
strengthens the place of organized religion in society. Liberals like the
bill because it would protect minority religions in, for example, the
wearing of beards, turbans or yarmulkes, or taking off religious holidays
not celebrated by employers. Nearly half the original sponsors are
Democrats. And RLPA is backed by a coalition of some seventy religious,
professional and political groups from across the spectrum.

But now the American Civil Liberties Union, originally a strong supporter
of RLPA, has withdrawn from that coalition after careful study of the bill,
charging - as ACLU legislative counsel Christopher Anders puts it - that
RLPA is "a devastating piece of legislation on sexual orientation, marital
status and the like that would upset the balance of civil rights laws at
the state and local level." And a number of original RLPA sponsors -
including liberal Democrats Jerrold Nadler, William Delahunt and Robert
Wexler--have taken their names off the bill because of their concerns about
how it would affect local gay rights laws.

Many religions teach that homosexuality is a "sin" and an "abomination"
that can never be condoned. RLPA would grant those claiming such beliefs a
religious liberty exemption from gay rights ordinances and would also
permit other forms of bigotry.

While the limits of RLPA would ultimately be decided by the courts, on its
face the bill would permit people to cite religion as a reason for
discriminating not just against homosexuals but also against people with
other differences of which they disapprove on some ostensibly religious
grounds. Thus, as the ACLU put it in testimo