Now comes Dana Puopolo ("filer") who respectfully files his comments in this proceeding. Filer does not support this proceeding. I believe that eliminating the main studio rule rule is bad for the radio industry as a whole. The radio industry is in decline because of consolidation and doing this only increases that decline even further. To illustrate this I use the example of Educational Media Foundation, a large non commercial FM consolidator who operates most of their FM stations with waivers of the main studio rule rule. Here in Philadelphia they own a full class B (formerly) commercial FM station, which is run with no staff whatsover. They also are the LP-1 station for this entire area of New Jersey. The problem is, by running this station from the Bay area of California, they have no connection to their licensed community whatsoever. Their entire property here consists of a small transmitter building located in a swamp with a satellite dish atop it. Period. Many if not most of their other stations also operate in this way. There is zero connection to the city of license. What if there is an emergency and a local official needs to relay emergency information?  He has to call their main studio in California to broadcast on a transmitter located down the street! How does that make any sense? Having one operator doing this is bad enough - letting them all do it would be catastrophic!  I predict that radio as an industry would be irreversibly hurt if this is allowed to come to pass. The major consoludations will build regional or national 'mega studios' where the programming for hundreds if not thousands of radio stations will come from - turning radio programming into Pablum and costing the industry many thousands of jobs. I have been in radio almost 50 years and in my time have seen it fall into decline in large measure BECAUSE of deregulation! More deregulation will not slow down this decline, only make it happen even faster. Thanks to deregulation we have seen many local stations move closer to bigger cities. In many cases the only tie that binds the stations TO their cotounities of license is the local studio there. Adopting this proceeding will only serve to permanently sever that! 

This proceeding is bad for radio and therefore I do not support it. I respectfully urge The Commission to not adopt this proceeding.


Respectfully submitted,

Dana Puopolo
114 Conestoga Road
Wayne, PA 19087
dpuopolo@usa.net