Examples of How to Announce Events on the Air
Examples of How to Announce Events on the air
KBOO is co-sponsoring a benefit/fundraising concert for the non-profit group: Rock and Roll Camp for Girls. The only money being 'made' is the proceeds from the benefit which go to the non-profit ... we are given tickets to give away on the air.
We can use promotional language and accept the consideration because its a non-profit group; a program host can talk about the event anyway he/she wants; the guests can also promote the heck out of it. It can be the subject of the whole show.
KBOO is co-sponsoring a hip-hop festival. Most of the proceeds come to us because its a benefit for the station. The festival is taking place at Berbati's Pan (a bar). They are selling beer and food - making a profit. We are giving tickets away to the event.
We must use informational language when we announce the event. We can give the tickets away; a program host must refrain from using any promotional language; the guests can't speak about it at great length and also must refrain from using ‘calls to action’. Only a short amount of time can be devoted to announcing the event.
KBOO is airing a huge blues festival. Most of the proceeds go to a food bank - a non-profit - which is the event organizer. There are vendors selling goods at the festival - making money, left and right. No consideration received.
We can use promotional language to announce the event; a program host can say anything, as often as he/she likes; guests can talk about the event during the whole show.
Save the Salmon is holding a fundraising salmon bake - its a non-profit. KBOO is not co-sponsoring the event. A rep with the organization appears on KBOO talk radio.
You can spend lots of time talking about the issue of saving the salmon, and you can spend lots of time talking about the group. You can also talk about the event and because it is a non-profit and there is no consideration you can use promotional language. You cannot spend time raising money for Save the Salmon. You can mention that the event is a fundraiser--but you are not raising money for STS when you do that, so you are ok.
The Alliance Newspaper (a non-profit) is bringing Winona Laduke to town to give a lecture on "Privileged White Men in Politics". Winona is getting a pittance for speaking. The tickets cost $10.00. No consideration received.
You can use promotional language to announce the event; a program host can say anything, as often as he/ she likes; guests can talk about the event during the whole show.
The Willie Week paper (a for-profit) is bringing Haanan Ashwrai to Portland for a speaking engagement. They are paying her close to normal lecture fees. We have tickets to give away on the air.
You can use informational language about the event; a program host cannot use promotional language nor can the guest speak about it at great length. Only a short time can be devoted to announcing the event.
A program host is doing a show on youth violence. One of the guests is the mother of a young man recently injured in a gang incident. The mother doesn't have adequate health insurance. She wants to solicit donations on-the-air from listeners to contribute to the "Johnny Get Well" fund.
A program host should be the one to announce information about giving donations -- not the mother -- with language like: "If you would like to contribute to the Johnny Get Well fund, you can contact his mother at 503-555-1212." It can only be announced a few times during the entire program - not excessively - and only by the host. The principle here is that you cannot interrupt regular programming to fundraise for another non profit.
A volunteer programmer is a musician. They are performing at a pub but don't expect to make any money. Can they promote the event on their own show? Can they promote that event on anyone else's show? Can a volunteer programmer ever announce an event that they are participating in whether they are or are not making money?
The FCC says that a host cannot use the airwaves to promote anything in which the host has a financial stake. So the short answer to is: No. However, if a volunteer is going to announce her own gig, she must not hype it and she must announce other gigs by competitors -- ideally more time should be spent on the competitors than on her own gig. You are much less like to have someone file a complaint, and if a complaint is filed, it is easier to defend yourself if you can show that lots of other artists, clubs, etc. were mentioned and given as much or more airplay, mention, etc.
More notes from conversation with Ginny Berson November 19, 2007, Arthur Davis and Toni Tabora-Roberts:
When is KBOO receiving “consideration?”
- YES: We receive tickets or money. Musician donates performance.
- GRAY AREA: We receive attendant publicity such as logo on brochures, banner on stage or announcements from stage. The FCC hasn’t ruled on these. If they ruled against us as a first case, we would get a warning.
What type of special programming can we air?
- We can air a live broadcast of the Pickathon (using underwriting language only)
- but we cannot do a one-hour “Pickathon Special” playing cd’s of Pickathon artists.
- If we consponsor a political speaker such as Michael Parenti, we can air a one hour interview because that would be our normal programming, whether or not we were receiving consideration.
- “You are invited” and “KBOO presents” are allowed and are not considered promotional language.
- We can announce co-sponsorships as often as we like.
- We can promote in our Listener Guide and website using any language that doesn’t present IRS issues.
- Why does NPR seem to “get away” with a lot? 1) They receive non-binding FCC opinions on their material. 2) There has to be a complaint to have an FCC action. Community stations get more complaints because most of them come from “disgruntled employees and volunteers.” Ouch.
From the FCC on WNCW:
Noncommercial broadcasters are generally prohibited from broadcasting messages that promote the products, services or businesses of for profit entities, if made in exchange for remuneration. However, where "economic consideration" is not the basis for the broadcast of particular announcements, noncommercial stations may broadcast messages promoting local "transitory events," such as movies, plays, concerts, etc., including ticket prices and information, so that listeners may be informed as to local happenings. In this case, complainant Bill Bost claims that the station broadcast announcements in October, 2000, promoting a for-profit concert event, “The WNCW Mountain Oasis Music Festival,” transcripts of which are attached. Mr. Bost contends that the music festival was not the station’s own event, but was jointly sponsored with ACE, and thus served to impermissibly benefit a for-profit entity.
Can a programmer make a donor acknowledgement for someone who supported their own work?
Situation: A programmer has someone maintaining their website in exchange for on-air announcements. Can the programmer do this?
According to John Crigler, “No”:
- The primary issue is that underwriting must give value to the station, but support for her website has no value for the station. The programmer is therefore using KBOO air time to thank someone for something that didn’t give value to KBOO. It’s illegal.
- The smaller issue is that we must have consistency of underwriting rate, and this situation doesn’t meet that test.
How is this different from a program that thanks donors who supported the show? For example, Dmae gets grants to produce a program. The grantors are mentioned.
- The station is getting the program in exchange for including the donor acknowledgements. Therefore we have agreed to air the donor acknowledgements in exchange for the right to air the program (we are receiving value).