January 5, 2011
Jennifer Kunkle
Sirius XM Radio Inc.
1500 Eckington Place, NE
Washington, D.C. 20002
RE:
Proposal for Qualified Entity Set-Aside Reserved SDARS Channels from Sirius
XM
Dear Ms. Kunkle:
Enclosed is Common Frequency’s proposal for a Sirius XM reserved channel per the
FCC’s MO&O Applications for Consent to the Transfer of Control of Licenses1 adopted
October 18, 2010. Sirius XM issued a request November 23, 2010 soliciting interested
parties to submit a proposal according to the screening questions. Six hard copies have
been provided here within and have been emailed to jennifer.kunkle@Sirius XM.com.
Signed copies of the Agreement have also been duplicated.
Any questions concerning the attached document can be directed to Todd Urick at
todd@commonfrequency.org, or 530-848-7831.
Sincerely,
Todd Urick
Program Director
Common Frequency
1
See Applications for Consent to the Transfer of Control of Licenses, XM Satellite Radio Holdings Inc.,
Transferor to Sirius Satellite Radio Inc., Transferee, Memorandum Opinion and Order, FCC 10-184 (released October 19,
2010).
Common Frequency, Inc.
1
Proposal for Qualified Entity Set-Aside
Reserved SDARS Channels from Sirius XM
Common Frequency, Inc.
“California FM” Proposal
Common Frequency, Inc. (“CFI”) submits this proposal for request to lease one (1) Sirius
XM digital satellite radio channel. Per request guidelines, proposal questions are
addressed below.
---------------------------------------------------------------------------------------------------------------1. Describe your programming plan for each channel you propose to program.
a. An explanation of the nature of the programming you will provide.
About
CFI requests one channel to carry “California FM”. California FM is a radio
service in-the-works centered in the Golden State. With main studio located in San
Francisco, with secondary studio planned for Los Angeles, the service embodies the
spirit, diversity, and innovation of California, while aiming to have national appeal.
California FM is a ground-breaking program concept pioneered by the non-commercial
educational radio advocates CFI.
California FM is the radio station music fans have waited years for someone to develop.
But in addition to music, the format aims to reinvent educational “public radio” for a new
generation.
Branding
The name “California FM” was aptly chosen with homage to its creative
broadcast legacy, spirit of independent music, and culture:

Tribute to the style of pioneering freeform FM stations: early days of KMPX,
KSAN, KPPC, KMET, KZAP, Boss Radio, formative days of KROQ.

Capturing the adventurousness of award-winning California college radio
stations like KXLU, KFJC, KUSF, KALX, KSPC and KDVS, with tribute to west
coast format pioneers such as Tom Donahue, Lorenzo Milam, and Lew Hill.

Distilling the individualism that has contributed to the unique sounds—Sunset
Strip garage scene, Hollywood hardcore scene, East Bay punk, sunshine pop,
hyphy hip hop, 70s country rock, skate boarding, surfing, chicano oldies, The
Smell, 924 Gilman, The Casbah, Free Radio Berkeley, Maximum RockNRoll
Magazine, bilingual rock—and encouragement to pay it forward to nurture new
movements in the current culturally sterile era.
Common Frequency, Inc.
2

Giving airplay to independent artists inspired by the sound of California music
innovators like Chocolate Watchband, The Screamers, Kim Fowley, Jello Biafra,
Blackalicious, Dick Dale, Frank Zappa, West Coast Pop Art Experimental Band,
LAFMS, The Watts Prophets, Ariel Pink.
However, California FM is not only about California music. It is about the spirit of
individualism, celebrating innovative modern music movements. This could encompass
British glam, 60’s French Ye Ye, Afrobeat funk, NY no wave, Brazilian psychedelia, 60’s
bubblegum and Jamaican soul.
The magic of the channel is the format’s ability to remain accessible to the music
listener without veering into areas only music anoraks would enjoy. The format is
upbeat and rock-centric, with the dj playing an integral part in creating a radio program
rather that playing random tracks back-to-back. This was the art of being a disc jockey
before all radio was formatted.
Audience
California FM is an art- and style- driven lifestyle station programmed by grown
up Generation X'ers and Generation Yes, rather than an industry-driven arm of record
labels cross-promoting sports drinks, video games, extreme sports, and Vans Warped
Tour-like concerts. For adults in later twenties and up, California FM will certainly appeal
to Generation X’ers, who actually grew up partially in eras where remnants of media still
existed that weren’t completely forged by focus groups and branded as “xtreme”.
California FM’s legitimacy will be able to be discerned by teenagers and collegeaged adults longing for something original rather than commodified for their generation.
Bridge Ratings studied radio attrition rates in persons 12-24 years old and found that this
demographic is quickly turning to mp3 players and internet streaming over radio
channels. 2 Bridge recommended the following to radio content providers:








Add variety - more different types of music and different types of programming
throughout each day.
Reduce repetition
Showcase much more New Music.
Hire relatable personalities who can expose this age group to new music.
Podcast your personalities, create blogs, eliminate the pre-recorded, imported
automaton announcers.
Completely embrace all of the technology available as extensions of the radio station.
Re-think commercial loads, placement and production quality. For example, properly
placed hour long sponsorships would enhance client brands and station image.
Provide what the MP3 player cannot.
California FM plans to incorporate all options. As a non-profit, California FM can
afford to invest quality programming infrastructure compared to a for-profit entity
attempting to fill the same niche.
In this digital age, people are demanding more from broadcast services. In order
for radio services to compete with personalized services like Pandora and Last.FM, radio
2
Bridge Ratings Release, How to Make Music Radio More Appealing to the Next Generation, December 2,
2005.
Common Frequency, Inc.
3
needs to evolve from an mp3 jukebox or DJ-assisted jukebox to one where the aircrew
provides something that customized web stream services cannot duplicate. California
FM achieves this by:

Turning DJs from just song announcers to musicologists. Musicologists
provide artist background, music links to social movements and people,
and impart their own personality and charisma into the program so people
grow attached to the shows.

Radio services need to evolve to provide listening interaction with a web
page. California FM plans to have a playlist that allows more information
on the artists and structured interaction with the DJ via the playlist.
b. Will this content be exclusive to this channel or do you plan to air it in
other media as well?
Content on the channel will also be available in limited listening areas in California.
CFI is permittee of limited coverage Class A NCE channels in Morgan Hill, CA, Marshall,
CA, Atwater, CA, and soon to be Two Harbors, CA. This translates to roughly fringe
coverage in San Jose, Santa Rosa, Merced, and Orange County.
There is a tactical advantage for Sirius XM to have California FM programming
duplication and overlap in these areas. These channels are low wattage signals
(ranging from 20 to 500 watts), imparting “fringe” listening radio coverage (below 60
dBu) into specified areas. That means listening is car-only with faint coverage. These
stations can promote the programming availability on Sirius XM in crystal clear
reception. Considering the minimum listenership will register in Arbitron’s 1% rating in
areas, we would anticipate such coverage to compel hundreds to thousands of
individuals to consider purchasing satellite radio equipment due to the cross promotion.
c. If available, provide names and biographies of personalities, demo tapes,
and audio samples of your programs.
All personalities on California FM will be recommended to have ample years of
continuous on-air FM broadcasting experience before being accepted for a daytime or
prime night slot.
Example hosts include:

Jennifer Waits a.k.a. “Cynthia Lombard” has been a college radio DJ pretty
much non-stop since 1986. She has hosted the show Too Cool for School at
KFJC (San Francisco Bay Area) since 1999 and before that was on the air at
KSPC, WBGU, and WHRC. Her show currently incorporates not only
experimental and underground artists with rock, jazz and pop leanings; but will
also include spoken word, educational oddities (from wine records to bowling
instruction), poetry, and international music from the past and present. Female
artists are strongly represented, from jazz divas to experimental geniuses, to riot
grrrl mainstays.

Carolyn Keddy a.k.a. “Carolyn” has been a DJ for 20 years at KUSF San
Francisco, 4 years at WTBU, and a writer, reviewer, and columnist for the
Common Frequency, Inc.
4
longest running monthly punk magazine Maximum Rock N Roll for 19 years,
including 8 years as a DJ for their syndicated radio hour. Her weekly radio show
features the newest in punk and garage bands, influencing Bay Area listeners
tastes so much that she has been awarded “Best DJ, Terrestrial Radio” two
times (2006 and 2008) by the San Francisco Bay Guardian.

Brett Berg, a.k.a. “Bret B” was a DJ at KXLU Los Angeles for a decade (’98-’07)
providing a uniquely skewed view skewed view on the wild, woolly world of
jagged rock, soundtracks, chansons, rags, ragas and any other gloriously loud
nonsense he could get his hands on. Equally idolizing John Peel, Joe Frank
(KCRW), and Wolfman Jack, Bret's ridiculous reign now carries over onto his
hectic and eclectic MP3 blog and podcast Egg City Radio.

Nate Orman, a.k.a. “DJ Nate”, has been hosting the weekly program The Nate
Show on KUSF San Francisco since 2003, a mix of jazz, beats, world music, hip
hop, experimental sounds, mashups, field recordings, and more. Nate was
former Production Director (’03-’08), and Program Director Emeritus at KUSF,
along with serving as booker/curator/manager at CellSpace and ArtSF, an
underground art/music venue.

Tim Matranga, a.k.a. “Timothy J” has been one of the longest running shows—
almost two decades—on KDVS, the University of California station that serves
the Sacramento area. The show, Kicksville 29 BC, covers lesser-known
underrated music in 1960s rock, 1960s and early 1970s R&B/soul/funk, as well
as psychedelic rock of the late 1960s. Collecting records since 1980, rare
psych, garage, and soul are excellent examples of underrepresented areas of
potential interest for satellite radio.

Beginning his eighth year at the legendary radio station KUSF San Francisco,
Howard “DJ Schmeejay” has been delighting listeners and critics alike with his
weekly, visceral, cinematic program, "Radiodrome". Spanning a full century of
recorded music from around the world, each new song presents a whole new
genre, a new era; a fresh way of looking at the way we connect things. Howard
also serves as KUSF’s Co-Program Director.
Above is a sampling of a roster. Others include: Two-decade KFJC host Peter “Zero
Gravity”, host of KFJC’s Saturday night cult prime time show No Way Out, featuring the
best raw rocknroll gems from multiple eras; Brenda Illescas, seven-year DJ of show Sin
Fronterias, a mix of Latin genres without borders (rock en Espanol, Cumbia, etc); Dan
Rowan, host of International Voice of Reason, for ten years on KXLU, serving up postpunk, industrial, breakcore, forgotten novelties, early electronic/moog, kraut rock, early
progressive, etc. CFI is reviewing DJs from stations such as KSPC (LA-Inland Empire),
KCSB (Santa Barbara), and KZSC (Santa Cruz). Eleven-year-old webradio Dublab
(www.dublab.com) from Los Angeles, which has hosts on KXLU, KPFK, and KCRW,
expressed interest in contribution to the project.
Audio is available by request, as a produced sampling reel can be provided if Sirius
XM is interested in California FM.
d. For each channel you propose to program, how much content will be fresh
each week? How much content will be repeated each week?
Common Frequency, Inc.
5
The operation, at full capacity, will have no repeated programming, except for the
reserved option of doing “best of” prerecorded and archive programming during late
nights Pacific time (2 AM – 5 AM) Monday through Friday. The only repeated
programming will be news segments that could average a couple minutes. The
preference is for all music programming to be done live, but due to DJ scheduling
constraints some first-run programming may need to be prerecorded.
e. While it is not required for consideration, you may also wish to provide
examples of illustrative programming that will be carried on the channels
you seek to program.
Programming on the channel will not be fragmented mixture. For master DJs, the art
of programming a show is the segue-way. The idea behind California FM is to take an
accessible track, and follow it up with something related, while then delving into
something the listener would have never explored before. Take for instance the
following:
A track by well-known artist, DJ Shadow, followed up by Afrika Bambaataa
(an Bronx originator of 80’s break-beat deejaying), followed by Afro funk artist,
followed by a New York art disco/no-wave band, followed by a post-punk track
with the same beat, followed by a garage rock track.
Each track follows a logical stream, a sonic relationship with the preceding track, but
all encompass different genres. This type of relationship is not delved into in genrespecific radio channels dedicated to one genre, nor is capable in an automated web
stream service such as Pandora. The only way to provide this service is by an
experienced DJ via radio service.
---------------------------------------------------------------------------------------------------------------2.State how much advertising, if any, the programming will include per average
hour.
Being a noncommercial nonprofit, it is within CFI’s values to minimize the
commercialization of our product. However, our main concern utilizing a Sirius XM
Channel would be to be able to recoup the cost associated with leasing the channel.
Our NCE operation would be funded through grants, membership, and underwriting.
There would be a lower and upper bound for either underwriting or advertising protocols
based upon worst-case expenses:

Lower Bound Plan: California FM would have two 30 second FCC NCE-type
underwriting announcements placed twice per hour spaced at two evenlyspaced times during the hour.

Upper Bound Plan: California FM would have drop-in advertising like the above
replacing the underwriting announcements. Depending on the demands of
satellite programmatic costs this could be up to 4 minutes an hour (less than half
the average of commercial radio). CFI would consult with Sirius XM to
determine their input, as this point is negotiable.
Common Frequency, Inc.
6
In addition, California FM reserves the right to run Public Service Announcements
regarding issues of health (eating right, exercise), protection of the environment
(recycling, save energy), any other notices in the public interest.
a. If the quantity of advertising will differ based on daypart, provide
projections for how much advertising will be included in each daypart.
Total advertising time will not differ per daypart, although rate and ad concentration
may very. If particular talent brings in added advertising interest, we will most likely
pursue hour-long sponsorships, as recommended by Bridge Ratings.
b. Provide your standards and policies for accepting advertising.
Underwriting shall adhere to FCC guidelines for NCE channels (Sections 73.503(d)
and 73.621(e) of FCC Regulations), using the standards and sound of NPR affiliate
more as a frame of reference than network underwriting on NPR, which tends to be
more editorially restrictive. If drop-in advertising is used, California FM would be
cautious in its advertisers not to damage the credibility of our brand. Advertisement
would follow our moral code for not accepting any immoral or questionable activities
(including pyramid schemes, questionable businesses, infomercial-style ads) or
advertising of entities we do not fundamentally agree with (petroleum corporations),
companies with exploitive models (Walmart), or activity that is illicit (fireworks) or banned
by FCC regulation (tobacco). All ad contracts would include a provision that states
advertisers will not discriminate on the basis of race per FCC mandate.3
c. Provide examples of potential advertisers.
American Apparel, Converse, REI, Amy’s Kitchen, Quicksilver, Newman’s Own,
Apple, Dr. Bronners, Etnies, Aeropostale, Ecko Unlimited, Levi's, Pac Sun, etc. Also,
movie distributors, record labels, and electronics manufacturers will seek our audience.
---------------------------------------------------------------------------------------------------------------3.Explain who owns and manages the proposing entity.
California FM is a project managed by Common Frequency, Inc., a registered
California corporation, that additionally is an IRS sanctioned 501(c)(3), a tax-deductable
non-profit entity. CFI has existed since 2006, started for the purpose of assisting
community and educational institutions start licensed non-commercial educational FM
radio stations. CFI has helped dozens of educational nonprofits apply for FCC-approved
channels, and has engineering and legal expertise in licensing channels and building
stations. CFI’s Articles of Incorporation allow us to pursue direct broadcast operations,
so Sirius XM’s approval of this application is highly anticipated:
The Corporation’s authority to establish radio broadcasting stations is as
extensive as law permits, including, but not limited to, primary stations, low power
stations, and repeater or translator units, with or without broadcast to the internet, or
any similar or new electronic broadcast or streaming medium. The Corporation may
3
See Promoting Diversification of Ownership… 23 FCC Rcd 5922 (2008)
Common Frequency, Inc.
7
also establish non-regulated broadcast facilities and medium, including but not limited
to, satellite or cable broadcasting.4
The Articles even direct type of content the Corporation shall produce:
The Corporation’s radio stations will provide broadcasting of public affairs, news,
free speech discussions, music, drama, other entertainment and educational
programs, and any matter substantially affecting the community, promoting cultural
diversity, the arts, or giving voice to the community. To the extent possible, the
programming shall be an alternative to that broadcast by commercial radio stations.
The Corporation’s programming may be distributed to any broadcast entity, group, or
individual, on terms determined by the Corporation and consistent with its nonprofit
and tax exempt status under federal and state law. 5
a. Provide biographical information for all shareholders owning 5% or more of
the outstanding voting stock, and all general partners, officers, directors
and employees.
CFI’s Board of Directors oversee the Corporations activities. The current board
consists of:
Jeff Shaw, President: Resides in Berkeley, California and works in community media
as Production Manager at Davis Media Access, founder and Director of KDRT-LP, and
has prior experience in radio at KVMR (FM).
Clay Leander: Resides in SF Bay Area, with 20 years of production/management
media experience including KPFA, Exec Director at Vallejo Access Ch 27, Alliance for
Community Media, co-founder KZCT (FM), Contra Costa Telecom Task Force, and
Diablo Valley Video Arts.
Tracy Rosenberg: Resides in SF Bay Area, has worked as Executive Director at the
34 year-old media resource and advocacy center Media Alliance since 2007, and has
served important positions at Pacifica Radio.
Nadav Carmel: Resides in Oakland, California, and has had previous radio
experience at Brown Student Radio, Community Radio Providence, and WMBR Boston.
Kristin Koster: Resides in Sacramento area, is a PhD in French Literature, an arts
activist, professional writing editor, and grant writer.
Chris Marland: Resides in San Jose, California, was former General Manager of
KDVS (FM), is a freelance programmer, and is on staff at KFJC (FM).
Marque Cass: Resides in Sacramento area, with experience from WFHB
Bloomington, and currently is Program Director for Davis Youth Media Program.
Yoo-hyun Oak: Resides in Sacramento area, is a graphic designer interested in
media justice and political activism. She's been involved in community radio as a DJ,
volunteer, and Program Director at KDVS (FM).
4
5
CFI Article II-B-1
CFI Article II-B-2
Common Frequency, Inc.
8
CFI’s Program Director, Todd Urick, is an independent broadcast consultant with
experience in submitting engineering proposals for licensing new FM broadcast facilities.
In addition, he also has been legal advisor on several FM projects, filing FCC petitions,
settlements, and transfers/assignments for non-profits across the US.
CFI works in a coalition called Radio for People, which includes National Federation
of Community Broadcasters, Prometheus Radio Project, Pacifica Radio, Future of Music
Coalition, Free Press, and Public Radio Capital. However, these entities have no
controlling/voting stock in CFI.
b. Explain what experience the company, its owners, officers, and key
employees have in producing and providing audio programming.
All Directors and employees of CFI have directly produced and hosted audio
programming for licensed broadcast outlets as affiliated above. California FM project
Program Director would be overseen by the CFM Committee headed by Gavin Dahl.
Gavin has produced syndicated non-commercial radio content, worked for KAOS
Olympia and CBS-owned KPTK Seattle, volunteered extensively at KRBX Boise and
KRFC Fort Collins, and is a working journalist, with stories published in Boise Weekly,
Austin American-Statesman, Raw Story, and Radio Survivor. The CFM Committee will
be made up of a team with experience in radio programming, management, and
underwriting and/or sales.
In addition, CFI has participating consultants Liz Berg, Assistant General Manager
WFMU New York, and Theodore Coe, Development Director from KCSB Santa Barbara,
including content producers from KFJC, KUSF, KALX, KXLU, and KSPC. On the news
side, CFI has chosen Josh Wilson as a consultant. Josh is co-founder of San Francisco
nonprofit Independent Arts & Media and Newsdesk.org. As professional journalist and
editor, Josh has worked in various staff and contract capacities for SFGate.com,
Meredith Corporation, and Wired magazine, and as a freelancer for the San Jose
Mercury News, the San Francisco Bay Guardian, and other publications. CFI has also
procured the professional help of Justin Beck. Justin is a media consultant, and
journalism teacher at San Francisco State University. He previously worked for the San
Francisco Chronicle as a multimedia producer, and as a producer, reporter and host for
"Making Contact," a nationally syndicated public affairs radio show.
Collectively as an entity, CFI is qualified to develop and maintain broadcast
operations, as evidenced by decades of combined experience, and cred among our
allies with new NCE FM radio facilities.
c. Is the proposing entity an FCC license holder of one or more full-power
broadcast stations? If so, please provide each station’s call sign, radio
service, and location.
CFI is permittee of three NCE facilities—Fac ID.’s 176797 (KXCF Marshall, CA),
176739 (KZCF Atwater, CA), 176421 (KHCF Morgan Hill, CA)—with one pending as an
assignee (Fac ID 175847 Boulder Creek, CA). KZCF is a permit to be tentatively run
under an LMA with the University of California.
Common Frequency, Inc.
9
If needed, CFI could divest from ownership of all FM permits if Sirius XM considers
the California FM proposal as a satellite channel contender but has already filled its
channel quota for full-power broadcast licensees, and has open channels for nonlicensees. 6 At the time this application has been submitted, CFI holds no approval of
any stations that are licensed to cover.7 Therefore, CFI is only a permittee, and not a
licensee. The awarding of a non-licensee satellite channel would then be sanctioned
under the FCC’s selection process (pending divestiture) since the contingency is only for
licensees.
d. Does the proposing entity have an attributable interest in the licensee of a
full-power broadcast station? If so, please describe the nature of the
interest and provide the station’s call sign, service, and location.
CFI, nor any of its directors holding voting stock hold attributable interest in any other
full power licenses.
e. Does the proposing entity have an attributable interest in any other entity
that has applied or intends to apply to program channels under this RFP?
CFI, nor any of its directors holding voting stock hold attributable interest in any other
entity applying for an Sirius XM channel under this RFP.
---------------------------------------------------------------------------------------------------------------4.Explain how (answer each question that applies):
a. The proposed programming will provide a new source of programming in
the mass media industry.
A Brand New Independent Music Service
California FM does not intend to duplicate anything currently available on
Sirius XM or commercial radio anywhere in the United States. Select CFI members
are acquainted with the many great formats on Sirius XM. We have digested the bevy of
offerings of Rock, Electronic, Hip Hop, and Pop Channel selections, but have yet to hear
a channel that delves into the originators and innovators of contemporary genres. There
are literally hundreds of thousands of titles by artists from rock to soul that have never
made it to mainstream compact disc release.
If you ask any diehard record collector, they will extol the virtues of swimming in
the sea of seminal recorded sounds eclipsed from general consumption by the record
industry whose pursuit to market a very select number of mainstream artists has limited
access to rare records. Much of the time, these represent the cream of their respective
genres. With California FM on Sirius XM, listeners will have exclusive access to
hundreds of thousands of rare records they wouldn’t hear anywhere else in the
6
“Sirius XM may allocate to full-power broadcast licensees no more than one half of the total capacity required
to be set aside under the condition”, see Para 27, Applications for Consent to the Transfer of Control of Licenses, XM
Satellite Radio Holdings Inc., Transferor to Sirius Satellite Radio Inc., Transferee, Memorandum Opinion and Order, FCC
10-184 (released October 19, 2010).
7
KXCF has applied for license to cover, but the application has not been approved as of January 2, 2010
Common Frequency, Inc.
10
world except, even if they were invited to sample a record collector’s personal
stash. You’ll hear slabs of warm vinyl—the soul of real music—straight from the studio,
delivered via satellite. Airplay will be accompanied by biographical information about the
artists by seasoned music experts with years of on-air broadcast experience. Along with
each record you’ll also hear biographical information on the artist from music experts
and record collectors, and not just people hired for their voices.
Along with archived vinyl, a third of the musical programming will be devoted to
new artists who receive no airplay in traditional outlets. To the basic rock n roll radio
fan, credible rock music died in the eighties (or even the seventies), and was briefly
revived for a second in the early nineties with “grunge” music, but died shortly after the
movement was co-opted by the record industry. Most people do not know that the
movement went underground and has stayed there ever since. Rock n roll artists,
street-level artists, and artists from new/unexposed genres release hundreds of vinyl
singles and LPs every year, but you do not hear them on commercial or public radio, or
for that matter, on Sirius XM. Rock movements like psychedelic, glam, punk, and
new wave used to filter into the mainstream when radio used to give the “new
sound” time on the radio, ushering in new eras in rock n roll. This does not
happen anymore; the record industry will not take a risk for the latest “new” sound.
Instead, the record industry attempts to make its own new rock genres, like by crossing
rap and rock, goth and mainstream rock, hiring pretty faces to sing stale songs, creating
what many true music fanatics levy as far too digitally overproduced, with artists all
sounding the same.
In our listening survey of Sirius XMU, Underground Garage, Alt Nation, and other
channels, we were unaware of any of these artists obtaining any airplay, except possibly
on the Gorilla vs. Bear show in XMU. Although we are giant fans of XMU/Left of Center,
the “college music” descriptor had diverged to mean “alternative” or “indie pop” post2000, meaning it references a certain “soft” alternative rock sound that derived from
band like R.E.M, 10,000 Maniacs, The Cure, and The Smiths, but now refers to their
modern equivalents like Arcade Fire, The Shins, Radiohead, and Death Cab for Cutie.
If you turn into a legendary college music station like KXLU, the stations do not
sound similar to “college music services” that originate from commercial sources.
Select freeform college stations are the last bastion of what real radio was like before the
1980’s. As in artists and musicians in music scenes doing radio. It’s 7-inch records from
new bands and artists that don’t sound anything like releases currently being promoted.
To that effect, an estimated 98% of the artists proposed to be played will have
no overlap with any of the other Sirius XM channels. It is our mission to usher in the
newest sounds in burgeoning music scenes by emerging artists on small independent
record labels. This differs from simply a new music service because we are creating
more than an mp3 jukebox. California FM is a west coast export built by music fans,
artists, and journalists collaborating under a nonprofit with strong allegiance to refusing
corporate tie-ins or music industry payola.
California FM intends to encapsulate the spirit of “wild west radio” done by the best
veteran college and community radio DJ’s on the west coast. It is not “amateur radio”,
nor NPR “horse whisperers”; we are experienced, knowledgeable voice talents who
provide more than just a voice-tracked DJ wannabe announcing alternative hits.
Common Frequency, Inc.
11
A Brand New Independent News Service
Besides music, California FM will employ innovative news reporting approaches. As
traditional print news—an essential source of investigative journalism—disappears, new
forms of alternative journalism need to evolve. California FM intends be the public radio
of the “remix generation”.
Current public radio entities have an aging median listener demographic (averaging
in the 50’s) because they cling to the old “newscast” model and schedule half hour and
full hour public affairs shows. The delivery is respectable, but also parched, unable to
capture the short attention spans of today. Commercial talk radio on the other hand can
be dividing, and delve into hearsay, pressing emotional buttons rather that delivering a
straightforward news picture without opinionated baggage.
The web generation digests audio content differently, most listening is unpinned from
time. Our model mixes aggregated news briefs into a content mosaic that includes
music, entertainment and interviews. This regional content would be assembled by our
own team of producers and presented live in real time. The paradigm is different than
public radio where content is produced by elite entities and syndicated, largely
disconnected from public participation, and talk radio, in which the overall
communication is spun by the presenter. Our model utilizes news from grassroots
sources and through citizen-participation via the web, compiled by an executive editor to
provide a unique perspective on current events. For the overall package think the
edginess of Rolling Stone reporting, meets the integrity of BBC, marketed to an
audience that enjoys The Daily Show with Jon Stewart.
California FM will have intelligent stories on current affairs, environmental concerns,
science and research via interviews with scholars, stimulating discussions with authors
who are promoting new books, historical musings, and political dissection without being
polarizing. Stories are dosed within music sets, within small sequences, with headlines
that can be accessed for in-depth analysis by visiting California FM's real-time playlist.
The playlist will include links to stories and full audio clips for on-demand exploration.
b. The proposing entity is a new entrant in the mass media industry.
CFI is a young start-up of four years with new ideas and qualified personnel from
non-profit media operations, with no affiliation to networks including NPR and PRI, or forprofit agencies. The organization is looking for opportunities to bring forward a new
paradigm in broadcasting and offer a fresh prospective on technique and DJ personality.
Mass media today is afraid to take any of the steps needed or provide investment into
retooling broadcast services. You hear over and over that “content is king”, and serving
diverse voices with smart content is the future, but very few of the main players are
stepping forward to make that a reality. In the meantime, mass media is losing audience
to web-centered services, and there are few openings for new non-profit startups like
CFI to pursue distributing new content forms geared towards younger generations.
c. The proposed programming offers a diverse viewpoint or diverse
entertainment content.
CFI offers both diverse viewpoints and diverse entertainment content.
Common Frequency, Inc.
12
Concerning viewpoint:
CFI works with national groups such as Native Public Media, National Federation
of Community Broadcasters, and Free Press; has collaborated regionally with
Spanish language groups like Sin Fronteras in El Paso and Somos La Llave Del
Futuro in New York, African American groups like Miller Child Development Center in
San Antonio, and educational groups like the University of California and California
State University. CFI is able to provide access for a spectrum of voices on a Sirius
XM channel by acting as a news outlet for issues that concern Native, Mexican,
Pacific Islander, Indian, African American, and other underrepresented voices.
Concerning diverse entertainment:
CFI is proposing some of the most diverse entertainment in commercial media
with California FM. In addition, this entertainment is produced by diverse artists on
independent labels, or by artists who are self-released, who do not receive airplay on
any mass media sources. This will include Spanish-language independently
released DIY music, inner city Hip Hop, women in rock, LGBT artists, youth, and
other foreign-language independent music. The channel will look for ways to
showcase these artists in either features or genre-specific shows.
d. The proposed programming will provide original content. If the content
currently exists in other media, where does it exist?
The proposed content does not exist on any other mass media source in the U.S.
except for select radio shows on freeform stations such as WFMU and other
college/community radio stations with veteran DJs. These radio stations exist in very
few communities, and even when they do, the station’s wattage is so low only fringe
reception is available. California FM is a good sell because it has the capacity to attract
mainstream listenership on Sirius XM, while being directed towards many niche and
underserved audiences to which there is no identical service.
e. The proposed programming is of a type not otherwise available to Sirius
XM subscribers. If the programming will be directed to an audience not
currently served by Sirius XM, please describe your plan to market to that
audience to generate listenership.
CFI has the ability to promote listenership:

CFI has a relationship with roughly a dozen pending FM broadcasters in
California. Through these outlets CFI can cross-promote the availability of
programming on Sirius XM.

California FM will have DJs who participate in record labels, clubs, blogs,
magazines, and other radio stations. The ability to cross-promote exists
through multiple mediums for the DJs themselves.

The terrestrial radio industry is so selective in their playlists that the artists
covered in music magazines rarely get played on domestic radio. The
coolness factor of a new music satellite service will garner publicity from
many rock magazines and blogs, allowing for cross-promotion opportunities.
Common Frequency, Inc.
13

Since California FM will have the support of thousands of new artists, we
will kindly ask the artists to support the channel through a grassroots
movement which will extend through social networking on platforms such as
Facebook, Myspace, and Twitter. The promotion could compel a whole new
roster of subscribers to Sirius XM.
e. The proposed programming will complement and augment existing
programming available on Sirius XM. For example, Sirius XM believes that
Spanish-language programming could potentially satisfy several objectives
of the Qualified Entity set-aside and at the same time complement and
augment existing programming.
The proposed program could complement other programming on Sirius XM. The
format is broad enough to turn listeners on to genres they might never have explored
before. In radio services where channels are divided into sub-genres, listener fatigue on
a format can occur in a matter of weeks or months. Because California FM is a lifestyle
station, the music never gets old because there is a virtually endless library. Such a
format will broaden a listener’s music knowledge, enabling them to explore Sirius XM
sub-genre channels that they would never try before.
There is a “new wave” of artists currently excluded from commercial media. For
example, an anonymous award-winning veteran garage rock DJ we know previously
auditioned for a Sirius underground garage channel and was turned down for being “too
underground”. CFI understands that Sirius XM channels need to have widespread
commercial appeal. However, the DJ was an experienced rock critic, and spins actual
underground garage releases listened to by true garage rock fans, yet was excluded for
being too much on the forefront of new music.
California FM is an example of a music format that currently has a market. Due to
terrestrial radio’s growing reluctance to take chances, innovative music has been largely
excluded since the era of deregulation. Remember, stations like KROQ and 91X took
chances on alien music formats back in the early 80’s; it paid off for those entities
dominating the new rock genres. California FM is the next step in rock n roll, beyond
services like Indie 103 and KEXP who play it safe. Such proposed music would attract
listeners from the college rock, deep tracks, hip hop, garage, and alternative channels,
but provide a completely different experience for the listener to get excited about.
f.
The proposed programming will improve service to historically
underserved audiences. How have you determined that this market is
underserved? What other audio services are targeted to the market?
The proposed market is proven to be underserved by historical and current example:

Freeform stations playing new forms of music used to exist and attract top rated
listenership before station formatting. Early incarnations of freeform stations like
KMET Los Angeles, KSAN San Francisco, WNEW New York, WBCN Boston,
WMMS Cleveland, and KQRS-FM Minneapolis were some of the highest rated
stations before the music industry changed. Today there are no commercial
freeform stations, yet history shows there is a demand for them. Therefore, it
remains an underserved market.
Common Frequency, Inc.
14

There is an untapped market for providing an independent news outlet in the
United States for younger audiences and Gen X’ers. There is no national
commercial outlet that caters directly to the market except for Current TV. In
radio, the Pacifica Network exists, but it is in limited markets, and is not
specifically catered to younger audiences.

There currently are no national services that provide the possibility of the
listeners in the markets contributing content for the network. With California FM,
members of the listening community will be allowed to contact the service with
proposals for new shows, post online feedback, and even contribute to newsgathering. Our site aims to utilize collaboration models similar to wikipedia to
build content rather than hiring many people from the top-down to complete.

Since CFI has ongoing connections with organizations such as Media Alliance,
NFCB, MAGnet, Reclaim the Media, Native Public Media, Free Press, Youth
Radio, Prometheus Radio Project, the University of California system, and
Future of Music Coalition, CFI has access to organizations who can provide
input concerning underserved audiences.
g. The proposing entity will be able to meet its obligations under the Channel
Leasing Agreement and be able to deliver the proposed mix or type of
programming for the duration of the lease term.
Because most of our content will be produced in the same fashion as noncommercial radio stations produce content, California will have a lower overhead of
operation compared to if a commercial operation paid DJs to provide the same content.
Since the content is out there and already being produced, CFI will only need to direct
participants to our central studio, fine-tune shows, and maintain professional quality
output. Programming will be consistent in quality to other programming on Sirius XM.
Thus, delivering consistent programming for the duration of the lease term is not a
problem.
-----------------------------------------------------------------------------------------------------------5. Provide a detailed financial plan for how you intend to provide the proposed
programming over the term of the Channel Leasing Agreement. As part of this
response, include detailed projected financial statements showing your
assumptions supporting projected revenue, expenses, cash flow and balance
sheet items over the term of the Channel Leasing Agreement (in Excel format.)
The detailed projection of operation is included in Attachment A of the submitted
hard copy. Excel file is included in emailed electronic copy.
The proposed budget was contrived by a CFI associate obtaining estimates on costs
in shooting for a low-overhead operation. Since CFI members have previously managed
media organizations, an operation was scaled to location and the most current budget
estimates. The base costs for the operation are projected to be covered by the
terrestrial broadcast operation. Since quotes regarding Sirius XM service fees were not
available with application, advertising revenue and satellite fee was excluded from the
budget. Although, the overall capacity of staff and budget attached includes the means
Common Frequency, Inc.
15
to provide for an advertising revenue plan. In addition, after year one CPB funding will
be pursued and budget will adjust in following years.
-----------------------------------------------------------------------------------------------------------6. If you will be relying on outside financing in connection with your proposal,
please provide firm commitment letters from your lenders or investors. Sirius XM
will not provide funding for applications under this set-aside.
Income will be generated in-house via underwriting, listener drive, and advertising.
The operation has scaled its budget to other existing terrestrial radio facilities.
-----------------------------------------------------------------------------------------------------------7. Provide a timeline showing when you will be prepared to provide
programming. The timeline should include interim dates for key milestones in the
production process as well as the final date on which you will begin providing
programming to Sirius XM.
A timeline is provided in Attachment B.
-----------------------------------------------------------------------------------------------------------8. If the programming you provide will include any copyrighted music or other
materials, please provide evidence that you have all necessary rights from all
relevant entities licensing such rights.
Music proposed to be aired on California FM is licensed in conventional manner
concerning the composition and sound recording. Royalties to ASCAP, BMI, and
SESAC would be due. Sound recording copyright fee would be paid to SoundExchange.
All other pre-produced material will be in-house, or licensed between the content
provider and CFI. No material prescribed within this proposal so far needs copyright
clearance.
-----------------------------------------------------------------------------------------------------------9. Provide evidence that you have obtained all required corporate or
committee approvals, including, if applicable, authorization of your Board of
Directors relating to your proposal.
Attachment C provides clearance from Jeff Shaw, President of the Board of Directors
from CFI regarding approval of this proposal.
-----------------------------------------------------------------------------------------------------------10. Identify any conditions or contingencies, financial or otherwise, that must
be resolved in order to provide the programming and satisfy requirements of the
RFP, the FCC Orders, and the Channel Leasing Agreement.
CFI appears to satisfy the requirements of the RFP, FCC Order, and Channel
Leasing Agreement. However, as stated in Question 3C, if needed, CFI could divest
from ownership of all FM permits if Sirius XM considers the California FM proposal as a
satellite channel contender but has already filled its channel quota for full-power
Common Frequency, Inc.
16
broadcast licensees, and has open channels for non-licensees. 8 At the time this that
application has been submitted, CFI holds no approval of any stations that are licensed
to cover.9 Therefore, CFI is only a permittee, and not a licensee. The awarding of a
non-licensee satellite channel would then be sanctioned under the FCC’s selection
process (pending divestiture) since the contingency is only for licensees.
-----------------------------------------------------------------------------------------------------------11. Provide the name, telephone number and email address of a contact
person who will be available to answer questions regarding your proposal, as well
as the names and telephone numbers of your financial and legal advisors and
external financing sources, as applicable.
CFI Contact
Todd Urick
Program Director
PO Box 4301
Davis, CA 95617
Phone: (530) 848-7831
Fax: (530) 757-2938
todd@commonfrequency.org
Attorney
Alan Korn
1840 Woolsey Street
Berkeley, CA 94703
Phone: (510) 548-7300
Fax: (510) 540-4821
aakorn@igc.org
-----------------------------------------------------------------------------------------------------------12. Identify any other matters you deem important to provide a complete
understanding of your proposal and/or certainty of your ability to perform as
required under the RFP, the FCC Orders, and the Channel Leasing Agreement.
If Sirius XM has any questions regarding the proposal, or any additional information
they need to process this application, the most expedient form of contact is email, stating
the requested materials. If the proposal appeals to Sirius XM, but there are concerns,
CFI is willing to have a dialog with Sirius to minimize the issues.
-----------------------------------------------------------------------------------------------------------13. Indicate whether we may accept your proposal with fewer than the total
number of audio channels that you propose or whether we should consider your
proposal only as a total package.
One channel is requested. We would welcome any input from Sirius XM on what we
could do to make CFI’s request compatible with Sirius XM’s operation.
8
9
Supra. See Note 6
Supra. See Note 7
Common Frequency, Inc.
17
Attachment A: Outlined Budget
CFI BROADCAST PROJ ITERATION 2.2 (12/10) / PROJECTED
CATEGORY NAME
INCOME
Gen Terrestrial Underwriting
Membership/On-Air Fundraiser
NCE Support
On-Air Advertising
Program Support
Sirius Program Income
Grants
Total Support
Fund Development Receipts
Event Donations
Online Donations (tentative)
Donations
Concerts
Total Fund Development Receipts
Receipts
Workshops
Fee for Service
Dub Service
Sales - Media
Sales - Promotional Items
Total Program Receipts
Grants
Total Receipts
CA-FM Merchandising Receipts
Total Real Income
EXPENDITURE ALLOCATIONS
CATEGORY NAME
PERSONNEL EXPENSES
General Manager
Program Director
News Director
Director of Operations/CE
Underwriting/Ad Director
Instructor
Technical Assistant
Production Specialists
Administrative Asst.
Ed Access Interns
TOTAL PERSONNEL EXPENSES
FRINGE BENEFITS
Insurance - Medical
Common Frequency, Inc.
FY (#) Ideal
161821
148835
310656
tba
tba
(excluded)
22731
333387
FY (#) Bare
33000
16000
4000
53000
161821
115360
277181
tba
tba
(excluded)
22731
299912
407
9274
33000
28567
4041
75289
1500
200
2500
100
500
4800
4000
61800
33500
428687
1500
200
2500
100
500
4800
4000
84089
33500
417501
FY (#) Ideal
FY (#) Bare
59000
24000
38000
44000
33353
1355
11890
10495
12240
4000
238333
57000
22386
38000
42000
40000
1355
11890
6000
4000
222631
25000
25000
18
Insurance - Workers' Compensation
Payroll Taxes
Retirement Benefits OPERATIONS EXPENSES
Contractor - Accounting
Contractor - Legal
Contractor - Payroll
Insurance - Combined Perils (SPIP)
Insurance - Crime
Internet Service Fees
Office Equipment - Maintenance
Phone System - Maintenance
Security System
TOTAL PERSONNEL & OPERATIONS OVERHEAD
Sirius XM Programming Fees
TOTAL SIRIUS XM
DIRECT PROGRAM SPECIFIC EXPENSES
Advertising
Outreach Promotions
Automotive Expense
Bank Fees
Board/Staff Relations
Charitable Contributions
Community Relations
Dish Network
Licenses and Fees
Media - onsite use
Media - resale
Newsletter
Phone
Office Supplies
Photocopying
Postage
Printing
Production Equipment - Maintenance
Production Supplies
Publications Staff Development
Subscriptions/Dues
Marketing Materials
Eng Repair and Maintenance
Utilities
Event Fundraisers
Contractor - Legal
TOTAL DIRECT EXPENSES
CATEGORY NAME
BUILDING EXPENSES
Common Frequency, Inc.
2469
20000
4500
20000
2100
500
2625
4115
263
1200
500
630
1145
60547
unknown
(excluded)
2100
500
2625
4500
500
1600
500
630
1207
63662
unknown
(excluded)
1000
1500
1000
1000
1549
29
1500
450
2308
1000
1000
1500
1000
1000
1549
29
1500
450
2308
1000
-
-
2000
1500
500
1200
500
3000
500
2000
1500
500
1200
500
3000
500
-
1000
1000
1200
1200
1500
1500
40151
40152
6000
6000
3500
3500
500
500
74387
74388
FY (#) Ideal FY (#) Bare
19
Mortgage Payment
Building - Property Taxes
Insurance - General Business
Utilities
Contractor - Janitorial
Supplies - Building
Building - Annual Maintenance and Repairs
Contractor - Gardening
Contractor - Property Management
TOTAL BUILDING EXPENSES
TOTAL REAL EXPENSES
Balance (1)
Common Frequency, Inc.
25500
6200
2900
3000
5000
500
8000
1020
3300
55420
428687
0
25500
6200
4300
3000
5000
500
8000
1020
3300
56820
417501
0
20
Attachment B: Timeline
Approximate duration for Sirius-XM program production would be one year. CFI
would like to provide a stable platform for 24-hour operation. Programming would be
projected to go live for beta testing a couple months before launch to provide time to
remedy technical and scheduling quarks.
TIMELINE
Jan 20
In progress
Programming Committee formed
Job Descriptions Finalized
Digital library procurement and legal/usage issues addressed
Tech Committee Review of playlist software.
Feb 15
Inquiry
Programming Committee:
Establish minimum host experience criteria, submission criteria,
and quality control guidelines, due Mar 10
Establish program format guidelines and balance for
general/diverse specialty shows due Mar 10
March 10
Post/promote openings for new hosts
Post/promotion of key positions
Production of “air sound” reels as demonstration of CA-FM air sound.
Apr 15
Programming Model Development
Researched possibilities hosts via programming listening.
Researched public radio scheduling models.
May 5
Technical consideration of automation and assist platforms
Coordination with facilities build committee exacted.
Library coordinator to report on library
Committee Review program submissions
Tech Committee recommends playlist protocol
June 10
Declare key positions
Staff-Committee Training and responsibility hand-off.
Produce promo package manufacture for sponsors
Connect with indie record servicing
July 15
Finalize assist and automation
Report on playlist, traffic, and other log requirements/Research plan
Aug 10
Coordinated and trained air staff
Constructed program schedule.
Produce demo shows and critique for changes.
Test News/music content mixtures
First inquiry for sponsors
Sept 15
Provide preliminary programming runs
Common Frequency, Inc.
21
Obtain focused feedback, make changes
Obtain final news/news-participation formula
Provide report to CFI board on “Total Package”; obtain sign-off
Provide testing of all computer-based systems.
Oct 30
Run preliminary publicity campaign
Second report on sponsor goals.
Finalize record-keeping, scheduling, traffic plan.
Sponsor goal #2
Nov 25
Preliminary continuous test run on internet.
Feedback and air sound tweaks.
Work on correcting problems
Critique 2
Jan 10 2012
Sponsor goals met
Go live.
Common Frequency, Inc.
22
Attachment C: Approval
Attachment D “Agreement” follows on next page.
Common Frequency, Inc.
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Common Frequency, Inc.
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