The “Petition Against God” from Lorenzo Milam and Jeremy Lansman was filed in 1974 with the FCC as a protest against duopoly and the bland, monolithic radio of the day. It drew a record 4 million record-number letters to the FCC when preachers of fundamentalist churches around the U.S. encouraged their parishioners to oppose the petition.
Regarding the text of the petition:
This petition before the FCC was an attempt to make radio stations on the noncommercial part of the band more responsive to the community.
Lorenzo Milam (“author of Sex and Broadcasting”) helped launch more than a dozen community radio stations around the country in the United States including KNDA (which is now KDHX) in St. Louis.
The petition attacks what it refers to as banal, boring, and moneymaking enterprises. He takes aim at university stations (which were pretty bad at that time) and religious stations which he considered cash registers attached to radio towers.
The petition so incensed fundamentalist preachers that they named it “The Petition Against God” and went to their pulpits to exhort their flocks to send letters of complaint to the FCC. This generated the most mail sent to a government agency for quite some time — over 4 million letters.
There is a lot of humor in the petition but a serious issue is addressed, also — who controls the media. The responses to the FCC were also fun to read, and it is outlined in the book called “The Petition Against God” written by a fictitious preacher named “Pastor AW Allworthy” if anyone is interested in finding it.
By the way, the Nazarene Theological Seminary radio station Milam refers to in the petition was here in Kansas City and was the former KTSR.
KKFI knocked KTSR off the air, (the only time a community radio station knocked a religious station off the air) a very rare occurrence. But that’s another story for another day. The story of this effort by Mid-Coast radio may be found in another post.
THE PETITION FILED AGAINST DUOPOLY, CONFLICT OF INTEREST OF
STATE-OWNED BROADCASTING FACILITIES, AND ABUSE OF THE EDU-
CATIONAL PORTION OF THE FM RADIO BAND BY “RELIGIOUS” RADIO
BROADCASTERS. ALSO KNOWN AS “THE PETITION AGAINST GOD”
BEFORE THE FEDERAL COMMUNICATIONS COMMISSION WASHINGTON, D.C.
In the Matter of )
)
Revision of Rules Permitting Multiple )
Ownership of Non-commercial Educational )
Radio and Television Stations in )
Single Markets; and )
)
Request for “Freeze on all Applications ) RM-2493
by Government Owned and Controlled Groups )
for Reserved Educational FM and TV Channels; and )
)
Request for “Freeze” on all Applications )
by Religious “Bible,” “Christian,” and )
other Sectarian Schools, Colleges, and )
Institutes for Reserved Educational FM )
and TV Channels )
)
1 December, 1974 )
PETITION FOR RULEMAKING
This Petition is filed by Jeremy D. Lansman and LorenzoW. Milam, who have individually and jointly operated,
financed, and encouraged many independent non-commercial,
non-institutional, non-sectarian radio stations in the United
States over the past thirteen years. In this Petition, they
are acting independently, and not as a part of any group or
corporation, and envision no pecuniary gain to themselves if
the suggestions herein are enacted by the Commission.
1) Petitioners ask the Federal Communications Commission
delete paragraphs 73.240(b) and 73.636(b) of the Commission
Rules and Regulations which permit non-commercial educational
licensees exemption from duopoly regulations. Under the
existing rules, there is no limit to the number of radio or
television stations which can be held by a non-profit
corporation, school, local or state political entity.
2) There are problems enough with government-controlled or
financed broadcasting outlets being permitted in each market-
but when these institutions control more than one outlet,
stultification of intelligent criticism and free programming
becomes irresistible. This is especially true in the smaller
markets, where the present rules would not prohibit one hide-
bound government entity from creating and holding a virtual
monopoly on the marketplace of ideas.
3) Non-commerical radio and television stations are expected
to have more community and public service type programming,
even though some of them avoid this heavy responsibility.
Contrary to popular belief, it is possible for the
programming on non-commercial stations “competing” in the
same market to be improved by the variety available through
different institutions. Permitting a single government or
school body to control more than one outlet in one city or
town can do nothing but smother such healthy growth and
creativity.
4) Petitioners have found that many schools, colleges, and
quasi-governmental boards will program their radio and
television stations as if controversy were dangerous and
repugnant. As well it might be: financing of these stations
comes from school boards and legislative bodies that hold the
spirit of free inquiry to be anathema. They obviously fear
that robust, wide-open programming might destroy governmental
income sources — proving that monetary stability is closer
to their institutional hearts than a diverse and lovely radio
and television.
5) It is bad enough that these fearful groups should be
licensees in the first place; it is trebly bad that there
should be no restriction on the number of outlets permitted
in s single market. And, given the untrammeled ambitions of
many school and college administrators to show size if not
diversity, we would suspect that applications for such
monopoly outlets will increase in the future. Because one is
“non-commercial” or “educational,” it does not follow that
one doesn’t have the ambition to lock out diversity. Such
monopoly situations will and shall continue to eliminate non-
institutional community groups (usually more racially,
socially, and economically integrated) from having their own
voice in these communities.
6) There is no possible way that monopoly ownership can be
healthy, necessary, or virtuous. Our experience with school
board and college “communications” departments has shown that
they can be just as greedily opposed to competition as an IBM
or AT&T. Some of our community groups have been forced to
rely on “Petitions to Deny” to get schools and government
broadcasters to share time on their unused broadcast day, or
even to move to another suitable frequency so that new
stations can be applied for.
7) We have listed in the appendix herein some of the present
monopoly situations existing in the country today. We think
that as a part of this freeze requested on applications, the
FCC should make inquiry to see if communities like Rolla,
Missouri; Minneapolis, Minnesota; and Columbia, Missouri have
richer and more diverse programming, or the opposite with
their monopoly government broadcasting facilities.
8) One should not have to use “Petitions to Deny” against
educators to permit others to have access to frequencies, to
educate in the wildest sense. Educational broadcasters
should not have to draw their Ivory Towers about themselves
as some sort of sacred cloak which permits them to choke off
efforts for new, diverse, more broadly-based groups to have
access to radio and television permits. Yet this is the
trend — and we feel that it will continue, if not stopped at
this point.
9) Integral to the American system and philosophy or radio
and television broadcast regulation is the thought that local
independent broadcasters can better foster discussion of
local issues than one large, federal-sponsored agency (like
the BBC in England or the CBC in Canada). But the FCC has at
the same time freely licensed broadcast and telecasting
channels to local tax-supported governmental bodies. Without
question, these government stations do not offer time nor do
they encourage controversial programming about local
political issues; in some cases, these outlets have positive
prohibitions on discussion of local issues of far-reaching
public importance.
10) This subversion of American broadcasting policy and
spirit should be the subject of a full Commission inquiry.
There should be no reason, for instance, that local
educational broadcast outlets could not be licensed to local
independent boards (like the BBC) with a guaranteed 20-year
funding. When local school board stations have to beg money
annually from local or state legislatures –freedom to
program creatively and controversially goes out the window.
Even some of the great independently commission outlets
(WGBH, KQED, WETA) are subject to unconscionable pressures at
annual finance time. And we would guess that the Alabama
Educational Television Commission Case would never have
transpired if the AETC had been free of the annual funding
needs — of going before a backwards legislative body for
necessary operating monies.
11) Every state has radio and television stations licensed to
a government-school groups. The daily toll on free speech
and free controversial programming is apparent. However,
rather than remove these groups as licensees, we would like
the Commission to make inquiry into the practicability or
requiring each school or government licensee to set up an
independent board of control with guarantees minimum
financing for twenty years. Even the most wimpish of
government school administrations might find some good and
controversial programming out there in the woods with twenty
years of freedom. Or to put it in another way: who would
ever have guessed that Earl Warren would become the scourge
of political conservatives when was appointed to the Supreme
Court twenty years ago.
12) Freedom of Religion should not presume a sacred duty to
program only the most bland and inoffensive; and to enrich
the licensee excessively by promulgating a comfortable, blond
Aryan view of the Godhead. Rather — Freedom of Religion
should involve a positive duty to investigate the challenges
of men and their gods, to utilize the arts and creativity to
define this relationship, this dialogue between the men and
the divine. Until the religious broadcasters of America
learn this simple truth, we must protect ourselves from the
wanton growth of senseless, inhumane apostolicism which
clutters so much American radio and television.
13 Religious broadcasters have shown a remarkable cancer-
like growth into the “educational” portions of the FM and TV
bands. They control endless monies from “free-will”
contributions, thrive on mindless banal programming aimed at
some spiritless, oleaginous God, and show the same spirit as
McDonalds Hamburger Co. in their efforts to dominate American
radio and television.
14) It is dreadful enough that Oral Roberts, Family Radio,
and The Church of the Foursquare Gospel invade the
“commercial” band — but, not satisfied with that, we have
such doubtful “educators” as Moody Bible Institute, Miami
Christian University, Nazarene Theological Seminary, Southern
Missionary College, Pacific Union College, Western Bible
Institute, among others, rushing to crowd the narrow FM band
set aside for non-commercial, educational stations. We have
no doubt that their attack on reserved VHF and UHF television
bands will start soon enough.
15) Moody Bible Institute has started applying for 100
kilowatt FM stations in the reserved part of the band outside
of its home territory of Chicago. With each new grant, the
radio band will be that much poorer in diversity, interest,
in-depth public affairs, and true education of the whole man.
16) This is not a blanket condemnation of all “religious”
broadcasters. KFUO in St. Louis, WRVE in New York, and the
late KXKX in San Francisco were and are honest, inquiring
stations run by religious groups. But these are the
exceptions, not the rule. Most religious broadcasters seem
to loathe the vitality and robust programming which should be
their obligation. They regularly and systematically ignore
the Fairness Doctrine, sabotage wide-open programming, and
even in their musical programming, deny the fullest flowering
of Western Christian music (Bach, Handel, Telemann, medieval
and renaissance church music) and by all means, they ignore
completely the musics of other religions (African religious
songs, Japanese Buddhist Temple music, Indian Hymns to Lord
Vishnu). Their programming is in no way “educational” rather
it is narrow, prejudiced, one-sided, blind and stultifying.
17) Therefore we are asking in this petition that a “freeze”
be imposed, immediately on all further applications for
reserved educational FM and TV channels — not only for state
and local governmental bodies — but, as well, by any and all
“Christian,” “Bible,” “Religious,” and other local sectarian
schools, colleges, and institutes.
18) Concurrent with this freeze, we would like the full
Commission to investigate those sectarian institutions which
are presently licensed for “educational” channels to discover
whether these licensees are actually living up to the
Fairness Doctrine in presentation of matters of controversial
importance; and whether these groups are presenting
educational, truly educational programming on their outlets;
or whether they are relying solely on music and talk which is
tainted with the ennui so characteristic of American
Fundamentalist Religion.
19) It is a continuing paradox to us that religious radio
should be so boorish. We — as petitioners — hold a great
affection for the potential of American radio. FM, between
1955 and 1965, when it was free of present financial
pressures, was a great and experimental medium. Now with the
vulgarization of commercial FM, our hopes should rest on the
reserved part of the radio band.
20) The fears of governmentally controlled, tax-supported
radio outlets might be understandable. Controversy creates
awareness and fear; fear threatens jobs. Fear could explain
why WSIE in Edwardsville, Illinois runs an automated station,
or why WRAS in Atlanta does top-40. Fear might explain why
KSLH stays solely with in-school programming, complete with
hour-long silences for tests. Porridge is always a safe
medicine for fear.
21) But religious broadcasters should be free of such fears.
After all, with their excessive donations* which come from a
large body of listeners, and their exclusive reliance on The
Great Upstairs, they should be willing to involve themselves
in any and all public controversy, even debate
of the existence of God.
- It is common knowledge in the industry that Family Radio
stations (which broadcast on the “Commercial” part of the
band with programming indistinguishable from that
describe above) buy new stations by begging “goodwill”
offering on their existing stations — and that when they
move into a new area, usually a suburb of a large
population area — they pay off the cost of the new
station IN CASH within six months of purchase. The low
cost and high return of “religious” stations is legion
within the industry. Mendicancy pays very well in this
business.
22) We are convinced that the problem is one of SCOPE and
VISION. Religions, traditioanll — over the centuries —
have been the repository of history, ethics, facts, apocryha,
and knowledge. Each branch of traditional religions
(Catholic, Jewish, Buddhist, Protestant) has an order,
branch, or sect which holds the core of knowledge. The
Jesuits, for instance, in their pursuit of their particular
devine, are willing to debate and discuss even the most anti-
religions tenet. Radio Vatican is no slouch in the
transmission of ideas, as well as ideals.
23) It seems to us that the particularly American
institution — “back to the Bible,” fundamentalism, The
Gospel — is ultimately vacuous when it comes to knowledge,
history, the spirit of learning because of its dependance on
only the Bible, and its exclusion of the ideas, commentaries,
and thoughts of man through history, through time. This may
explain its peculiar hold on the American poor and country
folk: it demands no other resource than Belief with Bible in
hand.
24) Which is all well and good if we were addressing
ourselves to man’s freedom to worship the god or gods he may
please. The interface — we would say the destructive
interface — is when fundamentalist churches and church
schools grab onto the rarest of spectrum space to purvey
their blank and questionless philosophy over the hapless
listener, and PRETEND THAT IS IS EDUCATIONAL.
25) We would be delighted to provide for the Commission
random tapes made from random broadcast days over stations
such as WMBI, KAMG, WDYN, KWBI to prove conclusively that
education and enlightenment are anathema to these and
similar stations. A day of listening to the end produce of
countless Back to the Bible programs may be a powerful
soporific — but it might be the only way to convince the
full Commission that education — in the truest, fullest,
Renaissance sense — if furthest from their minds.
26) We are concerned because educational FM is just
beginning to grow into the areas that need it the most —
rural and country areas 200 and 500 miles from major
population centers. How fine it would be if these areas
could count on an honest community radio, personal, with full
open-access and diversity of voices. What a pity if this
opportunity were squandered by fundamentalist religious
“schools” who would block off frequencies, and continue to
show scorn of open access and minority employment and
programming much as they have in the past. The case of KGDN
(King’s Garden, Washington) was not isolated nor special;
religious broadcasters have and will continue to examine
would-be employees as to their faith — they have just become
more discreet.
27) Over the past decade, Petitioners have shown dozens of
community minority groups how to apply for FCC permission to
establish open-access, free-forum radio stations that serve
the Whole Man — with curiosity, humor, and delight of
knowledge. It saddens us to see a rampant growth and
squeezing out of our (necessarily) poorer groups by large
“educational” tax-supported, governmental controlled
institutions, and a further deterioration of the band by
religious groups locked into a bleak, self-centered, and
miasmic view of man’s capability for knowledge.
28) It is for these reasons that we file the instant
petition with the FCC, and hope that that body will instantly
try to ameliorate these wrongs through the following actions:
A. Delete paragraphs 73.240(b) and 73.636(b) of the
rules and regulations;
B. Add duopoly and concentration of control regulations to
the non-commercial educational rules for radio and
television; such rules to be similar in language to
73.240(a);
C. Freeze granting of all construction permits for
educational radio and television stations to applicants owned
or controlled by sectarian schools, colleges, or other
institutions, and to groups owned, controlled, or directly
funded by state or local governments or other elective
political bodies including school boards;
D. Institute an inquiry into the restrictions on free
speech regularly practice by the above mentioned groups on
existing “educational” radio and television stations; and
E. On the basis of that inquiry, institute some
divestiture process (for religious broadcasters and duopoly
violative government groups) and requirements for financial
independence on a long term basis for all remaining tax-
supported licensees.
Respectfully Submitted
Jeremy D. Lansman
Lorenzo W. Milam
1 December 1974