Groups and individuals continue to weigh in on whether the Federal Communications Commission should put a strict limit on the number of Non-Commercial Educational (NCE) radio station applications that any non-profit can file for. Most commenters support the idea; but some Christian outfits want to relax the rule.

In early April, the FCC's Media Bureau announced an application window to begin on Friday, October 12th—that's the day that the Commission will accept formal requests from non-profits for full power NCE radio licenses. The window closes on Friday, October 19th.

"If you do not apply now, there is no telling when there will be another chance," warns a primer published by the National Federation of Community Broadcasters. Many parties are rushing to prepare their license requests.

But they're also participating in a proceeding on whether the FCC should cap the number of applications any group can file. In the proceeding announcement, the FCC tentatively suggested that no entity should be allowed to file more than ten applications.

"If it is determined that any party to an application has an attributable interest in more than ten applications," the Notice proposes, "the Bureau will retain the ten applications that were filed first—based on application file number—and dismiss all other applications."

The policy has the strong support of a wide variety of non-profit broadcasting and advocacy groups.

"Without a numerical filing limit there is the possibility of a single applicant filing dozens to even hundreds of stations across the U.S.," argue three advocates who commented with the FCC in late July. "This goes against the original intent of a reserved educational channel - one set outside the competitive marketplace, within the grasp of local or regional educational institutions and non-profits."

The statement, submitted by Reclaim the Media, Common Frequency, and Pacifica Radio, also asks the FCC for more public disclosure of the application rules, especially since many non-profit boards meet every other month, and need time for "digestion of the knowledge, and proper adherence to the rules among all parties."

A similar filing comes from Capital Community Television of Salem, Oregon. Capital supports the 10 application limit, and also calls for moving the filing window to January 2008 or later and extending it for ninety days, providing "ample time for the public to participate and to take critical decisions to [their] Boards and other decision makers."

Other groups have gone even further than the FCC. Native Public Media, a non-profit that represents Native American broadcasters, wants the agency to modify its point system for evaluating NCE applications, giving one additional point to applications filed by federally recognized Native American tribes.

"The establishment of such a point [for federally recognized tribes] would be a step towards acknowledging tribal sovereignty," NPM concludes, "and would promote longstanding Commission policy goals in the provision of broadcast service, including competition, localism, and diversity."

But Christian groups want the FCC to relax the application cap. Here are summaries of some of their filings:

• Network of Glory describes itself as a South Carolina based non-profit ministry that "aims to broadcast music and information to the African-American community." Its August 15th filing claims that it has completed 37 applications for the NCE window.

  "With a filing cap of ten (10), our nonprofit organization stands to lose thousands of dollars paid in engineering and legal costs to prepare for the upcoming NCE window," the group claims.

  Network of Glory proposes that the cap be lifted to 50 applications, as long as at 30 are for licenses in rural areas. Their proposal also calls for the FCC to impose a filing fee on each application; at present there is none.

• Similarly, a filing from "Victor Broadcasting Inc." complains that the petitioner has "conscientiously put together many more applications than 10 with no intent towards 'speculation' and selling of construction permits."

  "Over these last 7 years relationships have been established with local community groups who have requested we bring a station to their community," the comment continues, and argues for a cap of 40 applications instead.

  It is unclear who or what exactly "Victory Broadcasting" is, but the filer lists the same address as Sterling Communications, a professional radio station application company that works with Christian groups.

  "A limited number of frequencies are available for new radio stations," Sterling's mission statement begins. "Every channel we can capture for Christ will have a far reaching ministry to people who never go to church."

• Western Inspirational Broadcasters Incorporated (WIBI) of Carson City, Nevada runs "Pilgrim Radio," and has also called for a cap of 40 applications. According to its Web site, Pilgrim Radio broadcasts to over 100 areas in Nevada, California, Wyoming, and Nevada.

  " . . . we occupy until he comes," Pilgrim's mission statement declares and claims that without a more relaxed cap, some of its FM translators could be displaced by full-service applications.

  " . . . prior to the Commission's proposed 'cap' on filings, WIBI invested in expensive engineering software and has expended thousands of dollars in labor to execute engineering studies and application preparation," the group writes. "Should the Commission hold to the limit of ten (10) applications per entity, many thousands of dollars already entrusted to us by the listening Public will have been wasted."