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I'm in awe of the many Kos-activists who are leading the charge against Rush Limbaugh's sponsors. That's a great way to hit Rush where it hurts, and it's great to see the movement already bearing some fruit.

In this diary, I'm going to share some tips from the inside about another line of attack: some useful techniques to put pressure on your local Limbaugh affiliate to consider whether to keep carrying the show, and also why some of the well-meaning suggested lines of protest probably aren't worth the effort.

Ahoy, mateys...let's walk the Mighty Orange Squiggle to action:

1. Your local station's advertisers

This first line of attack is probably the most likely to be effective in the short run. Some background, first: local stations that carry Rush's show effectively pay for it in two ways. They pay cash to Premiere Radio Networks, the arm of Clear Channel that syndicates Limbaugh. They pay a lot of cash, in fact, to Premiere. At nearly any station that carries Rush, he's the most expensive syndicated show they carry; in fact, most other syndicated shows (cough*Mark Levin*cough*Michael Savage*cough) are so desperate to get stations to carry them that they're offered on "100% barter," so stations don't shell out any cash. They get the show for free and give up airtime for national ads that the syndicator sells during the show.

But Rush is a different story. He's still considered the tentpole for most talk stations, and Premiere believes they'll pay dearly for the privilege, because having Rush on the air brings listeners who'll stick around for the rest of the station's local and syndicated shows, and because stations can charge premium prices for the few local ad slots that are available during Rush. Well, at least they could charge premium prices...but as Rush's ratings have leveled off and his demographics have gotten older, his show is becoming a harder sell.

That's where we can come in as activists: we can make it an even harder sell. Yes, this means listening to Rush, at least for a day or two, but I'll make it easier for you. Here is a link to the program clock for Rush's show. You only need to listen during the minutes when local stations can sell ads. They're marked in green - from 18 to 20 minutes past the hour, from 30 to 34 minutes past the hour, from 45 to 46 minutes past the hour, from 54 to 56 minutes past the hour and from 58 minutes before the hour to 6 minutes past the hour (most of that one will be network or local news.)

UPDATE: I should note here that you're likely to also hear national advertisers in these time slots. These are either "agency buys," in which a national ad agency buys time on local stations around the country for national advertisers, or they're "network spots" that the station runs during local time in exchange for getting network newscasts or other syndicated programming. I think this is a lot of what's causing the confusion among national advertisers who swear they don't buy time on Rush - they don't actually "buy time on Rush," but they buy time on a network that's carried by a local Rush station, or they make an agency buy that happens to include spots during the Rush show. The advertiser really may have no way of knowing its ads are running during the show...but you can tell them, and they can ask the agency or network to keep their spots out of Rush.

Listen for a day or two during those times. Make a list of the local advertisers you hear there. Look up their contact information and go have a chat with them about what they're supporting. They may tell you "we're not specifically buying Rush," and they probably believe that. Most Limbaugh affiliates are part of larger station clusters that also include several FM music stations, and it's not uncommon for "the AM station" to be sold to advertisers as part of a bigger package. This is OK. You can still ask them to ask the station to remove their ads from the Rush show, or even entirely from the talk station that's carrying Rush...and you can make noise locally if they don't. No business wants people demonstrating outside their store because of where they choose to spend their advertising dollars...

2. Your local station's management

...and no local station manager wants his advertising clients to be getting pressure from their customers because of what's airing on his station.

Back in the days when stations were mostly owned locally, this was a very effective means of ensuring that programming stayed sane. The guy who owned the station (and it was almost always "the guy") went to church on Sunday with the guys who owned the businesses that bought advertising, and then he went and played golf with them. Having someone like Rush on the air was largely unthinkable, simply because it would have been too embarrassing for the local owner in those situations.

Today, of course, most of the stations that run Rush aren't owned locally. The vast majority of Rush affiliates are owned by Clear Channel, just like Rush's syndicator, Premiere. You're probably not going to get very far with the local management at those stations. Even if they can make a case to corporate that the local bottom line is being harmed by running Rush, it's still in corporate's best interest (at least for now) to keep Rush on the air. Clear Channel even loses money in some markets by moving Rush from a competitor to a smaller Clear Channel-owned signal. In theory, they make it back by having a larger national footprint to advertisers.

Maybe you're lucky, though. Maybe your local Rush affiliate isn't owned by Clear Channel. It might be owned by one of the other big national broadcast companies like Cumulus (WABC in New York, WLS in Chicago, WJR in Detroit) or Cox (WDBO Orlando, WOKV Jacksonville) or even CBS (WPHT Philadelphia).

How do you find out? Use a site called, which accesses FCC records. Punch in the call letters, click on the callsign, and then scroll down to the box marked "Licensee Information." If it says "CC Licenses" or "AMFM" or "Capstar," with an address in Tulsa or San Antonio, you're looking at Clear Channel. If it says "Radio License Holdings" or "Citadel" with an address in Las Vegas or Atlanta, it's really Cumulus. But if it's a local address, you're in luck. Your station is a prime target to be de-Rushed.

Write that letter to the general manager, cc: it to the program director, and be sure to ask in the letter that a copy be inserted in the station's public file. Indicate, in these words, that you don't think that continued carriage of the Rush Limbaugh Show "serves the public interest, convenience or necessity." This has no particular weight with the FCC, but it will make a local station manager nervous anyway, so do it. Local station managers, especially at locally-owned stations, don't like anything that makes them nervous. They want to cash their checks and go play golf, and they don't want to deal with angry listeners...and that's why you're going to make their lives a little less pleasant on the way to the golf course.

(If your station is corporate-owned, be sure to write to the corporate HQ, too.)

So...after you write that letter, go to the station. Bring some friends. If you're up for some political theater, plan a little protest outside the station. Make some signs. Let competing media (local TV, newspapers) know about it. Get all over social media with it...including the other music stations that are probably co-owned with your target Rush affiliate.

And once you're at the station, go into the lobby and very politely ask to see the public file. This is mostly for theater - most of what you'll see in that file is as dull as dirt, and there's very little in there that could actually cost a station a license renewal these days. (You won't, for instance, find a list of all the station's advertisers, or of how much it pays for shows like Rush.) But the station is required to let you see it during regular office hours without an appointment or prior notice, and you're not required to tell them why you want to see it. If they ask what part of the file you want to see, ask for the "issues/programs list." It will be boring, too, but it will at least give you an interesting look at what the station thinks it's doing to serve its community, or at least to persuade the FCC it's serving its community. If the issues/program list isn't there, that can be expensive for the station at renewal time, so make a note if it's missing.

Most important: it makes station managers very, very nervous when people show up unannounced to see the file. Again, be incredibly polite and friendly. You're not a crazy person. You just...want to look at the file, especially if it's close to renewal time.

This will get the station manager (or at least someone in power) out of their office to talk to you, much more quickly than you'd ever get in by trying to make an appointment. Talk to that person, politely. They probably don't listen to Rush all the time - they're busy running multiple stations, after all. Make sure you bring some examples of what he's been saying, so that person knows what it is we're upset about. Tell them you've been contacting their local advertisers...and that you really, really don't want to feel compelled to...

3. File against license renewal

Understand: there's really nothing at all you can do as an ordinary private citizen to keep a station's license from actually being renewed. Reagan-era deregulation and its Clinton-era followup pretty much eliminated any of the power the FCC once had to control a station's content. (And as a First Amendment near-absolutist, I think that's OK, but that's a different diary.)

Filing a letter with the FCC objecting to a station's renewal can hold up the process, though. It creates a legal headache for the station's ownership, and they don't want that.

Fortunately for us, we're right in the midst of the three-year period in which all radio station licenses are up for their eight-year renewals. The dates are staggered by state. Here's the list.

We want to target the stations that are next up: stations licensed to Indiana, Kentucky and Tennessee must file for renewal by April 2. Michigan and Ohio come up in June, followed by Illinois and Wisconsin, then Iowa and Missouri later in the year. If you're in one of those states, your local Rush affiliate really, really, really doesn't want you to have a reason to contact the FCC and suggest that the decision to carry the Rush show means the licensee "lacks the proper character" to hold a valuable FCC broadcast license.

And, lucky you, the FCC tells you exactly how to go about filing a petition to deny or an "informal objection." You want to file a petition to deny, and if you're not a communications lawyer, you probably won't do it in exactly the form the FCC specifies. That's OK. The FCC will still look at your petition, they'll probably treat it as an informal objection, and eventually they'll toss it and renew the station's license anyway.

In the meantime, though, you'll have made your point, which is this: carrying Rush Limbaugh is a liability to any station owner that isn't Clear Channel. Station owners don't like liabilities. They want no controversy at all. They just want to make money, and the smart ones are already figuring out that Rush doesn't make much money for them, at least not the way he used to.

We've got a beautiful opportunity right here, right now, to help them figure that out a little sooner.

Let's go get 'em...

Questions about how to move forward? I'll be around in comments for a while...

UPDATE: Kossack Shuksan Tahoma points out downthread that station remotes are also a great target for bad publicity:

A car dealer is having a promo or a new appliance store is opening or a tired old retailer is looking for some new mojo.

We all the know the schtick:

    WFUK will be broadcasting live from the Very Upstanding Ford/Chevy Dealership Saturday March 3.  Come down for some free hotdogs and cokes and listen to us live.  Talk to the family friendly staff at the Upstanding Ford/Chevy Dealership and get your best deal on a new 2012 Ford/Chevy.

I don't think the upstanding Ford/Chevy dealership will be too happy when they are the target of guilt-by-association protests.

UPDATE #2: Here is the list of all Limbaugh's affiliates. If I can find some time over the weekend (ha!), I'll see about creating an annotated version showing who owns what. That would be useful, wouldn't it?
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