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“The administration of the University of California, Davis is facing backlash after deciding to move its freeform radio station KDVS to a space that is roughly a third of the size of its current headquarters. 

After the downsizing announcement was made in early April, KDVS alumni and the local community quickly formed the organization Save KDVS in an effort to preserve the station’s current operations. 

The plan would require KDVS to give up a live performance room, second production room and record-listening rooms, according to GM Noel Fernandez. Other areas will be condensed to fit in the space, including the music library and staff office. The move is scheduled for the upcoming school year.”

Read more at current.org

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Differences in Estimates of Space Allocation



KDVS current student staff asserts that 100% of the KDVS Library can fit within the Gunrock location while maintaining a full-studio, core staff offices, and an area where volunteer staff can use as a lounge/workspace. This despite having initially publicly stated that the plan for the library would be offsite storage, and the location of said storage having not been identified publicly or privately. Save KDVS has made two independent estimates of the number of items in the KDVS Library and are confident that our estimates are correct.

“At this time our consultants and engineers have said that according to ADA compliance and the utilization of high density shelving, the full and complete stacks will be included in the Gunrock Gaming space without exception. We have received concrete confirmation that 100% of the stacks will fit within a 550 linear feet limit inside of the new space, leaving room for things like a lounge and listening areas.” – Lucas

Estimates of the linear footage of the KDVS Library done in 2014 (over 3200 linear feet) and subsequently are in dramatic contrast with the linear footage estimated by the current staff.

Our recent estimate of the size of the ‘stacks’ is 4043 linear feet. This breaks down in the following calculations:

LPs and singles in Library 1 = 1374 Linear feet

CDs in Library 2 = 1558 LF

LPs and CDs in Library 3  = 699 LF

Currents room (live studio shelves) = 412 linear feet

Total = 4043 linear feet.

There is no high-density storage system that could possibly accommodate the KDVS record library into the area they are describing. Beyond that, we question the viability of high-density storage in an active and functioning radio station. And there is a serious consideration of not having separate and discrete spaces for an on-air broadcast studio, which needs to be silent and clean, library areas which need to be secure, and staff areas which should be accessible and foster interaction. Bottom line, we don’t believe their estimates are serious and we don’t believe their proposal is viable.

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Radio Station Complex Relocation Should Not Take Place During FCC Relicensing


https://publicfiles.fcc.gov/api/service/fm/authorization/1559458.pdf

License Renewal August 2021

KDVS has their FCC License coming up for Renewal on August 2nd, 2021. The application and all the materials must be up to standard by that date and the Communications Lawyer at UCOP submits it with all other supporting documentation the to the Federal Communications Commission (FCC) website. The approval decision, unless issues arise, will be issued by the FCC on December 2, 2021.

“Before we can renew a stations license, we must first determine whether, during the preceding license term, the licensee has served the public interest, has not committed any serious violations of the Communications Act or the FCCs rules, and has not committed other violations which, taken together, would constitute a pattern of abuse. To assist us in this evaluative process, a station licensee must file a renewal application (FCC Form 303-S).” The Public and Broadcasting (FCC 2021)

The license renewal process is time consuming for staff, requiring that all Departments assure that the on-line Public File is up-to-date

Community Ascertainment – Public Input on Renewal

In addition, during relicensing a period of Community Ascertainment and commenting occurs. The FCC hold that being given a broadcast license is a privilege that is earned by the station serving the public interest of those within the broadcast coverage area. Thus the licensees (the Regents) and management of KDVS are stewards of the public trust. The station must begin a process of soliciting comments from the public regarding the service the station has performed within the Community of service, their listenership and others in the public. These mandatory recorded announcements must be broadcast on a specific schedule established by the FCC – beginning in August and ending in late October. Any interruption of broadcasting that would interfere with these notifications being aired complicates things further.

Being enmeshed in a controversial move that may impact the service provided to that community is not very astute during renewal periods. It is why commercial stations rarely announce format changes in the year that they are renewing their license. They get a tsunami of negative letters to the FCC which are then referred back to be placed in the station file. Some may even submit Formal Objections to Deny or informal opposition to renewal.

Some correspondents may have information regarding the station performance that the FCC may believe warrants deeper investigation. This can extend the renewal process over several years.

The University could do much to reduce these negative comments about the licensee by suspending or cancelling the Gunrock decision and clarifying that they will now consider several other larger potential sites that could maintain the KDVS music library. They could foster goodwill by meeting with various stakeholders about the suitability of those locations in preserving the diversity of KDVS Programming for the Community of License. These announcements must be very public. To properly acquire input this process would take months. The Campus Media Board and other shared governance groups will be unlikely to meet until fall semester.

Studio Migration and “Keeping the Lights On” Disrupts Licensing

Any change in studio location, even temporary, requires letters of notification and approval from the FCC. All functionality of the station must be maintained from site-to-site: the Emergency Announcement System, the Studio Transmitter Link. Access to the public to the Public Files and to staff contact within normal daytime operational hours must be maintained.

As well, the FCC expects licensees to operate a minimal amount of hours each day. “Going dark” also requires notification, and in some cases, approval from the FCC.

If the relocation of the main studio occurs before relicensing is completed in December 2021 the FCC renewal process will be immensely complicated with possibly two requests for change in studio location, potential notifications of non-operation (going dark,) construction permits for the new studios, etc.

Save KDVS believes it would be better to make no change in studio location until the renewal process is submitted and the FCC processes it sometime around December 2nd, 2021. It allows the GM and core staff to be focused on the renewal process, which also includes community ascertainment. 

What’s the Rush?

While portions of Upper Freeborn are potential seismic hazards, no such ranking applies to Lower Freeborn. This was why KDVS and other campus units were allowed to remain in Lower Freeborn. The University has not clarified which areas of Upper Freeborn are incapable of retrofit.

The University has consistently failed to justify why a relocation must be done on such a rushed schedule, or even what the schedule actually is. According to a University spokesperson, although the new building will not be a student-use structure, there is no actual plan as to what will replace Freeborn. The rubble from the demolition will simply be used as infill for the cavernous crater created. Then some years down the road the infill will be re-excavated and removed and a new foundation and basement laid for a so-called “exemplary project.” So the space will remain vacant for years. At best it will be a grassy knoll, at worst an unsightly rubble field surrounded by a chain-link fence.

Why not coordinate the demolition with the construction of whatever undisclosed “exemplary project” is put into the “expensive, Central campus real estate”? There would be no rush to evacuate KDVS and other student-run facilities from Freeborn.

Pandemic-Related Failures Of Established Protocols

It has been increasingly found nationwide and globally that during the current Covid-19 pandemic, academic officials have eliminated their normative procedures and policies of fact-finding and consultation, as well as marginalizing their already created decision-making “shared governance” boards. This has led to a major statement by the American Association of University Professors “Principles of Academic Governance during the COVID-19 Pandemic” calling on redoubled efforts by University leadership to maintain the system of shared governance, not only with faculty, but with students and other stakeholders, as well.

In the case of Freeborn demolition and KDVS, the UC Davis Administration has sidelined two important committees established by the Regents to provide information and guidance to the Chancellor and the University President. The first is the Council on Student Affairs and Fees which should decide on the legitimacy of using the $66 per student annual Student Health and Safety Fee intended for Seismic Renovation and Retrofit for Demolition of Freeborn. The fee was intended for safety needs in student fee constructed and use buildings, not for the entire demolition of a previously student-use building expropriated by the campus Administration. One is reminded of the old Vietnam-era military doublespeak “we had to destroy the village to save it.”

Campus Media Board Left In The Dark

The other “shared governance” group not consulted was the Campus Media Board which consists of Students, Faculty, Staff and Administrators (in an ex-officio role). It also has hearings taking in the advice and perspectives of campus and non-campus stakeholders. The Media Board has been tasked by the Regents to oversees the operations and finances of KDVS and has always been intimately involved in major projects and protecting the station from undue interference in programming by the Administration, ASUCD and others. Media Board recommendations are provided to the Chancellor and University President for approval. The Campus Media Board was not involved in the approval process for the new studio location of KDVS. They also need to be immediately informed of the process that KDVS intends to undertake during the license renewal process,

Both of these groups have had difficulties arranging meetings and hearings on these important issues during the pandemic. They need to be involved as they are a critical part of the consultative and shared governance system on the UC Davis campus. They will need to meet in the Fall, when, and if, students are allowed to resume full on-campus course work.

Proper Pathways at Deliberative Pace

The COVID-19 pandemic should not be used as an excuse to misappropriate student registration fees simply to avoid scrutiny. Neither should a student organization undergoing FCC Renewal be moved without the assistance of the Campus Media Board and experienced former staff.

This is precisely why a one-year time scale was not a reasonable possibility for KDVS to move from seismically-safe Lower Freeborn into a new site, let alone a new site that seems likely to extensively reduce KDVS operations.

It’s possible that the UCD administration didn’t even know that KDVS was up a license renewal starting this summer. If they did, then approving a move was setting up KDVS for failure. KDVS should not be compelled to move into a space inadequate for its needs. Even if such a space can be found, a move should be delayed until after the KDVS FCC license is renewed.

With more time, additional options for more appropriate studio siting can be explored, which is what the University initially promised. The involvement of KDVS core staff, volunteers, the Campus Media Board and the views of the varied stakeholders in the community can be properly ascertained. A better solution can be reached.


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Sacramento News & Review Article

“Plan to downsize beloved U.C. Davis radio station, demolish historic building, was hatched by the administration of Linda Katehi”

“As generations of alumni try to keep KDVS FM intact, they’re battling a proposal that started with the controversial college leader who many would rather forget.”

Read more at https://sacramento.newsreview.com/

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Statement From Former KDVS GMs


“The undersigned former General Managers of KDVS 90.3 FM have read the April 2, 2021 UC Davis announcement of its plan to drastically downsize the radio station by relocating it into a 1,000 sq. ft. room. This plan will be extremely harmful to the function of the radio station, its historic and ongoing mission, and the wider community KDVS serves. No deadline that would require such a precipitous and highly unfortunate move has been identified. The University’s current plan will permanently change KDVS to its detriment.  We urge the University to abandon its disastrous plan, a remnant of a 2015 initiative by former Chancellor Katehi, and work further in good faith with the expert KDVS relocation group that it originally convened to find a better solution. Please reconsider.”

Bruce Riordan 1969-70
Program Director for the Climate Readiness Institute at UC  Berkeley

Ken Beck 1973-74
Vice President News, Talk, and Sports Programming,  Entercom Communications (Retired)  

Rob Pattison, Esq. 1975-76
(Also Editor-in-Chief of The California Aggie for 1976-1978)  

Mark Friedman, Esq. 1978-79  
Chief Legal Officer for ChromaDex, Inc  

Eric Heinitz 1980-81
Educator 1983-2018 Foothill High School, Pleasanton-English  and Latin; 1988-2018 Sponsor and Certamen Staff,  Calif. Junior Classical League  

Ray Leos 1981-82
Dean, Faculty of Communications and Media Arts; Professor of  Law and Communications at Pannasastra University,  Cambodia. J.D. King Law, UCD; MFA, Graduate School  of Film TV, UCLA  

Randy Fender 1982
Freelance Writer, Former Mgr. The  Graduate, Davis  

Mark K Stevens 1984-85  

Geoff Lomax 1986-87
Program Manager & Government Affairs CIRM (California Stem  Cell Agency)  

John Nelson 1987-88
Director of Marketing & Activation at iHeartMedia, Marketing  Director Entercom, Promotions Director KXRQ-98 Rock,  KDND-107.9, and KWOD 106.5  

Brian Grattidge 1988-89
Environmental Land Use Planner, CEQA, State of California,  City of Woodland.  

Ted Verani 1990-91
Vice President, Global Business Development at wappier  

Marg Tobias, Esq. 1989-90
Tobias Law Firm, S.F.  

Marta Ulvaeus 1990-1993
Educator, Former Faculty Advisor at KUSB-FM UC Santa  Barbara  

Martin Buzak 1994-95
Senior Assistant City Attorney, Contracts J.D. Univ. of Pittsburg School of Law  

Todd Urick 1995-97
Broadcast Engineer, Program & Technical Director of Common  Frequency  

Paul Wilbur 1997-98
Manager, Eucalyptus Records, Davis 

Justin Kable 1998-2001
Licensed Professional Civil Engineer

Liz Berg 2001-02 
Senior Product Manager NY Public Radio WNYC, WQXR;  Asst GM- WFMU 

Chris Marland 2001-02
Cisco Certified Network Professional, Routing & Switching  CNSS 4011 National Security Agency, Phi Kappa Phi, Lifetime Member  

Paul Shramski Towers 2002-03
Executive Director at Community Alliance with Family Farmers  

Teresa Kenny 2003-04
Founder & Director, Office Ops, LLC  

Steven Valentino 2004-2006
Producer, “The New Yorker Radio  Hour WNYC; Producer~ Peabody Award-winning  “Leonard Lopate” Show (2008 to 2015). WNYC  Newsroom.  

Drake Martinet 2006-07
Chief Technology Officer at MIT Technology Review    

Ben Johnson 2007-09
Co-Owner, Delta Breeze Records  

Kevin Corrigan 2009-10  

Neil Ruud 2010-12
Technical Director, Cosmic  

Renner Burkle 2012-13
Regulatory Affairs & IoT Platforms Engineer  

Cameron Cairns 2013-14
Chief Technical Officer, Start-Up; Sr. Software Engineer, Simply Legal  

Ashley Hanson 2014-15
M.S. Nutrition for Wellness  

Dynn Javier 2015
Private Personal Trainer  

Olivia Henderson 2015-17
Program Director Red 103.1, Bob FM, XS Sports 96.1 FM  

Mitchell Rotter Sieren 2017-18
Environmental Engineer  

Jacob Engel 2018-19

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What Can We Surmise Regarding The Proposed KDVS Relocation Site

The proposal is to move KDVS from Lower Freeborn Hall to the Gunrock Gaming Room, which is on the side of the UCD Memorial Union Building, as depicted below.

Within the downsizing of offices to one-third of the current size, the space priority at the new location is to maintain the “General Staff” part of the KDVS offices.  This an important cultural aspect of the station, and the chief workspace for volunteers.  Space for “Master Control” is also a requisite part of the station per FCC guidelines.  “Studio B” — the main broadcast studio — is also a priority.  Under ADA guidelines, this studio would likely need to be expanded, but for the sake of this document, we will assume equivalent space.  These three areas consist of 787 SF at KDVS.  The next priority is a record library, which consumes 1103 SF.  With 213 SF left at the new KDVS location, 19% of the record library would be accommodated.

View the current functional space usage at KDVS.

ESTIMATION: PROPOSED RELOCATION AT GUNROCK

542 SF General Staff Area: Four to five desks, Music Dept,
couch, three computers, public file 
190 SF Studio B (Main Studio)
55 SF Master Control
213 SF 19% of the current Record Library

= 1000 SF

ESTIMATION: EXCLUDED PARTS OF RELOCATION AT GUNROCK

890 SF 81% of the current Record Library
336 SF KDVS Staff Office (Core Staff Business)
80 SF Two Listening Rooms
75 SF  Studio C News Room
160 SF Studio A (Live, Production, and Recording / Auxiliary
Broadcast Studio) 

The following remediatory measures are being considered to mitigate space loss:

High density archive media shelving for record storage was proposed to increase the density of storage:  Instead of media shelving along walls, it was proposed that archive storage could be used.  The problem is there is a major difference between a “library” and an “archive.”  Libraries accessible for general daily use.  Archives are for select limited access for historical preservation.  The following demonstrates the two regimes:

Record Library
High Density Archive (e.g., to get to one record stored in
  on the far right shelve, five shelves of archives need to 
   be manually shifted left.)

The first photo is a library: with easy access, many volumes can be pulled in rows in a matter of minutes, with multiple people accessing the library at once.  The second photo is a proposed high density archive.  Each volume takes multiple minutes of moving multiple shelves to access, and one person can only use the archive at one time.  Browsing is severely encumbered.  High density storage might be ADA compliant on paper, but ironically, for many disabilities, this high density storage is much more difficult to access than the current KDVS library.

Off-Site Recording Storage: It was stated off-site record storage was needed because the new KDVS location could not accommodate much of the library.  Since such a secondary record archive location would need staffing, with a person to check volumes in and out, it is presumed that this site would not be accessible for individual DJs for normal radio shows.  The question is which records would be used at the station and which would reside at the archive?  Would specific genres, like “jazz”, be placed in storage because it is assumed less people utilize it?  The idea of segregating the collection based upon popularity of use is antithetical to the mission, history, and legacy of KDVS.  The library would be relegated for simple common airplay usage, and not its heritage of an educational laboratory for students and the community to explore historic analog recordings.  Moreover, this frustrates the execution of the longstanding Freeform format when only the most popular records and/or genres are accessible.  

Digital audio solutions:  With reduction of space, the question of much more to rely on digital audio was presented.  Modern broadcasting employs digital media for its flexibility of use, so there is an implicit decision to move towards partial replacement of physical media.  The issue for KDVS is that there is not a budget for a complete digital library to cover the compulsory facets of licensing, functioning, maintaining, and archiving.  With the move decision made, KDVS is thrusted into a digital dependence, when (A) no planning has occurred, (B) it is not known whether the university would support laptops and private online streaming services, and (C) will UCD require the adoption of new DJ practices when a digital library is made.

There are major implications to consider.  First, it is assumed by the current relocation plan that students might just employ consumer streaming services like Youtube, Spotify, etc. for their radio shows.  This is illegal for a broadcast entity.  A new formal digital strategy might certainly create new rules by campus legal to explicitly prohibit this practice.  Thus, an on-site digital library would need to be relied upon.  However, the time and skills associated with digitizing tens of thousands of albums cannot be advanced via volunteers with ad hoc local hardware (it has been formally attempted at KDVS in the past and failed).  Consider that in the last fifty years KDVS has not even cataloged its physical library because it is too laborious and technically-intensive for the volunteers.  Besides the skill for mastering, track-album dividing, and cataloging, digital rights protocols must be meticulously observed, cataloging the physical copy, assuring proper copyright protections on a system, and providing library back-up(s).  On top of that, professional servers are required and needed to be maintained.  Beyond the hardware aspects, it would require earmarking over $100,000 yearly for a librarian/IT/digital rights position, with hardware.  With this, a digital replacement library would cost more after a few years than just properly relocating the whole collection on-site within the studio.  But if the university is not subsidizing a digital media regime, streaming is formally discontinued, and most of the physical library is in storage, there is a dilemma of how music programming would be executed.  

Elimination of Studio B: Everything that is not live is produced in Studio B.  Recorded announcements, pre-produced programs, interviews, audio editing, news segments, etc all require a fully equipped studio.  A future-designated site for this studio somewhere else on campus is casually speculated by the university, but not guaranteed in writing within the relocation decision.  Furthermore, shifting between studios or combined studio use would be difficult with a remote studio.  Without the university designating this now, KDVS’ future functionality as a broadcast outlet is at question.

Elimination of “Dead Room”: Perhaps one of the most essential parts of the station is a room for live audio, sound recording, and collective audio.  Recording of bands for the longstanding program “Live in Studio A” would be discontinued.  Live debates, radio theater, multitrack recording, or any production of multiple people requiring microphones and production would be eliminated.  Like Studio B, the addition of this room would be a work-in-progress.

Elimination of Staff Office:  An office with desks and computers is essential to any workspace.  The office also a place to catalog and store fundraiser premiums for fund drives, station merchandise, materials for remotes, and publicity banners, for production of publicity products, for placement of file cabinets, to have private uninterrupted professional meetings concerning business and station clients, for creation of news scripts, for coordinated projects, and for general work.  The absence of this area is deleterious for essential station business.   

Elimination of Studio C and listening rooms:  Listening rooms provide the most basic of service for DJs preparing material for radio shifts.  It is thought listening areas might be added to the current plan by subtracting general staff space, but that space is lean as it is.  Studio C provides a quiet, dedicated studio for the news department only.  Like Studio A, the Dead Room, and the library annex, a fourth spot was mentioned concerning the possibility of a news area some place on campus.

Bathrooms: There are no bathrooms integrated with the plan, but it may be assumed the University would grant the hundreds of volunteers associated with KDVS access to the Memorial Union building 24 hours a day.  This might seem like a liability for the University, especially for the women’s restroom, which would require two keys to access in the west wing of the MU.

SUMMARY

Location 1 Core Station – Space Proposed
Location 2 Studio A and Dead Room – KDVS needs to appeal
Location 3 Off-Studio Library Storage – TBA
Location 4 News – KDVS needs to appeal
Location 5 Off-Site Bathrooms – TBA

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Video

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Freeborn Hall & KDVS Facilities

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Freeborn Hall Concert Posters

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KDVS Stickers