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19 Ways to Make the FCC Rules Better

iHeart, Emmis, Urban One and others push for a raft of changes to familiar rules

This is one in a series of Radio World articles about proposals for changes to FCC media rules.

Ask any radio broadcaster how the FCC can make life easier, and you’ll probably get plenty of good suggestions.

Several large U.S. radio entities — including the largest one, iHeart, as well as an influential public broadcaster, New York Public Radio — want the FCC to change a whole bunch of familiar management and technical rules under which broadcasters have operated for years. Their proposals touch on a range of issues from station IDs and ownership reports to AM proofs and single-sideband FM stereo carriers.

The companies that filed these joint comments are Alpha Media, Emmis Communications, iHeartMedia, Liberman Broadcasting, New York Public Radio, and Urban One, the former Radio One.

They were among companies responding to an FCC call for ways to “modernize” media rules, and they eagerly embraced an opportunity to change restrictions that they think are “outdated, unnecessary, or unduly burdensome.” Targets include technical rules that are “ripe for repeal or modernization to reflect the realities of modern broadcast technology and the manner in which stations operate today.”

They said the FCC should do the following, extracted and summarized from their filing by Radio World:

– Eliminate the newspaper publication requirement for local public notices, substitute an online posting version and change the on-air requirement so a broadcaster can just announce the type of application and then point listeners to a website.

– Do away with required mid-term EEO reports, Form 397, because EEO reports are now in online public files.

– Drop the requirement that you have to post the station license at your principal control point. Most stations, they say, use dial-up or IP remote control systems and can be managed from a smartphone or PC at any location. Licenses are in public databases, they argue; so the FCC should require stations only to produce a copy upon request.

– Simplify rules for ownership reports (Form 323).They’re glad the FCC is transitioning from the familiar CDBS to a new Licensing and Management System; but they asked the FCC to address problems in its Form 323 interface and to make sure the new system works right before December.

– Kill the rule that stations must submit ownership reports every two years; require reports only when there’s a new construction permit or transaction that needs FCC approval. Otherwise, at least cut back the cycle to every four years or longer.

– Require that issues/program lists be placed in the public file on an annual basis, rather than quarterly, and …

– … permit broadcasters to provide only a brief summary of issues covered plus a list of programs, instead of all the details about date, time and duration.

– Let stations make their station IDs periodically instead of near the top of the hour, to avoid audio clutter and interruptions of long-form programming.

– Give stations discretion in the format of their station IDs as long as they include call letters or a locally recognized “brand or moniker.”

– Allow alternative means of station ID other than “aural,” such as Radio Broadcast Data System Program Information Code or a RadioText message that includes a station’s call letters and community of license on an FM receiver, or digital Program Associated Data.

– Eliminate the EEO language that broadcasters must disseminate full-time vacancy notifications to “entitled sources.” The broadcasters told the FCC most stations “find very little return on the significant investment in time and resources it takes to notify these sources of their open positions.” Job vacancy info is readily available online now, they said (while emphasizing that they “vigorously support” the commission’s overall EEO rules).

– Eliminate the practice of placing a “hold” on applications when there’s a pending enforcement complaint or investigation, with certain limitations.

– Allow stations with experimental broadcast licenses to ask for renewals instead of facing a hard five-year limit, which the companies believe can force broadcasters to end experiments prematurely.

– Eliminate or relax the Method of Moments proof rules for AM directional stations. The rules require them to recertify at least every 24 months; this is very costly, the companies said, and unfair compared to stations using the conventional method. Also about MoM …

– … If a recertification requirement is kept, the FCC should limit the obligation, perhaps by requiring periodic antenna monitor recalibration and re-measurement of reference points, but with full recertification mandated only if there is substantial drift in reference points or if a recalibrated monitor reads out of tolerance. At minimum, the FCC should reduce the frequency of full recertification measurements, requiring them within 24 months before license renewal filing.

– Let FM stations that use the “indirect power determination” method rely on an efficiency factor that is automatically generated by their transmitter. The current rules require them to use a factor based on prior measurements or data from the manufacturer.

– Allow stations to use single-sideband FM stereophonic carriers without further authorization. Experiments to date, they say, indicate that “many stations have successfully used such carriers without causing interference or other issues for other stations.”

– Don’t require equipment performance measurements annually. Reduce it to three years, if any. Require equipment measurement only when installing a new or replacement main transmitteror replacing an audio processor intended to provide audio bandwidth limitation. Rely on the complaint process in cases of interference from unstable transmitters.

– Allow digital RPU operations in the 450 and 455 MHz bands, as well as digital emissions for two-way radio systems.

This joint filing is only one of four or five dozen that the FCC has received so far. Radio World will continue to provide a sampler of filings.