The FCC’s inbox is overflowing with suggestions from broadcasters on ways the commission can improve regulatory practices as part of its “Delete, Delete, Delete” initiative.
We told you earlier about the filing from the National Association of Broadcasters. But many others have filed too. The wish list from large and small broadcasters includes loosening ownership caps, changes to EEO rules, updates to technical rules and overhauling public file obligations.
A review of the filings shows how broadcasters are fighting to survive in a media environment that continues to rapidly evolve on a near-daily basis.
Beasley Media Group in its comments pushes the FCC to repeal the Local Radio Ownership Rule. It says the commission can no longer consider AM and FM radio as a standalone market with so many audio streaming and digital offerings from tech giants like Amazon, Apple, Meta and YouTube readily available.
“The current ownership limitations are depriving radio of the investment it needs and hampering its ability to innovate and develop additional local content and digital offerings,” Beasley said in its comments to the FCC. “Radio broadcasters must be allowed to develop the economies of scale they need to compete against the digital giants.”
The media company, which operates 56 radio stations in 12 medium and large markets, tells the FCC that immediate action is necessary. “Years ago, a more incremental approach such as loosening or eliminating the radio ownership subcaps might have been warranted. But in the words of Chairman Carr, ‘we are at a break glass moment for America’s broadcasters.’ There is no time to waste,” Beasley wrote.
[Related: “FCC Moves to Clarify Foreign Ownership Rules“]
Joint comments from state broadcast associations advocated for moves beyond deregulation, saying a more practical approach to broadcast enforcement is critically needed.
“In the case of the commission’s broadcast rules, the problem is not simply one of excessive rules and policies; the commission’s strict liability approach to one-time and minor rule violations forces broadcasters to overinvest in compliance personnel and resources, trying to achieve an unachievable 100% compliance 100% of the time,” the state broadcasters said.
Educational Media Foundation (EMF) asked the commission to modify or eliminate numerous rules and policies that are “no longer supported by sound policy and which adversely affect broadcasters,” including noncommercial broadcasters like EMF.
EMF said the commission can begin by eliminating the Rural Radio Policies, modifying NCE translator signal delivery rules and amending the definition of an FM translator “minor change” to encompass any change where the proposed facilities would be precluded by the current operation.
The noncommercial broadcaster also asked the FCC to eliminate requirements that reserved-band stations protect Channel TV 6.
Press Communications, a New Jersey-based owner of a half dozen radio stations, offered suggestions on technical matters that “reflect the glaring disparity of Class As versus the higher power Class Bs.”
The broadcaster proposes deleting all references to third-adjacent channels and “deleting the fictitious Class B 54 dBu protected contour” in the rules. “Instead the commission should substitute the actual Class B 56.5 dBu protected contour to Class A’s as built into the spacing tables,” Press said in its filing.
Meanwhile, radio station operator SSR Communications proposed six specific rule changes, including a request for the commission to delete “abandoned” FM allocations in cases in which a licensee has surrendered its license.
A coalition of 82 broadcast station licensees in joint comments focused on changes to EEO obligations, specifically that create “burdensome paperwork and nonproductive actions” for small broadcasters.
The group of stations proposes several measures to promote wide outreach to recruit for full-time openings, resetting market-based employment units and reexamining the small station exemptions to EEO reporting.
REC Networks, a community radio advocate, pressed the FCC to move ahead with a Notice of Proposed Rulemaking to establish a new LP-250 low-power FM service. The LPFM service was created in 2000 with a maximum power of 100 watts.
LPFM Advocacy Group focused its comments on technical standards for low-power FM broadcasters. The group told the FCC it supports revising LPFM technical rules to allow full compliance with the same interference and contour standards used for FM translators.
“We believe LPFM stations should have the option to operate at up to 250 watts ERP under these translator-style engineering protections, without being bound to a separate set of technical standards or power restrictions,” LPFM Advocacy Group said in its comments.
Not all commenters in the docket agreed with the assertion made by the broadcasters that the FCC needs to eliminate the local ownership rules for radio. The musicFIRST Coalition urged the commission to maintain the status quo when considering public interest concerns.
“We urge the commission, when analyzing competition between audio platforms and, importantly, within the AM/FM radio platform within respective geographic markets, to consider listeners and music fans as well as the music creators who provide much of the content used by audio platforms,” musicFIRST wrote.
The group, which has advocated for imposing new performance fees on radio broadcasters, reminds the commission that its decision-making “is not just about the pocketbooks of those radio conglomerates that would like to exceed the current maximum of commercial FM stations in a single market.”
You can read industry comments in Docket 25-133 online. Reply comments are due April 28.
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