The author is partner in the law firm Hardy, Carey, Chautin & Balkin LLP.
At its May meeting, the FCC kept up its rapid pace of change, boldly launching a “catch all” Modernization of Media Regulation Initiative to review all media regulations for the purpose of eliminating or modifying rules that are outdated, unnecessary or unduly burdensome. Rather than suggest what rules might need to be changed, the FCC simply listed the principal rule parts covered by the proceeding, inviting comments by July 5, 2017.
Many of the FCC’s broadcast station rules need scrutiny. For example, does the requirement to publish local notices when stations file certain forms really matter? Who is reading those? It’s hard to believe, but the “local notice” rule is literally 3,893 words long. And it requires newspaper publication in many instances.
Why is it necessary to have a top of the hour station identification? Why do you have to maintain a separate “records” file for FM translators? And can’t the FCC look in the latest online filing for a translator’s contact information instead of requiring that it be posted in a weatherproof placard at the bottom of the translator tower?
If these cause you to scratch your head, we’re with you. It’s summertime, so make a top ten list of FCC rules that should head to the trash heap (or at least be updated). And then let the FCC know. The only broadcast rules exempt from this proceeding are the multiple ownership, affiliation, and video accessibility rules, which are being addressed elsewhere.
What other rules should the FCC reconsider? Post a comment below or email a letter to the editor firstname.lastname@example.org.