Just How to Revamp Media Rules? Comments Run the Gamut

Filers ask for review on lottery ads, translator IDs, LPFM collaborations
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Commenters have dug deep on issues ranging from hybrid IBOC operation to the collection of regulatory fees as the deadline slides up for comments on modernize media rules.

The modernization efforts were kicked off in May when the Federal Communication Commission issued a Public Notice and invited the public to weigh in on which media rules are unnecessary or burdensome and should be modified or eliminated. The commission noted it is seeking input on those rules from which small businesses should receive regulatory relief.

Western Inspirational Broadcasters Inc. (WIBI), which is licensee of nine full-service noncommercial FM broadcast stations and 27 noncommercial FM translators across four states, filed comments to urge elimination of one specific section of the FCC Rules: The one that clarifies how a primary station should identify a translator station.

That section is outdated and unduly burdensome, WIBI said in its comments.

Station KNIS(FM) in Carson City, Nev., must broadcast a list of its translators, their call letters and location three times daily, a process that “contains no meaningful information for the average listener,” WIBI said. “To identify all 27 facilities requires approximately two minutes of airtime, for a total of six minutes daily, and annual total of 36.5 hours of programming being devoted to translator identification,” the licensee said.

“It seems evident the public interest would be better served by taking the 36.5 hours a year of translator identification announcements and, instead, using it for programming which would be more meaningful and relevant to the listeners,” WIBI said in its comment filing.

In its comments, SSR Communications in Flora, Miss., proposed that the commission relax — or even outright eliminate — third-adjacent FM broadcast separation protection standards for all station classes, provided that an intended licensee can demonstrate its proposed facilities and antenna system would not cause any real-world interference to third-adjacent stations.

“[S]uch a change would allow hundreds of full-power stations an opportunity to relocate or upgrade to less-congested channels without impacting the actual signals of neighboring stations,” said Matthew Wesolowski, chief executive officer of the company.

Others, like KXRN(LP) in Laguna Beach, Calif., are asking the commission to modify certain rules as they pertain to LPFM simulcasts and other collaboration possibilities.

The station is a neighbor to nearby KOCI(LP) in Laguna Beach; as such, residents of Newport Beach and Laguna Beach are interested in similar news, local happenings, and public affairs programming, said Tyler Russell, KXRN program director. The two stations could better serve both communities by simulcasting content from one LPFM station to another, he said.

“[W]e believe, that in some cases like ours, the ‘community’ is bigger than one single LPFM can cover, and it can require a successful collaboration between two in order to make an impact,” Russell said. “If the FCC is willing to eliminate or modify [the rules] to allow simulcasts, translating or ownership of a second LPFM, listeners in some larger communities like ours would be better served.”

Licensees like Blackbelt Broadcasting in Livingston, Ala., requested that proposed FCC regulatory fees be reappraised, reduced or waived for certain classes of small market radio stations based on size class or revenue.

Blackbelt Broadcasting pointed to the small advertising revenue base that exists in a town like Livingston, whose population of 3,400 has been unable to support a car dealership, furniture store or hospital.

“We ask you to consider the burden that increasing regulatory fees has on many small rural AM and FM broadcasters,” said Damon Collins, president of Blackbelt Broadcasting.

Others submitted comments often focused on a single issue: one commenter asked that the FCC amend its regulations so that LPFM stations, FM translators and FM boosters can broadcast using the same IBOC DAB standard that full-power FM stations use. Other commenters asked for the FCC to consider eliminating one very specific restriction: the limitations on lottery advertising that exist for four states (Alabama, Hawaii, Mississippi and Utah).

The comment deadline for this issue — which is Media Bureau Docket 17-105 — is July 5; the reply comment deadline is Aug. 4. Comments can be filed electronically via the commission’s ECFS system.

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