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NAB Comments on FCC Modernization

Group says members are tired of pushing paper

The National Association of Broadcasters says its members are tired of pushing paper. The group’s comments this week on FCC modernization are focused on reducing or eliminating paperwork, record-keeping and filing burdens.

The FCC’s Modernization of Media Regulation Initiative, released in May, seeks public input on ways to eliminate and modify rules that are outdated and burdensome for broadcasters.

The NAB begins its response by making it clear what broadcasters are not pursuing: “Local radio and TV stations are not seeking any diminution in their obligations to serve their communities of license. Rather, broadcasters support an updated regulatory regime enhancing local stations’ ability to serve their listeners and viewers more effectively in today’s competitive media marketplace.”

However, NAB makes clear its members “urge the FCC to reduce or eliminate unproductive and competitively disparate regulatory and administrative burdens that divert broadcast stations’ scarce resources away from programming and other services that benefit the public.

Among the reforms the FCC hopes to see is the creation of a combined annual compliance report to replace the currently separate quarterly issues/programs lists. “This streamlined annual report would rely more on broadcaster certifications, rather than their unnecessary submission of pages and pages of granular details about individual programs that lack practical utility for consumers and impose undue burdens on local stations,” NAB says.

The NAB is asking the FCC to take advantage of the internet to provide the requisite public notices associated with various types of broadcast applications. “Commercial and noncommercial AM, FM, TV and Class A television stations must every quarter place in their public files a list and description of the programs that have provided the station’s most significant treatment of community issues during the preceding three-month period and retain those lists until the FCC takes final action on the station’s next license renewal application. There is little justification for this type of reporting,” NAB says.

The commission should also continue its efforts to reduce unnecessary burdens on AM stations and barriers to broadcast innovation, according to the NAB’s comments. It supports further relaxation or elimination of AM antenna efficiency standards — the United States is believed to be the only country in the world with minimum AM antenna efficiency standards — which increase the costs of constructing and the barriers to operating AM stations.

“Clarifying and/or revising the current length of and renewal limits on broadcast experimental radio licenses also would help facilitate experimentation and innovation by broadcasters,” NAB wrote in its comments.

The NAB also is lobbying for fewer ownership report filings, the elimination of EEO midterm reports and argues the filing of numerous paper copies of contracts, including network affiliate contracts and some personnel contracts, is unnecessary.

The reply comment deadline for MB Docket 17-105 is Aug. 4. You may comment electronically via the commission’s ECFS system.