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NAB, Many Broadcast Groups File Comments With FCC On Main Studio Rule Elimination, Rule Modernization
July 5, 2017 at 2:10 PM (PT)
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The NATIONAL ASSOCIATION OF BROADCASTERS was one of several parties weighing in on the FCC's proposed elimination of the main studio rule. In comments filed MONDAY with the Commission, the NAB called the current requirement that stations maintain main studios in their primary coverage area "inconsistent" with listener and viewer expectations, and suggested that eliminating the rule would result in cost savings, better deployment of resources, efficiency, and better service. "(W)idespread use of electronic communications enables efficient interaction between stations and their communities of license without the need for the physical presence of a studio," the NAB asserted. CUMULUS' filing agreed that the "primary purpose of the main studio rule – which was to facilitate the public’s access to a station’s main studio and public inspection file – has been out of date for some time."
NEW HAMPSHIRE PUBLIC RADIO echoed the same position with the example of how it serves all eight of its radio stations statewide from the studio of its flagship WEVO/CONCORD, NH; UNIVISION called the rule "arbitrary" in how it allows some stations greater flexibility for locating their main studios than others (noting that, for example, its KLVE/LOS ANGELES can have a main studio anywhere within the principal community contours of any LOS ANGELES-licensed TV or radio station but its KRCD/INGLEWOOD-LOS ANGELES may only locate its studio within its Class A contour, a fraction of the market); and MAX MEDIA noted the importance of eliminating the rule for stations in smaller markets, allowing for more efficiency and lower costs.
Engineering firm MCCARTHY RADIO ENTERPRISES, INC.'s MICHAEL MCCARTHY generally supported eliminating the rule but stopped short of calling for outright deletion, saying that "While society's mushrooming predisposition of intermediary non-linear technology in lieu of personal 'linear' voice telephone calls and/or face to face visitation has substantially derailed the well intentioned role (of the Main Studio Rule).... it has not completely eliminated such a need." He suggested that while the rule is now outdated, the change "should not completely exclude the part of the public which doesn't have ready access to social media or generally to the internet," and should provide for a redefined "main studio presence" in "regional proximity of the community of license."
Also filing on MONDAY were FLINN BROADCASTING ("The Commission’s proposed action
makes sense. Plain and simple."), LPTV operator VENTURE TECHNOLOGIES GROUP ("The purpose of the rules has been bypassed by technology"), TV operators MOUNTAIN LICENSES, L.P., BROADCASTING LICENSES, L.P., STAINLESS BROADCASTING, L.P., BLACKHAWK BROADCASTING LLC, and BRISTLECONE BROADCASTING LLC ("Over the last several years, the number of public visitors to their main studios can generally be counted on one hand"), CORNERSTONE COMMUNITY RADIO (stressing the lack of waivers for commercial broadcasters acting as noncommercial operations), URBAN ONE ("the costs of complying with the Main Studio Rule are real and divert resources away from other station activities that do produce public interest benefits"), HUBBARD, COX, SAGA, NPR, and several more.Also Drawing Comment: Rule Modernization
The FCC was also among the parties filing comments TODAY (7/5) in the Modernization of Media Regulation Initiative docket. The filing called for, among other things, replacing some quarterly filing requirements with annual filings (and eliminating the quarterly issues/programs lists, which it says "serve little apparent purpose"); requiring ownership reports only after "relevant" ownership changes; dropping mid-term EEO reports and filing of contracts; no longer requiring broadcasters to retain hard copies of FCC rules; initiating a rulemaking to change broadcast attribution rules to count only interests "that confer a significant degree of influence over a licensee; do not discourage investing in the broadcast industry and reflect the current investment landscape; are not needlessly complex or overly prescriptive; and are consistent with the current broadcast ownership rules"; and relaxing AM antenna efficiency standards in favor of existing interference standards.
Other commenters in the docket included FAMILY LIFE MINISTRIES (asking for opening the FCC to waivers for translator applications near the Canadian border when INDUSTRY CANADA does not object); MEREDITH (elimination of paper notices and excessive forms like those for children's TV educational/informational programming); QXZ MEDIAWORKS LLC's ROBERT LEE (a proposal to move all AM stations to FM using TV analog RF channel 6 for an expanded FM band and making the transplanted stations digital-only); EDUCATIONAL MEDIA FOUNDATION (eliminating "rural radio policies" that put moves from rural to urban service under strict scrutiny; eliminating the prohibition of security interests on licenses as well as restrictions on reversionary interests and sales of "bare" licenses; redefining "minor change for FM translators to include any change that would be precluded by the existing facility); FAMILY STATIONS (removing the prohibition of satellite delivery of programming to translators in the non-reserved portion of the FM band); and REC NETWORKS (a 77 page filing asking for elimination or revision of many rules affecting LPFMs, accompanied by a 536-page technical addendum), as well as several others.

