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Background Information
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Contact the FCC Today!
Click Here to File Comments
Do Not Delay - Final Deadline Is June 11
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The FCC has issued a Notice of Proposed Rulemaking that seeks comment on various rules that would mandate how broadcasters serve their communities. Below is a description of these proposals and some suggestions on the type of information you might include in your comments to the FCC.
You do not need to comment on every proposed rule change, but please try to include the following: (1) detailed descriptions of your efforts to assess the needs of your communities; (2) how the FCC’s proposals will negatively affect your stations; and (3) why these new rules will not improve your already excellent local service record.
Renewal Processing Guidelines
The FCC proposes to introduce specific procedural guidelines for the processing of license renewal applications, similar to the process in place in the 1970s. Thus, a station that does not air a specified amount of local programming would automatically have their renewal application reviewed not at the Bureau level, but by the commissioners themselves.
- Tell the FCC why this process would be counter-productive. Would it pressure your station to air programming that fits within the FCC's proscribed categories at the expense of programming your local audience prefers? Are these "processing guidelines" just another way of expressing programming "quotas?"
- Explain why a uniform programming requirement imposed on all stations, regardless of local needs and station or market characteristics, would not result in improved service to the public.
- Tell the FCC why this proposal is unnecessary by describing the types of local programming you already provide:
- Local newscasts: how many per week, percentage of your overall programming devoted to local news.
- Programs devoted to local public affairs, politics or community activities, in terms of formats, frequency and length. Number and type of PSAs.
- Coverage of important issues: health, consumer, crime prevention, drinking and driving, etc.
- Responses to local emergencies and your station's positive community impact during emergencies.
- Political coverage: debates, free time offers, coverage of local political issues (not just race horse coverage), candidate interviews, voter registration drives, others.
- Programming aimed at particular community segments (art lovers, youth, minorities, farmers, women, foreign language, others).
- Promotion of local musicians and local genres.
- Explain to the FCC how programming can serve local needs and interests without being locally produced. Give specific examples.
Ascertainment/Advisory Boards
The FCC believes that new efforts are needed to ensure that broadcasters gather information from their communities to help inform their stations' programming decisions. The FCC has proposed a requirement that stations establish permanent advisory boards consisting of local officials and other community leaders, and meet with the boards on a quarterly basis.
- The FCC recognizes that many stations already perform "ascertainment" through various means, such as service on community boards, councils and commissions; audience surveys; town hall meetings; and soliciting calls and emails. Give examples of your current ascertainment efforts to help demonstrate that FCC rules are unnecessary. Include information as to how you ascertain the needs and interests of minority and/or underserved segments of the community.
- Explain why stations already have marketplace incentives to ascertain the needs of their viewers and listeners.
- Tell the FCC that a "one size fits all" requirement for every station in the country, regardless of market and station size and characteristics, would be counter-productive.
Remote Station Operations
The FCC suggests that automated broadcast operations may hinder a station's ability to determine and serve local needs. The FCC proposes a requirement that all radio and TV stations be manned during all hours of operation. The FCC believes that such an obligation will increase a station's ability to offer local programming, during both regular hours and local emergencies.
- Give the FCC an informal cost-benefit analysis of how the proposal might affect your station. Would the additional costs compromise your ability to create and offer local programming, or deliver other programming of interest to your audience?
- Describe why the FCC's assumptions may be inaccurate. Would having personnel at the station 24 hours a day, seven days a week, truly improve your ability to ascertain the interests of your local community or offer programming that meets those needs?
- Explain to the FCC why automated operations do not hinder a station's ability to provide emergency information.
- Explain how alternative, less draconian measures can rectify the FCC's concerns.
Main Studio Location
The FCC's original rules required that a station's main studio be located within its community of license so that the station would be accessible to the local community. The FCC liberalized this restriction in 1987 and 1998 in part to allow station groups to operate more efficiently. The FCC now seeks comment on whether it should revert to its pre-1987 rules to strengthen a station's connection with its local community and to expand a station's production of locally originated programming.
- Describe the costs associated with complying with this rule, including real world costs of physically relocating your main studio. How would it impact your ability to offer local programming and other programming demanded by your audience or perform other station activities?
- Explain to the FCC why increased restrictions on main studio location would not lead to the production of more locally originated programming.
- Give examples of how you interact with your local audience today. Explain why restrictions on main studio location would not lead to greater interaction.
Voice Tracking/National Playlists
The FCC seeks comment on the prevalence of voice tracking, and whether the FCC should take steps to limit this practice. The FCC also expresses concern about how the use of national playlists may negatively impact access to the airwaves of local musicians.
- Describe your use of voice tracking (if any), and how voice tracking has little effect on the presence of broadcasters in the community or your ability to serve the programming needs and interests of your local community.
- Describe your programming that involves local musicians and local music genres.
- The FCC asks whether broadcasters should be required to submit data about the airing of music by local artists and how stations compile their playlists, which the FCC would use in its consideration of a station's license renewal application.
- Tell the FCC how this proposal would affect your station. Would it pressure you to air local musicians at the expense of your regular format or instead of other programming that your local audience prefers? Would it involve the FCC in programming decisions better left to local stations?
How to File Comments
Click here to access the NAB's user-friendly form that sends comments automatically to the FCC's Electronic Comment Filing System (ECFS).
Do not delay. The deadline is June 11. If you miss this date, please file anyway as soon as possible.
Note: The FCC's system will not accept comments that are attached to the NAB form as a separate document. To electronically file comments you have separately prepared in a Word document or PDF, click here for a direct link to the FCC's electronic filing system.
If you prefer to file your comments by mail, address your letter to:
Ms. Marlene H. Dortch
Secretary
Federal Communications Commission
445 12th Street SW
Washington DC 20554
All comments must be filed under the assigned docket number MB Docket No. 04-233. Please be sure to include this number.
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