On behalf of a diversified joint client group comprised of more than forty broadcast companies, Lerman Senter filed extensive Comments April 28th in the FCC’s rulemaking proceeding on broadcast localism. The Comments note that, “[o]n the basis of little more than anecdote, [the FCC] proposals would reinstate overnight a slate of intensive regulations that, over the period of the last 25 years, the FCC has thoughtfully and incrementally reshaped, or discarded altogether, in multiple decisions amply supported by compelling facts and sound policy rationales.” The Comments further observe that “[i]In the absence of demonstrable industry failure, blanket reinstatement today of regulatory processes rejected decades ago as poorly suited for their intended purposes is retrogressive and ill-conceived.”
The particular proposals addressed in the Comments are those that would: (1) mandate the location of each broadcast station main studio within the political boundaries of the community of license to which each station is assigned; (2) require each station to maintain “a physical presence” at the studio during all hours of operation; (3) “reintroduce specific procedural guidelines for the processing of renewal applications for stations based on their localism programming performance;” and (4) mandate that each licensee “convene a permanent advisory board made up of officials and other leaders from the service area of its broadcast station.” A complete copy of the Comments can be accessed here.
