In a recent decision, the FCC eliminated the main studio rule, which requires radio and television station licensees to maintain a main studio at locations in or near a station’s community of license. The FCC also eliminated several requirements that are associated with the main studio rule, including the requirements to have at the main studio a meaningful management and staff presence during regular business hours and program origination capabilities.
The elimination of the main studio rule does not in any way limit or reduce a licensee’s obligation to maintain control over essential station matters – including personnel, programming, and finances. Moreover, the FCC expects that stations will continue to serve their local communities. To that end, certain service requirements will remain in effect, including the requirements to: (i) maintain a local or toll-free telephone number, which must be answered during regular business hours and, for stations that have already transitioned to the online public file, posted in the online file; (ii) air programming responsive to significant issues facing the community and document such programming in quarterly issues/programs lists; and (iii) maintain a public inspection file at a location in the community that is open during regular business hours, but only to the extent that a station still maintains a paper public file. For stations that have transitioned to the online public file but still maintain “old” political documents in a paper file, they could avoid having to continue to maintain the paper file by uploading to the online file the remaining paper documents that are less than two years old.
Certain stations currently hold main studio waivers, which may contain certain pledges or commitments regarding station operations. With the elimination of the main studio rule, those waivers, and any related pledges or commitments, will be superseded.
The rule change has not yet become effective. We will send another alert when it does. Until then, stations must continue to comply with the current main studio rule.
If you have any questions about the elimination of the main studio rule, please contact any attorney in our office.