FCC Seeks Comments on Alleviating Regulatory Burdens

The FCC is seeking input on a new sweeping deregulatory initiative referred to as “Delete, Delete, Delete.” It opens up to comment, review, and potentially repeal or relaxation, all FCC rules across all services and industries regulated by the FCC. As part of this process, the FCC is inviting the public to identify rules that should be considered for repeal or modification.

“Delete, Delete, Delete” was triggered by Executive Orders signed by President Trump on January 31, 2025 and February 19, 2025 calling for greater federal deregulation and instructing federal agency heads to work with the Department of Government Efficiency (“DOGE”) to create a process to review existing regulations. FCC Chairman Brendan Carr described the new initiative as a “massive” effort and said, “The FCC is committed to ending all of the rules and regulations that are no longer necessary.”

The FCC is requesting that commenters propose rules for elimination or modification on any relevant grounds, but specifically asks for comments on the following questions:

• • Do the costs of compliance with the rule outweigh the benefits resulting from such compliance?
  • How has experience gained from implementation of the rule informed the question of whether the rule is necessary and advances the public interest?
  • To what extent have marketplace and technological changes rendered the rule unnecessary or inappropriate?
  • To what extent does the rule result in barriers to entry into an industry (for example, where the costs of compliance would disproportionately be borne by smaller companies or new entrants)?
  • Have changes in the broader regulatory context made the rule unnecessary or inappropriate (for example, have state or local laws, other federal rules, or self-regulatory efforts diminished the need for the rule)?
  • How is the rule affected by changes in, or other implications of, the governing legal framework (for example, where the statutory language under which the rule was promulgated has changed, or where judicial decisions, such as the Supreme Court’s recent decision in Loper Bright requiring courts to exercise greater independent judgment and pay less deference to the judgment of an agency such as the FCC, may impact the interpretation of a rule)?

Comments are due Friday, April 11, 2025, and reply comments are due Monday, April 28, 2025. Companies that hold FCC licenses, are regulated by the FCC, or are otherwise impacted by FCC regulation should consider participating in this proceeding.

If you have any questions regarding “Delete, Delete, Delete,” or would like to submit comments, please contact one of our attorneys.