WASHINGTON—In an opening brief filed in the U.S. Court of Appeals for the D.C. Circuit, the FCC laid out its claim that it was reasonable to reinstate the UHF discount immediately while it considers adjusting the national audience reach cap, that is has the authority to adjust that cap, and that the discount and the cap have to be considered together because the UHF discount is meaningless except in relation to the cap.
This is in response to the challenge to its UHF decision filed by Free Press, Office of Communications of the United Church of Christ, Prometheus Radio Project, Media Mobilizing Project, Media Alliance, National Hispanic, Media Coalition and Common Cause.
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