NAB Pitches ‘Minor Modifications’ to FCC Application Filing Rules

Says less is more for online and on-air presentations of pending applications.
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WASHINGTON—The NAB had just a few notes it feels the FCC should take into consideration when it comes to the modernizing of broadcast application public notifications for TV and radio stations, mostly about just how much info needs to be pushed directly to the public.

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Commenting on a Further Notice of Proposed Rulemaking dealing with the public notice of the filing of applications, the NAB came out mostly in support of the FCC’s revisions to the rules, but did pinpoint a “minor modification” to online notice requirements.

First, the FNPRM primarily deals with the revision that TV and radio stations will no longer need to publish notice of application filings in newspapers, saying they are costly and, with the decline of newspapers nationwide, no longer have the reach they previously did. The NAB fully supports the commission’s move to now require online notices.

As far as how that notice is displayed online is where the NAB begins to have some notes. It says that it agrees with the goal of directing viewers and listeners to pending applications. However, the NAB believes “it is not necessary or appropriate for the notice to include additional material in the notice that will be apparent from reviewing the application and/or the station’s online public file.” The organization says that these notices should adhere to popular website design where, while clearly identified, the notice can be less than 15 words and offer a link to the application for more details, suggesting a link labeled “Pending FCC Applications” or something akin available on the homepage.

With the proposed rulemaking, the FCC would still required on-air announcements for applications that require them, which again is something the NAB supports. Where they want to see the FCC adapt in this instance is in the delivery of these notices. The NAB says it is best to simply have a full display of the text while it is being read on-air rather than to create a text crawl with the information. The NAB believes that text crawls are typically only used for critical information and cause undue burden on broadcasters, as well as “impede innovation on new platforms and raise First Amendment issues.”

NAB’s full comments on this FNPRM can be found on the FCC’s ECFS database.