NAB this week told the FAA that information collection requirements proposed by the agency's recent Notice of Proposed Rule Making (NRPM) regarding "Safe, Efficient Use and Preservation of the Navigable Airspace" create significant burdens to FM stations and VHF TV broadcasters. As noted in a previous RF Report, in addition to FM and VHF TV stations, many other communications services would be affected by the proposed rules. These licenses would be required to notify the FAA when a facility supporting a radiating element of the licensee's system is constructed or modified.
NAB also argued that collecting this information will not result in any public interest benefits. "To the extent the FAA determines that its review of facility and antenna information is absolutely necessary, it could obtain such information from the FCC's databases," the association said, arguing that this redundant collection of information would violate the Paperwork Reduction Act, which, it notes, "prohibits any federal agency from adopting regulations that impose paperwork requirements on the public unless information is not available to the agency from another source within the federal government."
NAB concludes that the FAA's proposed modifications to Part 77 "will significantly increase the number of notifications that must be filed by the broadcasting industry and other targeted licensees. As a result, the proposed modifications will impose a significant burden on those licensees, without any corresponding public interest benefit. Accordingly, NAB urges the FAA to reconsider its proposed modifications to Part 77 and requests that OMB disapprove the FAA's proposed information collection request."
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