In the Matter of Modernization of Media Regulation Initiative, MB Docket No. 17-105. Joint Reply Comments filed August 4, 2017.
The Massachusetts Broadcasters Association, in combination with state broadcasters associations across the country, filed extensive Joint Reply Comments in this proceeding, which is aimed at modernizing inefficient and unduly burdensome FCC rules.
The Joint Reply Comments requested that the FCC modify its rules to allow broadcasters the flexibility to provide required public notices online rather than in newspapers or on-air, and to provide private notices like cable and satellite must-carry elections electronically rather than by certified mail.
The Joint Reply Comments also asked the FCC to (1) eliminate the annual filing of FCC Form 317, the Ancillary and Supplementary Services Report, for stations that have not provided such services in the past year; (2) eliminate the requirement that stations file FCC Form 397, the EEO Mid-Term Report, which has become redundant with information already available in a station’s online public file; (3) no longer require the filing of various contracts with the FCC; and (4) reexamine the Form 398 Children’s Television Programming Report requirement to simplify or eliminate the quarterly collection of such detailed information.
Finally, the Joint Reply Comments discussed the FCC’s EEO Rule and various ways to reduce the paperwork and regulatory burdens imposed by the rule without affecting its underlying intent, including eliminating or streamlining the FCC’s annual random EEO audits, eliminating the posting of annual EEO Public File Reports on station websites as they are already available in stations’ online public files, and eliminating the requirement that stations upload their responses to random EEO audits to their online public files.