NAB To FCC: Eliminate The Main Studio Rule

In response to the FCC’s proposal to eliminate its main studio rule, including the related staffing and equipment requirements, the NAB offered enthusiastic support in comments.

NAB wrote: “The rule was designed to facilitate input from the community and station participation in community activities through physical access to the local studio, and was conceived nearly eighty years ago.

“Today, however, widespread use of electronic communications enables efficient interaction between stations and their communities of license without the need for the physical presence of a studio.”

In addition, the association said: “The elimination of the main studio rule and related staffing and equipment requirements will reduce regulatory burdens on broadcasters, resulting in cost savings and other efficiencies that will allow stations to better serve their audiences.”

The main studio rule was conceived at a time when physical access to a studio was likely the principal means for viewers and listeners to interact with station personnel.

“Audiences certainly had the ability to mail letters to stations,” NAB noted, “but in 1940, only 39% of U.S. households had telephones. Even when the main studio rule was most recently revised in 1998, many of the revolutionary ways in which stations and their audiences interact today had yet to be developed.

“Today’s audiences are in frequent communication with their local stations through multiple means. Stations have deployed their own mobile applications, are active on multiple social media platforms (often with multiple accounts specific to their news and weather operations) and have websites with both live and archived content.

“Audiences can and do share information with their local stations using social media, website comments, letters, emails and calls.”

NAB added that the commission also recently held that stations no longer need to maintain a paper correspondence file at their main studios, observing that the requirement was “not necessary to ensure that broadcasters comply with their public interest obligation to air programming that is responsive to the needs and interests of their community of license” particularly given that community members “can continue to communicate directly with stations by letter, email, social media, telephone, or other means.”

In eliminating the requirement, NAB said, “the commission relied on evidence that few members of the community visit stations to inspect the public file, and the fact that the volume of feedback stations receive via social media accounts, which can be viewed instantaneously by any interested party, is likely to far surpass the volume of letters and emails stations receive from the public.”