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Communications Broadcast AdvisorySpecial Advisory to BroadcastersMarch 2008CommunicationsBroadcast AdvisorythNew Comment Deadline of April 28 and Reply CommentthDeadline of June 11 Announced inthe FCC’s “Broadcast Localism” Notice of Proposed Rulemaking ProceedingWhy should you, as a broadcaster, file comments in the FCC’s “Report on Broadcast Localism and Notice of Proposed Rulemaking” in MB Docket No. 04-233 (“NPRM”)?By adopting its NPRM, the FCC has signaled to the broadcast industry that a number ofregulations that were discredited long ago are still worth recycling today. Broadcasters must actnow to halt this backward, re-regulatory slide toward a level of governmental micromanagementthat was thoroughly repudiated and discarded some 25 years ago. Given the wide and burdensomeimpact of the FCC’s proposals on al broadcasters, every broadcaster should come forth and let theFCC know how wrong-headed the proposals are.The Commission concedes, as it must, that broadcaster competition for listeners and viewers hasnever been as intense, given the explosion in the number and types of sources for information andentertainment since the 1980s when the FCC eliminated many of the requirements that thisrulemaking is looking to resurrect. However, implicit in each of the proposals advanced in theNPRM is a faulty premise, namely that even though broadcasters are keenly aware of the criticalneed to be relevant and responsive to their listeners and viewers, that ...
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