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NYSBA to FCC – Get Rid of Unnecessary Regulation


NYSBA, along with other state broadcast associations, filed comments in the FCC’s “Delete, Delete, Delete” proceeding.  Importantly, this proceeding merely asks for the types of regulations that should be examined.  Nonetheless, it is an important exercise to establish which rules should be considered.  The comments asked the FCC to modify the following rules:


EEO: The FCC should eliminate its regulations seeking to micromanage the recruitment, hiring, and promotion of broadcast employees.  This includes all the associated EEO recording, keeping, and reporting requirements found in §73.2080(b), (c), (d), (e), (f), and (g) of its rules.


Filing Station Contracts: The FCC should eliminate the filing of station contracts and the reporting requirements in §73.3613 and related rules.


Public File: The FCC should eliminate from the public most or all documents that are not currently automatically inserted by the FCC. Including:


  • Quarterly Issues Programs Lists should be eliminated      

  • The Annual EEO Public File Report and Associated Audit Response filing requirements should be eliminated 

  • The requirement to file biennial ownership reports should be eliminated            

  • The detailed reporting of children’s television programming preemptions


Again, these comments merely help “set the table.” For these rule changes to take place, the FCC must commence additional proceedings on each rule.


You can see the comments of state broadcast associations here.

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