FCC Flooded With 'Delete' Suggestions

The Federal Communications Commission’s (FCC) “Delete, Delete, Delete” initiative, launched on March 12, 2025, under Chairman Brendan Carr, is a sweeping deregulatory effort aimed at identifying and eliminating unnecessary or burdensome FCC rules. The initiative, aligned with President Trump’s Executive Orders on deregulation, has generated significant engagement from broadcasters, who have flooded the FCC’s inbox with nearly 500 filings, proposing reforms to modernize regulations and enhance their competitiveness. 

Broadcasters, facing competitive pressures from unregulated digital platforms like Netflix, YouTube, and Spotify, have seized the opportunity to propose significant regulatory reforms. Their filings, led by the National Association of Broadcasters (NAB), state broadcast associations, and major companies like Sinclair, Nexstar, and Beasley Media Group, focus on modernizing rules to level the playing field and ensure viability in a digital-first media landscape. Key suggestions include:

Elimination of Ownership Rules:  Broadcasters, including NAB, Nexstar, Sinclair, and Gray Media, urge the FCC to eliminate the 39% cap on the percentage of U.S. TV households a single broadcast company can reach. They argue it restricts investment and scale, limiting their ability to compete with global tech giants.

Local Radio and TV Ownership Rules: The NAB’s 80-page filing, supplemented by a 60-page appendix, calls for modernizing local radio ownership rules, unchanged since 1996, which impose numerical caps on AM/FM station ownership in a market. Broadcasters argue these rules are “frozen in time” and hinder local journalism and public safety services.

The NAB and others note that digital platforms face no such ownership limits, yet reach larger audiences, while broadcasters are burdened with public interest obligations. A PwC report cited by NAB shows internet ad revenues surpassing broadcast TV, underscoring the competitive disparity.

Sinclair and NAB advocate eliminating simulcast and “substantially similar” programming requirements for the transition to ATSC 3.0 (NextGen TV), which enables hybrid over-the-air and internet-based services. They also propose setting a sunset date for ATSC 1.0 to accelerate adoption, arguing current rules slow innovation. NAB further suggests allowing software-based Emergency Alert System (EAS) solutions, eliminating the need for physical devices, to reduce costs and enhance flexibility.

Reducing Paperwork and Reporting Burdens: NAB and state associations propose eliminating or lightening online public file requirements, such as recruitment, hiring, station contracts, and political file reporting, which they call “busy work” that diverts resources from programming.

Biennial Ownership Reports: Broadcasters, including Mission Broadcasting, argue that biennial ownership reports (required under 47 CFR 73.3615) are unnecessary outside of license transfers, citing technological advancements like automated systems that reduce the need for manual reporting.

EEO Requirements: NAB suggests pruning Equal Employment Opportunity (EEO) rules, particularly audits burdensome for small stations, aligning with Trump’s executive orders rolling back DEI programs.

Eliminating Outdated Technical Rules: Mission Broadcasting and others call for repealing 47 CFR 73.1870, which mandates a designated “chief operator,” arguing that automation and reliable computer-controlled transmission systems have rendered it obsolete.

AM Antenna Efficiency Standards: NAB proposes removing minimum efficiency standards for AM antennas, which limit station reach and increase costs, as newer antenna designs offer sufficient coverage without meeting outdated criteria.

Radio Duplication Rule: The NAB seeks to eliminate the rule prohibiting commonly owned AM or FM stations with overlapping contours from duplicating more than 25% of programming, arguing it restricts operational flexibility in a competitive market.

Foreign-Sponsored Content Rules: NAB criticizes recent FCC orders on foreign-sponsored content as overly burdensome for broadcasters, who face unique compliance costs compared to unregulated platforms where misleading content proliferates.

State broadcast associations advocate a “holistic approach” to enforcement, arguing that unwritten bureaucratic practices and excessive paperwork “strangle” smaller operators and deter new entrants. They describe the regulatory environment as a “bureaucratic boa constrictor” that drives consolidation and blocks investment.

NAB calls for a shift from rigid, bright-line rules to case-by-case enforcement, which they argue would better reflect modern market realities and reduce compliance costs