ALABAMA BROADCASTERS ASSOCIATION

2180 Parkway Lake Drive • Hoover AL 35244 • PHONE 205.982.5001 | 800.211.5189 • FAX: 205.982.0015

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ABA among group asking for changes to FCC Station Contest Rules

The Alabama Broadcasters Association has joined with all other State Broadcasters Associations in filing comments with the FCC in support of its rule making proposal that would amend the Station Contest Rule to give radio and television stations the option, in lieu of over-the-air broadcasts, of disclosing the terms of their station contents via their own websites or any Internet website that is publicly accessible. 

We argued that giving broadcasters the flexibility to choose between on-air and online station contest disclosures will better enable them to reach and inform their audiences. We also pointed out that this flexibility will also bring broadcast licensees one step closer to regulatory parity with their cable, satellite, and internet competitors, to whom the Station Contest Rule does not apply.  We urged the Commission to be careful not to unduly encumber the online disclosure option. 

Specifically, we objected to any requirement that licensees broadcast the “complete and direct” website address where contest terms are located “each time” a licensee makes any mention or reference to a station contest.  Rather, we proposed that the new rule require the announcement of the website’s home address (e.g., “wxyz.com”) only when the station affirmatively promotes the contest. 

Additionally, we urged the Commission to refrain from micro-managing stations that choose to post contest disclosures on the Internet because there is no reason for the Commission to depart from its long-standing policy of leaving the manner of disclosure to the licensee’s discretion. 

In response to the Commission’s proposal to establish record retention requirements, we argued that since the State Associations agree that station contest rules posted online should be available 24/7 during the contest, for free, and without any registration requirement (subject to technical outages and other force majeure events), we saw no reason to adopt retention requirements, particularly given that such a requirement would be better dealt with at the state level.

READ THE FULL TEXT OF NASBA COMMENTS

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