FCC Main Studio Elimination Effective January 8, 2018

The waiting has finally ended. The FCC’s action eliminating the main studio rule was finally published in the Federal Register, which started the 30-day clock on the rule becoming effective. As a result, on January 8, 2018, broadcast stations will no longer be told by the government that they must maintain a broadcast studio and man it with two full-time employees as a condition of holding a broadcast license. Just to let that sink in a little, that rule dates back to 1939. Nearly 80 years (ok, 78 to be exact).

Earlier this month, in an email exchange with an FCC staffer during which we were trying to glean when publication would occur, we learned that the staff was having some difficulty coming around to the elimination of the main studio rule. So deep was their melancholy that they were contemplating having a “memorial service” of sorts on January 8^th. With great empathy (ahem), we offered to give a eulogy, and the response was that we would have to take a number. Not to be outdone or relegated to the rear of the eulogy line, we offered a written poem as a proposed eulogy and were told that it moved us to the very top of the eulogy list. And so, we thought it appropriate to share our Ode to a Dying Rule. It was written from the FCC staff’s perspective, so we hope they will read it out loud as the first eulogy on January 8^th.

Ode To A Dying Rule

Here’s to that school

Of the main studio rule

Those lawyers, owners and FCC staff

Who used maps and calculators to do the math

To pinpoint the location of the studio

Where two full timers hung out, so

People could come by, or not;

Programs could originate, or be brought.

Farewell main studio rule

Our comfort, our cool

Remember not how we waived you

Twas something we had to do

Carry on, old friend

We’ll see you around the bend

In that sacred place for the best

Where regulations go to rest.

Don’t forget to maintain a toll-free telephone number (not necessarily a 1-800 number, but one that does not charge the caller) in the community of license so that the public can reach you without incurring a long-distance charge. Plus, even without a main studio, you must still use your community of license for determining the issues affecting your community to address in your programming, all as part of your continuing obligation to prepare quarterly issues/programs reports addressing the station’s most significant treatment of issues in the station’s community of license. One final note – if you eliminate your studio before you’ve transitioned the station public file to the online FCC portal, you must still make your paper public file available at a business or establishment open during normal business hours in our community of license.