Does the "Main Studio" Rule really need to be eliminated?

The FCC meets today at 10:30 a.m. in Washington, DC. On the agenda is a Report and Order eliminating the rule that requires radio stations to maintain a "main studio" located in or near its community of license. The NAB, and most broadcasters, say that rule must go. Franklin Raff is one broadcaster who says that’s a big mistake…

Story by Radio Ink
Written by RaffRadio's Franklin Raff

Fifteen years ago in Minot, North Dakota, a train carrying caustic chemicals derailed, releasing deadly gas. Police tried to contact local radio stations to warn the public, to no avail. EAS failed. Phones went unanswered in the empty studios and offices of six radio stations – owned by one company – as a thousand people were injured and one died. Desperate citizens tuned in; satellite-fed deejays kept the hits coming.

The new ruling will read: The dereliction of the group in Minot was deemed a freak lapse in corporate responsibility and a gross violation of FCC regulations, namely the long-standing "Main Studio Rule" requiring stations to have a responsive physical presence in or near their communities. All of that is about to change. The FCC now says it’s time to abolish the Main Studio Rule, ending even the ability of station operators to originate programming.

Eliminate existing requirements associated with the main studio rule, including the requirement that the main studio have full-time management and staff present during normal business hours, and that it have program origination capability.

The FCC has always maintained stations “must serve the needs and interests of the communities to which they are licensed.” The new logic is that by "Eliminating The Cost" of being in their communities, stations will be better able to serve their communities. But experience shows, of course, stations leave and don’t return. “Community presence” means tower lights on the skyline and the station ID at the top of the hour.

According to the FCC:

The Commission first adopted main studio requirements in 1939 to ensure that stations would be accessible and responsive to their communities. However, a local main studio is no longer needed to fulfill these purposes.

How can a broadcast facility be “accessible and responsive to its community” when it is not in the community, is not a facility, and cannot broadcast?

Many broadcast studios are long-abandoned. Few groups even have a receptionist. These are cost-cutting measures, and efficiency is good. But let us see these trends in context. Our industry is in the hands of very few players: two companies now own half of our country’s stations.

As we know, the well-intentioned 1996 Telecommunications Act changed ownership rules so that near-monopolies could exist in most markets. It was billed to increase profitability and enhance consumer choice. The result was also a decline in local service and — not coincidentally, for a medium whose unique selling proposition is local service — audience share and revenue. The “better for the consumer” part – “competition” – meant drastic programming cuts. Local radio came to offer what emergent smartphones and satellite radio did – along with interminable commercial breaks.

Let’s zoom out. Stations are licensed to serve local communities for commercial benefit. Licenses granting significant power and coverage at desirable frequencies are enormously valuable. They are generally held by the same interests who pushed for deregulation and who now, again citing competition, want to ditch the Main Studio Rule.

Fair competition entails rules. If a broadcaster cannot profitably fulfill FCC-mandated obligations, instead of lobbying to change them, should it not sell the station? The FCC recently released a flurry of low-power FM licenses. Many of these stations, with transmitters emitting as much power as a light bulb, manage to maintain “staff present during normal business hours” and “program origination capability.” Why can’t the big boys do it?

We have all seen, through the arc of deregulation and the rise of the Internet and smartphones, a decline in terrestrial radio listenership. Syndication and homogenization was good for short-term profitability but radio’s best position against media competitors withered just when it was needed.

Now, after years of regurgitating the sort of impersonal, cookie-cutter audio we associate with streaming services, disaster event listenership and news/talk ratings trends confirm a strong demand for the intimate “localism” we do best. This is our time to shine. Why would we want any part of our public-service mandate and unique selling proposition – localism – to be extinguished?

By absolving radio owners of local obligations, the FCC will help owners cut costs. That’s a good thing for the owners. Market forces and experience indicate it will also open up even more opportunities for local content providers in less-regulated, less-reliable, less-ubiquitous media: Not so good for listeners, or radio, in a time of crisis or any other time.

When this next cost-cutting binge is over, when the winners in this deal cash out and Minot becomes a tragic prophesy, why would anyone rely on radio?

Franklin Raff was a General Manager in the radio business by the age of 20. He’s worked in both major markets and unrated markets. He can now be reached at franklin@raffradio.com or (212) 203-2100