Strategic Improvements to Media Regulations

Deregulation of broadcast television station owners has also helped highlight just how backward and outdated certain aspects of our media regulation regime really are, and therefore, how much work remains to be done. To facilitate this process, I would humbly submit a few more ideas that the Federal Communications Commission could quickly implement to improve the plight of America’s struggling broadcasters and support local journalism:

• End Freeze on License Modifications: Stations should be permitted to start filing applications for needed upgrades. 
• Update Failing Station Criteria: We should establish separate criteria, perhaps even a new process that is separate from the failing station test, for presuming certain mergers that improve local and/or live programming are in the public interest.
• Low Power Station Relocations: Limit unnecessary regulatory burdens by allowing waivers of our LPTV processing rules for in-market station moves that would otherwise be approved. 
• VHF to UHF & Communities of License Changes: Update the rules related to VHF stations seeking to upgrade to UHF channels and easing the process for television stations to change their community of license in certain cases.