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College broadcasters to FCC: we need more time on indecency proceeding

CBI conferenceCollege Broadcasters Inc has asked the Federal Communications Commission to extend the    deadline on its proceeding on indecency enforcement. The organization represents hundreds of college and high school radio and TV signals, plus student webcasters. CBI has filed comments with the FCC asking the Commission to take a kinder and gentler stance towards student run stations, given the consequences of a full FCC indecency fine on a cash strapped college signal.

The advocacy group now requests a 15 day extension. The current deadline is July 18. CBI writes:

CBI and its FCC-licensed members are particularly interested in the outcome of this proceeding given their extreme vulnerability due to their limited budgets, the nature of their staffing and potential for their parent institution holding the license to sell or abandon a license due to an indecency complaint, regardless of the validity due to the cost involved of having to defend itself against such a complaint, makes it integral that they have an opportunity to actively participate. Thus in light of the foregoing concerns, academic calendars — many students involved with their student-run stations are now on summer break — and the sheer volume of comments to reply to, granting this modest extension is reasonable and proper and will help ensure that those affected by FCC policy have adequate opportunity to participate in shaping it.

CBI has put out an action alert to its members, urging them to file statements with the Commission on the indecency enforcement question. The group recommends that filers look to comments to the FCC made by UC Riverside station KUCR as a template:

KUCR is concerned, however, that with all the training, all the precautions, all the goodfaith, intelligence and devotion of our volunteer staff, and an 8-second delay – with all of that – accidents may still occur. For KUCR, with its small budget, an indecency fine would be catastrophic. The legal costs of responding to an FCC inquiry would be crippling, even if no fine were imposed. Clearly, the maximum $325,000 per incident fine is meant to chasten a corporate broadcaster who may have previously viewed a mere $32,500 fine simply as a cost of doing business by providing a racy language edge in the competitive world of drive-time morning zoo sensationalistic commercial radio. A fine of this magnitude might cause the CEO of a Fortune 500 broadcaster to restrict language for bottom-line interests. However, not all broadcasters are Fortune 500 companies. Many are small NCE stations with large volunteer staffs and lots of specialized programs running 24 hours a day, 365 days a year. KUCR is terrified that something unintentional may go over the air, resulting from a misunderstanding, a mistake, a spontaneous remark that inadvertently lets an indecent word or phrase slip though. For a small NCE broadcaster that momentary lapse is not an expensive cautionary lesson, but is fatal to its entire operation and to the valuable local service that a “hand-made” broadcaster such as KUCR provides. The punishment for a small broadcaster in no way fits the violation. In fact, it ultimately punishes the local community that supports the station.

Student broadcasters can submit brief comments at http://apps.fcc.gov/ecfs/upload/display?z=xk7vd. The “proceeding number” is 13-86. For a longer filing use http://apps.fcc.gov/ecfs/upload/display?z=q3ljm.


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  1. FCC Extends Deadline for Indecency Policy Comments | Radio Survivor - July 15, 2013

    […] the FCC released a letter announcing that it would honor College Broadcasters Inc.‘s (CBI) request to allow more time for the public to file comments regarding the broadcast indecency policy […]

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