FCC Chairman Brendan Carr asked for ideas to cut outdated broadcast regulations – and the NAB has now given him plenty to work with. In an 80-page filing backed by a 60-page appendix, the NAB delivered a sweeping blueprint for deregulation under Carr’s “Delete, Delete, Delete” initiative, targeting everything from local ownership caps to Equal Employment Opportunity requirements.
“This is a moment for bold ideas, and NAB is proud to lead the charge,” said NAB President and CEO Curtis LeGeyt. “The FCC’s rules should reflect today’s media landscape, not one from decades past. Our filing lays out a clear, actionable path to modernize regulations and empower local radio and TV stations to better serve their communities. We appreciate the Commission, especially Chairman Carr, for launching this important effort. Reforming outdated ownership rules is the essential first step to strengthening local journalism and ensuring broadcasters can continue to survive.”
At the top of NAB’s list is a demand to abolish local broadcast ownership rules that restrict how many radio and television stations a company can own in a single market. NAB argues that these caps were created in the analog era and have no place in today’s vastly expanded media environment. “No broadcast regulations are more devastating to the viability and future vitality of TV and radio broadcasters than the national TV ownership restriction and the local radio and TV ownership rules,” NAB wrote.
Deletion of the ownership caps is viewed as a non-negotiable for NAB, saying on page 14, “Despite the insightful ideas that follow… THE FCC SHOULD NOT PROCEED UNTIL IT ELIMINATES THE NATIONAL TV AUDIENCE REACH CAP AND THE LOCAL TV OWNERSHIP RULES AND SIGNIFICANTLY MODERNIZES THE LOCAL RADIO OWNERSHIP RULES.”
As for those other ideas, in tandem with ownership deregulation, NAB is urging the FCC to modernize or scrap the Online Public Inspection File rules, describing them as outdated and disproportionately burdensome for broadcasters, as uploading thousands of documents to comply with OPIF requirements diverts manpower from critical operations.
The NAB also targeted the expanded Foreign Sponsorship Identification rules, which broaden disclosure requirements for political advertisements and public service announcements. Calling the expansion unnecessary, NAB emphasized that existing rules already sufficiently ensure transparency without the need for further red tape.
Ownership reporting requirements also came under fire. NAB asked the FCC to eliminate the biennial ownership report mandate in favor of a requirement to file updates only when a material change in ownership occurs. According to NAB, the current filing schedule burdens small broadcasters who often report no changes at all.
In addressing employment-related regulations, NAB called for a full overhaul of the FCC’s Equal Employment Opportunity framework. The group advocated ending the practice of random annual EEO audits, eliminating the requirement to notify entitled organizations of every job opening, scrapping the mandate that broadcasters conduct a set number of outreach initiatives every two years, and discontinuing the controversial Form 395-B employment report. NAB criticized the system as ineffective and punitive, writing, “The EEO rules create an intricate Rube Goldberg machine that prolifically produces paper while fecklessly failing to promote EEO hiring.”
In addition to cost concerns, NAB pointed to major legal questions surrounding the FCC’s authority to apply certain EEO requirements to radio broadcasters at all. They argued that the Communications Act of 1992 addresses only television stations, noting, “Section 334 says nothing about radio.”
Technical rules were also a major focus of the filing. NAB reiterated its call to eliminate the Telephone Broadcast Rule, which requires broadcasters to obtain consent before airing a recorded phone conversation. NAB contended that the rule places broadcast journalists at a disadvantage compared to podcasters and social media content creators who are not subject to the same restrictions.
Similarly, NAB renewed its argument to eliminate the FM Duplication Rule, which limits how much content two commonly owned FM stations in the same market can share. The rule was brought back in 2024 at the petition of the musicFIRST Coalition, which many in the industry viewed as retaliation for resisting musicFIRST’s push for the imposition of a new performance fee on local radio. The association said that real-world experience since the FCC last repealed the rule showed no harms materialized, while reinstatement only creates unnecessary barriers to operational flexibility.
For AM broadcasters, NAB called for the deletion of minimum efficiency standards related to antenna height and ground system requirements, saying those technical standards restrict station flexibility and increase costs. They also advocated for removing restrictions that complicate licensing new AM stations in the 1605–1705 kHz expanded band, noting that no filing windows for expanded band applications have been opened in more than two decades.
Emergency Alert System rules were another major area where NAB pushed for modernization. The association asked the FCC to allow the use of software-based EAS encoder/decoder systems, arguing that reliance on physical hardware is costly and outdated. NAB also called on the Commission to clarify vague and overly broad false alert rules, stating, “The FCC’s false alert rule can inhibit broadcasters’ airing of content that may well be permissible.” They additionally urged the agency to abandon pending proposals to make Disaster Information Reporting System filings mandatory and to require multilingual EAS alerts, which NAB said would create confusion without measurable public safety benefits.
The longstanding Contest Rule, which requires broadcasters to disclose all material terms of station-sponsored contests on air or online, was also criticized. NAB argued the rule is duplicative of existing Federal Trade Commission and state-level consumer protection laws.
Beyond codified rules, NAB asked the FCC to formally rescind several informal policies. Chief among them is the FCC’s news distortion policy, which discourages staged or falsified news broadcasts but, according to NAB, is outdated and constitutionally questionable. “The news distortion policy impermissibly chills speech and discourages coverage of important public issues,” NAB wrote.
Finally, NAB asked the FCC to close its pending proceeding considering mandatory disclosure of artificial intelligence use in political advertising. The group warned that such requirements would be vague, burdensome, and ineffective, stating bluntly, “The FCC should CLOSE this proceeding without taking any further action and hopefully forget this was even a thing.”
NAB’s filing closed with a warning: without sweeping regulatory reform, particularly the elimination of national and local broadcast ownership restrictions, the future viability of TV and radio broadcasters is at risk. While broadcasters continue to deliver local news, music, and live entertainment to their communities, NAB argued that they do so under the crushing weight of outdated and unnecessary regulations. “Far from serving the public, these requirements often strain already resource-constrained local stations,” the association concluded, urging the FCC to act decisively to level the competitive playing field.
The full filing can be viewed here.
NAB Submits Sweeping Broadcast