The FCC has continued this week on its recent tear of fining broadcast stations and other regulated entities for violations of FCC rules – in the last week proposing fines or reaching consent decrees relating to issues including incomplete public files, EAS violations, unauthorized transfers of FM translators, and tower lighting issues, among others. But a fine issued to a station a few weeks ago merits further review as it provides some more clarity as to what the FCC requires from a broadcast station’s "main studio." In this recent case, the FCC proposed a $21,000 fine to this broadcaster who allegedly did not have an adequate main studio or public file, and for operating its AM station after sunset with its daytime facilities.
What do the FCC main studio rules require? Currently, all full-power broadcasters (including Class A TV stations, with the limited exception of satellite television stations and some noncommercial radio satellite stations who may operate with main studio waivers) must maintain a studio either within its city of license, or at another site either within 25 miles of its city of license or within the city-grade contour of any station licensed to the same city of license as the station. As set out in Section 73.1125 of the FCC rules, no matter where the studio is located, local residents must be able to reach the station by a toll-free telephone call. The rule, however, does not specifically state what must be at the main studio – those rules are either found elsewhere in the FCC rules or have been developed by caselaw.