1STATEMENT OF 
COMMISSIONER MIGNON L. CLYBURN
Re: Elimination of Main Studio Rule, Notice of Proposed Rulemaking, MB Docket No. 17-106
For years, you have heard me speak about the unique role broadcasters play in local communities. 
NAB President and CEO Gordon Smith reinforced this view in his 2014 Congressional testimony by 
stating that “Localism underpins each of our FCC licenses . . . Our stations demonstrate their commitment 
to this promise in times of every emergency, reminding us of broadcasters’ important role as first 
informers.” 
So I find it perplexing that those very same broadcasters are advocating to absolve themselves 
from maintaining local roots in their community of license. A broadcaster’s main studio is often the only
physical tie to a community. Broadcasters are often among the first to report an emergency, and when it 
comes to radio, that physical presence means they actually know and are experiencing first hand, what 
their local listeners want and need to hear. By tentatively proposing to eliminate the Commission’s main 
studio rule however, it seems to me that we are embracing a world in which automated national 
programming is the new normal. When the community wants to know what is going on in their backyard, 
my question is, will simulcasting fill the gap?  
Now I understand the economic challenges facing many stations, particularly in small and mid-
sized markets. And if elimination of the main studio rule is what gives that small market station with just 
five employees, the chance to keep the lights on and continue producing local programming, then I am
empathetic. But we need to think long and hard about the practical implications of eliminating this rule
altogether. 
While it is true, that with the public file now accessible online, members of the public have one 
less reason to visit a station’s main studio. And yes, a local or toll-free telephone number is a good thing,
but if nobody is there to answer that call, and the only option is to leave a voicemail, how often will it be
checked, when will that call be returned, and who is going to report if, heaven forbid, there is, say, a train 
derailment and hazardous chemicals are spilled, jeopardizing the safety of the surrounding community?
This was indeed the case in 2002, during the Minot train derailment, when it took several hours to locate 
station managers.
I thank Chairman Pai for hearing my concerns, and including a series of questions focused on 
whether eliminating the main studio rule will impact a station’s ability to communicate time-sensitive or 
emergency information to the public. The NPRM also asks at my request, whether a station’s phone 
number should be staffed during the hours in which that station is on the air. This would provide a means 
for the public and local officials to communicate life-saving information during an emergency. I am also 
grateful for the inclusion of questions on what impact elimination of this rule would have on LPFM and 
non-commercial stations.
So while I admit that I remain skeptical about moving forward with an outright elimination of this 
rule, I believe that the NPRM tees up the appropriate questions needed to build a fulsome record. For 
these reasons, I will vote to approve today’s NPRM. 
My thanks once again go to the staff of the Media Bureau for working with me to ensure that 
broadcasters remain a core part, of every local community in this country.