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March 12,1996 ~~-'$'_ ~ QIJIii...~~ Federal Communications Commission ~fAlIt """'oN Washington, DC 20554 uOCKET FILE COpy ORIGINAL RE: PP Docket 96-17

Dear Sirs:

These are comments regarding the Commission's Notice of Inquiry seeking suggestions on how best to streamline FCC processes and improve its delivery services.

I am a small market broadcaster, owning 4 AM and FM stations 1n small towns in . I have been a broadcaster for some 23 years, an owner for some 14 years.

Here I S some suggestions from a small market broadcaster, on lessening the regulatory burden for small market broadcasters:

1 • Eliminate the requirement of yearly employment reports, for stations with 20 or fewer total employees. This 1S an unnecessary burden for such small markets that traditionally have a very small number of minority population. As to employment of women, most small market stations inclUding ours, have employed women in all positions for many years. This rule for markets our size, is not needed.

2. We are totally in favor of development of a short form application for simple eng1neering matters, and the elimination of the requirement for FCC approval of minor change facility changes. A simple notification to the Commission should be all that I s necessary for m1nor changes. This will save the Commission a lot of time and money.

3. We would ask for the elimination of filing yearly ownership reports, unless there I s a change 1n the ownership status. Why file a yearly report? The Commission has current information on ownership of a broad­ cast property, already on file. Why file a yearly report? Eliminate this report and again the Commission will save a great deal of time and money.

4. We favor a new FCC Form 301 which would combine the application for a construction permit and license for AM, FM and TV applications. Having to apply for a license after going thru the paperwork for a construction permit, is redundant and not using the Commission's resources wisely. Federal Comm.Commission--page 2

5. We believe there would be one 18-month window to build a broadcast property, with NO extensions. Continual granting of extensions by the Commission, agaln uses Commission staff and resources needlessly. The grantee should be ready to build a station they I ve applied for, upon receiving a construction permit.

6. We would ask that an electronic filing process for applications be offered as an option and not mandatory. We think, in the end, most broadcasters would opt for the electronic process anyway, and this would also save the Commission time and money.

7. An electronic system of reserving call letters, is a good idea, but we do not agree with outsourcing this task. Any Commission application or action, should be done by the Commission, and not outsourced.

8. An electronic system to be able to track applications electronically, either thru a computer bulletin board system or thru the FCC I S Internet web site, is an excellent idea. This will save broadcasters a lot of phone calls to the Commission, and lots of fees paid to broadcast attorneys.

In short, small market broadcasters are ln total support of the above ideas to streamline the Commission I s process of applying and licensing radio stations. We hope our comments will be taken into account, in determining which direction the Commission will go.

With limited resources, the Commission is doing the right thing ln asking for ideas on how to streamline the process, and we hope our ideas will be taken into account.

SinCerelY,! 7 :J~~/e;- E:al J. Miller President WTIM (AM) Taylorville, IL WCNL (FM) Carlinville, IL WKEI(AM)-WJRE(FM) Kewanee, IL

cc: Public file