Ten-month-old proposal takes first step toward possible rulemaking.

Last January, we wrote about a proposal by Entercom Communications Corp. to change the FCC’s on-air contest rule. As we all know, that rule requires that, when a station promotes a station-conducted contest on the air, the station must disclose – on the airall the material terms of the contest.  Such disclosures can be a real drag programming-wise, even when they’re jammed into the kind of compressed super-fast babble normally reserved for extended disclaimers about sketchy products. 

Entercom has sensibly suggested that broadcasters be permitted to post contest rules on their stations’ websites, rather than subject listeners to the fine-print recitations the Commission currently requires.  (Note that the Enforcement Bureau has expressly held that, under the current on-air contest regulation, licensees may not rely exclusively on website posting of contest rules to satisfy Section 73.1216.)

Ten months after Entercom’s petition rolled in the FCC’s door, the FCC has finally gotten around to asking how anybody else feels about the proposal. If you would like to chip in your two cents’ worth, you’ve got until December 20, 2012 to let the Commission know. This invitation for comments does not mean that the Commission will for sure change the rule, or even issue a notice of proposed rulemaking (which would be a necessary step before the rule could in fact be changed). But the invitation does give interested parties the opportunity to let the Commission how they really feel about this issue. A solid show of support at this stage could improve the prospects for the eventual adoption of Entercom’s proposal.