By now we’ve all heard about Delete, Delete, Delete (GN Docket No. 25 133)—inviting the public to identify rules, regulations, or guidance documents that should be eliminated or streamlined. Sort of a “DOGE, ME TOO”. As of the FCC’s August 7 Open Meeting, the agency has expressed its intentions to remove or modify close to 100 outdated regulations. There are roughly eight broad categories of areas for review:
- Broadcast & Media Rules
- Universal Service Fund (USF) & Broadband
- Merger Review & Administrative Burdens
- Satellite & Space Regulations
- Common Carrier, Line Discontinuance, & Recordkeeping
- Consumer & Robocall Rules
- Legal Framework & Cross-Cutting Principles
Why It Matters:
This initiative represents a rare, comprehensive re-examination of the FCC’s rulebook—targeting legacy mandates across broadcast, telecom, satellite, compliance, and enforcement. Supporters argue it reduces institutional inertia and regulatory drag. Critics warn of unchecked consolidation, weakened consumer protection, and First Amendment constraints.
Pardon My Cynicism:
The FCC’s track record with the statutorily mandated Quadrennial Review—which it has failed to complete on time for several cycles—raises doubts about its willingness or capacity to follow through on major deregulatory efforts which would include “Delete, Delete, Delete.”
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The Quadrennial Review Problem:
Under Section 202(h) of the Telecommunications Act of 1996, the FCC is required every four years to “Review its broadcast ownership rules and determine whether any of such rules are necessary in the public interest as the result of competition.”
However:
• The 2010 and 2014 reviews were combined and not resolved until 2017;
• The 2018 review got tied up in litigation and political shifts; and
• The 2022 review is still unfinished as of August 2025—three years late, and a new review cycle is technically already due.
Kinda makes you wonder, right?
Why This Matters for Delete, Delete, Delete:
The Delete, Delete, Delete initiative is not legally required, unlike the Quadrennial Review. It is voluntary, open-ended, and politically motivated, meaning:
• There’s no statutory deadline;
• There are no legal consequences for inaction; and
• It’s susceptible to FCC leadership changes, court challenges, or shifting political winds.
So, if the FCC hasn’t met its legal obligations, why expect it to act aggressively on an optional initiative? That’s the core of our concern.
Realistic Expectations:
Don’t expect, as far as we’re concerned:
• Sweeping changes to media ownership rules;
• Elimination of EEO or public file requirements; and
• Major robocall or broadband funding reforms—at least not quickly.
Political Context:
The pace and depth of deregulation under Delete, Delete, Delete will ultimately depend on:
• Who controls the FCC (the current Republican majority seems to favor deregulation);
• The outcome of the 2028 presidential election and potential legal/policy shifts; and
• How much industry lobbying and public pressure moves the needle.
If political control flips again, Delete, Delete, Delete could stall or reverse, just like we’ve seen with net neutrality or media ownership rules.
Summary:
So should we expect anything meaningful from “Delete, Delete, Delete”?
• Short-term: Yes, but mostly minor deregulatory moves;
• Mid/long-term: Only if the FCC shows it can also resolve major obligations like the Quadrennial Review, and if political alignment remains stable.
Given the FCC’s mixed track record on mandatory reviews, we can’t help but wonder how quickly or how deeply it will act on the more politically and economically charged suggestions. Nonetheless, the comment record and industry submissions demonstrate the ambition of Delete, Delete, Delete to go well beyond cleaning technical clutter.
Over the Coming Months, Here’s What We’ll be Tracking:
1. Ownership Rules & Deregulation
• Changes to national audience caps, local TV/radio ownership limits, cross-ownership rules, and elimination of the UHF discount; and
• Any movement on completing the overdue Quadrennial Review, which directly affects ownership policy.
2. Spectrum Allocations
• Potential reallocation of broadcast spectrum; and
• Actions affecting AM/FM translator allocations, LPFM, or interference protections.
3. FCC Reporting Burdens
Proposals to eliminate or simplify:
- EEO filings;
- Annual/Biennial Ownership Reports;
- Quarterly Issues/Programs Lists; and
- Public File Documentation.
So, as they say: Stay Tuned!
Co-written with my good friend Chat GPT. The sentiments are mine; any errors are his :)
That’s 30 for now…
