On March 12, 2025, the FCC released a Public Notice1 seeking public input on identifying FCC rules that could be eliminated or modified for the purpose of alleviating unnecessary regulatory burdens. Specifically, in light of President Trump’s recent Executive Orders, the FCC seeks comment on deregulatory initiatives that would “facilitate and encourage American’s investment in modernizing their networks, developing infrastructure, and offering innovative and advanced capabilities.”2

The FCC requests that Comments identify with as much detail and specificity as possible the rule that the commenting party believes should be repealed or modified, and their rationale for their recommended action, with a focus on the following:

Cost Benefit Analysis
o Are there existing Commission rules for which the costs exceed the benefits?

Experience Gained from the Implementation of the Rule
o Has the rule proven not to advance FCC policy in the manner, or to the degree, originally anticipated?

Marketplace and Technological Changes
o Are there existing rules that have outlived their usefulness?

Regulation as Barrier to Entry
o Do certain regulations impose costs unequally on large and small businesses, or unfairly disadvantage American-owned businesses?

Changes in the Broader Regulatory Context
o Have the imposition of new rules or other regulatory requirements rendered a given Commission rule no longer necessary?

Changes in, or Other Implications of, the Government Legal Framework
o Are there rules that were based on a past FCC interpretation of statutory language that should be revisited in light of the Supreme Court’s Chevron decision?

Other Considerations Relevant to the Retrospective Review of Commission Rules
o Should there be other considerations taken into account when assessing the viability or need for a rule?

We strong urge you to consider filing comments in this proceeding should you have specific rules that you believe are burdensome and should be eliminated. Comments are due on or before April 11, 2025, and Reply Comments are due on or before April 28, 2025. If you would like to file comments or would like to discuss this issue further, please contact Dee Herman at [email protected] or Shannon Forchheimer at [email protected].
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[1] In re Delete, Delete, Delete, GN Docket No. 25-133, Public Notice, DA 25-219 (rel. March 12, 2025)
[2] Id.