Rutgers Law-Camden Alumna is Changing FCC Policy on Radio Contest Rules

Just in time for the holidays, when radio listeners everywhere could especially benefit from plush prize winnings, the Federal Communications Commission has put on its agenda this week an amendment to modernize contest rules for radio and television broadcasts.

Audience members and stations have Rutgers Law–Camden alumna Carrie Ward ’05 to thank for researching and filing a petition to update the rule first enacted in 1976. Instead of listening to contest rules read over the radio in record pace, Ward’s petition, written on behalf of Entercom Communications Corp., suggests listeners be directed to a website that would disclose the contest’s comprehensive rules. Ward says the suggestion isn’t exactly innovative, but what modern American audiences expect.

“In today’s fast-paced world, Americans expect to instantly access information at their fingertips by merely logging on to a website, conducting a Google search, or using an app on their smart phone,” she writes in the petition filed about three years ago.

Senior counsel at Entercom, located in Bala Cynwyd, Pa., Ward said the petition was filed at the insistence of Entercom’s former general counsel, Jack Donlevie.

“The rules required lengthy, boring on-air disclosures and people would just tune out. It’s a rule that affects TV as well, but right now they can put a blurb on the bottom of the screen. Radio has to list the rules on air. We would get complaints from program management, saying ‘Do we need to do this? People are tuning out.’ But it’s the law. Broadcasters get fined all the time and have to follow up.”

When the six-page petition was finally filed, the FCC put it on public notice for comment in December of 2012 and it generated more than 100 individuals who issued positive statements, all indicating that this modernized rule made sense. Now the petition is on the agenda for Friday, Nov. 21, and is expected to proceed to a rulemaking proceeding.  

“I was told that it was a Don Quixote quest,” recalls Ward, who enjoys the everyday excitement of a job that throws legal curveballs of all kinds almost on the hour. “When I researched and wrote it, I knew I was putting time into something that may not happen. Now it feels really great. The law will probably be changed and that’s really fantastic.”

Ward will return to her alma mater at 2:30 p.m. Thursday, Nov. 20, to visit a copyright law class taught by Rutgers Law–Camden Prof. Ellen Goodman, who co-chairs the Rutgers Institute for Information Policy and Law. Ward says her experience writing this petition to the FCC is definitely a teachable moment.

“Persistence is key and I never gave up. We didn’t have a lot of supporters on our side initially, but now we have strong support. We are steps away from changing law and changing the industry. Not just for my company, but the entire radio industry and television industry as well.”

Ward is excited to return to Rutgers Law–Camden, which she says was a supportive academic environment that has benefited her career. “One thing I really felt as a student was that a lot of professors came to teach after being out in the real world and gave a practical perspective to students,” she says. “Students are encouraged to get their feet wet in real world experiences and are not just reading about case law, but actually feeling what it’s like to practice in the real world, through clinics and externships, beyond just sitting in a classroom.”