In practice for near a decade. Educational Media Foundation case. City of License is a simple Post Office Box. FCC has been approving local studio waivers like free hypodermic needles and condoms for years. This rule may codify common practice.
PIFs are available in electronic form. Although CFR ‘studio’ language may have to be changed.
Unless a radio station is scrubbing along with a 1 or 2 share “Non-local origination” programming loses market ratings but does reduce costs. Particularly for AM radio.
Where have y’all been?