The 365-day rule was part of the 96 Telecom Act.
"Pursuant to this language, the Commission no longer has the discretion or obligation to consider whether a licensed broadcast station should be permitted to remain silent for periods greater than 12 consecutive months. Nor is the Commission required to initiate revocation proceedings to terminate such licenses. Instead, broadcast licenses will expire as a matter of law at the end of the consecutive 12-month period of silence, without need for any Commission action."
What PR stations are you seeing with silent periods longer than a year? I'd be interested in looking at their FCC records to see whether they're reporting their silent status accurately to the Commission - what it doesn't know, it can't enforce, after all.
(Feel free to send me a private email if you'd rather not mention calls here.)