TAB submits public file commentsposted on 3.18.2015
TAB joined NAB and the other state broadcast associations in filing comments on the FCC's online public file proceeding.
The major points contained in the comments are:
(1) having required TV broadcasters to maintain an online file, the FCC should require the same of MVPD TV competitors (cable and satellite);
(2) given the differences in staff size, etc., and the sheer number of stations affected, the FCC must recognize the differences between TV and radio in implementing a radio online public file rather than just unthinkingly imposing the same rules on radio as were imposed on TV;
(3) the FCC should phase-in any requirement by starting in the Top 50 markets before later expanding beyond that;
(4) rather than temporarily exempt stations with less than five full-time employees, the FCC should permanently exempt Station Employment Units with ten or fewer full time employees, consistent with the FCC’s exemption standard for Midterm EEO Reports and certain other EEO obligations;
(5) exempt stations should be permitted to voluntarily move their public files online if they elect to do so, and the FCC should modify its rules to incentivize stations to make that voluntary move by offsetting the regulatory burdens involved;
(6) the FCC should examine and strengthen its filing systems to ensure they can handle the added load more online public files will bring;
(7) the FCC should extend its ten-day quarterly filing windows to thirty days to reduce the burden on both the system and filers by spreading out the number of filers on any particular day; and
(8) the FCC should not use this proceeding to expand broadcasters’ public file obligations, but instead focus on implementing online public file requirements that are practical, functional, and not harmful to smaller stations.
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