TAB urging FCC to drop letter requirement from public file

TAB is urging the FCC to eliminate the requirement that commercial broadcasters retain correspondence from the public in their public inspection files as it tentatively concluded it should in an earlier rulemaking proceeding. That measure expanded online public file obligations for broadcasters and Pay-TV and satellite radio services.

As the Commission noted itself in that proceeding, commercial broadcasters are the only entities required to maintain letters from the public in their public inspection file. Dropping the requirement would “create greater regulatory parity among entities subject to public file obligations” the agency concluded.

The move would improve security at stations while reducing staffing burdens, allowing stations with online public files to make more effective use of their staff to serve the public.

While radio stations outside the top-50 markets and radio stations with fewer than five employees in their Station Employment Unit are not required to transition to the online public file until March 2018, they may elect to do so voluntarily at any time prior to that date. By eliminating the letter requirement now, stations would have an incentive to make the move sooner, giving the public online access to that content much earlier.

Moreover, the advent of social media has generated a volume of commentary on social media sites about a station’s performance that greatly exceeds the number of letters and emails ever sent to a station and already is available online.

Eliminating the requirement is a rare opportunity for the Commission to simultaneously reduce the burden on broadcasters while benefitting the public.

Joining in the filing are state broadcast associations representing 49 other states, plus the District of Columbia and Puerto Rico.  It was prepared by TAB’s federal legal counsel, Pillsbury Winthrop Shaw Pittman.

Questions? Contact TAB's Oscar Rodriguez or call (512) 322-9944.