NOTE: Comments are due June 17
The Federal Communications Commission is inviting public comment to reduce paperwork burden by proposing changes to public files kept by commercial and non-commercial radio and TV stations. LPFM stations are not required to keep a full public file but are required to keep a political file.
This proposal is not a Notice for Proposed Rulemaking (NPRM) and therefore there is docket number at this time.
Information regarding this proposal and comment filing processes can be found in the Federal Register:
http://www.gpo.gov/fdsys/pkg/FR-2011-04-18/pdf/2011-9251.pdf
REC Networks feels that public files are still necessary to maintain localism but with changes in technology, there are methods to reduce the paperwork burden as well as reduce the amount of station confusion as we have seen many cases where staff are confused about the public file and who can access the public file. In addition, we have seen cases where there are satellite and main studio waivers where the public file is at a place like a library and none of the staff knows the instructions on how to handle requests for public inspection. We even had the KCET case in Los Angeles, where a security guard refused access to the property by someone wanting to view public files during business hours.
REC's position is that a public file must be maintained and that data be filed through electronic filing so it obtains an OMB control number. Therefore, members of the general public would go online to access public file records instead of visiting the station or designated site for the Public File.
Especially for commercial radio and TV, REC feels that the public file is one of the few remaining bonds between the broadcaster and the general public who entrusts the broadcaster the right to use the radio spectrum for broadcasting.
Comments are due by June 17, 2011. This is not a standard proceeding so there is no reply comment and comments must be sent by E-Mail and can not be placed into ECFS.
