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At its open meeting earlier this week, the FCC adopted a Notice of Proposed Rulemaking proposing changes to the public file rules for both broadcasters and cable systems. For commercial broadcasters, the FCC proposed to eliminate the requirement that they include in their public file copies of letters and emails to the station concerning station operations. For cable systems, the FCC proposed to eliminate the obligation to include in their file documents disclosing the location of their headend. What do these proposals mean for broadcasters?

Most of the broadcaster focus has been on the proposal to delete the obligation that commercial broadcasters keep a correspondence folder in their public inspection file for letters and emails from the public commenting on the operation of the station (the requirement has never applied to noncommercial broadcasters). Those files are supposed to contain, in a physical file at their main studio, all of the correspondence that stations receive from viewers or listeners (allowing broadcasters to omit correspondence that listeners asked to be kept private, and correspondence that contains offensive material). For TV stations that have already converted to an online public file for all of their other public file documents, and for radio stations who will soon be doing so (see our posts here and here on the upcoming obligation of radio to convert to an online public file), these letters will be the only remnant of the public file that must still be maintained at the main studio. The FCC tentatively concluded that the obligation to keep these letters and emails was no longer necessary.
Continue Reading FCC Proposes to Eliminate Public File Obligations – No More Letters from the Public for Broadcasters, No Cable Headend Information for Cable Systems?

Yesterday, the FCC announced its agenda for its May open meeting to be held on May 25. Among the items on the agenda is a proposal to adopt a Notice of Proposed Rulemaking looking to abolish the obligation that broadcasters maintain in their public files copies of letters and emails from the general public about station operations. These letters are the last vestige of the physical public file for TV broadcasters who several years ago migrated the rest of their public file to an online system maintained by the FCC (see our summary of the TV online public file obligations here). The letters from the public were deemed too sensitive to put online, as they could reveal private information about the writers of those letters. Thus TV stations must still maintain a paper file at their main studio. Radio broadcasters too will soon be moving their public files online. In the order adopting the requirement for an online public file for radio (see our summary here), the FCC proposed that the same paper system for letters from the public be maintained. However, it did note that there were calls to abandon entirely the requirement to maintain these letters in a separate file, and promised to initiate this rulemaking to look at that issue.

Commissioner O’Rielly has been a major proponent of that change, tying the issue to one of the security of broadcast stations and personnel. In his concurring statement to the Online Public File order, he noted that the abolition of the requirement that broadcasters maintain these letters from the public would eliminate the need for many broadcasters to open their stations to all comers who enter on the pretext of inspecting the public file. In a blog post, he noted the need for security at broadcast stations. The recent events at Sinclair’s Baltimore TV station, where an individual with emotional or mental issues triggered a police shoot-out at the station, and last year’s tragedy involving the Roanoke TV crew, highlighted the very real threats to safety that broadcasters face every day. Minimizing these threats by removing one pretext for people to enter broadcast studios unchallenged is an important consideration in these deliberations.
Continue Reading FCC To Consider Abolition of Requirement that Broadcasters Maintain Letters From the Public in their Public Files – Moving Toward the End of the Physical Public File?

How to deal with a noncommercial radio station’s public inspection file when the station is licensed to a college and has a main studio in a restricted-access student residence hall is a question that I have received repeatedly when I have conducted sessions on FCC rules at noncommercial broadcasters’ conventions and meetings.  In a consent decree reached with a college and announced by the FCC on Friday, the FCC’s Media Bureau has suggested how this issue should be dealt with – by asking for a waiver of the Commission’s rules to allow the file to be maintained at another campus building which has access for the public during normal business hours.

In that case, the Bucknell University station had its main studio in a residence hall not open to the public, and it kept its public file at the student center, another campus building to which the public had access.  While the station posted a sign at the entrance to the residence hall where the main studio was housed that the public file was at the student center, and instructed campus security that this was where anyone who asked for the file should be directed, the college had not asked the FCC for a waiver of Section 73.3527(b)(1),  which requires that the public file of a noncommercial station be kept at the main studio of the station.  In the Consent Decree, the FCC agreed to waive the FCC rules to allow the public file to remain at the student center location, balancing the needs of the public for access to the file with the security needs of the college.  Nevertheless, the licensee made a $2200 “contribution” to the US treasury for not having previously asked for a waiver of the rules to locate the files at a location other than its main studio, and for also failing to include in its files Quarterly Issues Programs lists for several years during the license renewal term in which these issues arose.
Continue Reading The Location of the Public Inspection File of a College Radio Station When the Station’s Main Studio is in a Building Not Open to the General Public Addressed in FCC Consent Decree