FEDERAL COMMUNICATIONS COMMISSION
June 14.2012
..JULIUS GENACHOWSKI
CHAIRMAN
The Honorable Brian Bilbray
U.S. House of Representatives
2410 Rayburn House Officc Building
Washington, D.C. 20515
DcaI' Congressman Bilbray:
Thank you for your letter expressing concern about the Commission's efforts to require
television broadcasters to post their public files onlinc - including their political files. Your Ictter
will be included in the record lor thc procceding.
Congress has mandated through the Communications Act that broadcasters have unique
public intercst obligations. including the public availability ofa broadcast station's political filc.
Transparency. accessibility and equal access are essential to scrving the public interest goals of the
Communications Act. The question that the Commission recently addressed was whether. in the 21 st
ccntury. the broadcastcrs' obligations to makc certain filcs available lor public inspection continued
10 mcan tucked in their local office filing cabinets, or available online. The Commission acted to
ensure that television broadcasters' public files. including the political files. be accessible not
just in hard-to-access physical filing cabinets. but online.
Before adopting the online filing requirement, the Commission carefully analyzed potential
costs to broadcasters. As with all paper-to-paperless conversions. the broadcasters will experience
some onc-timc upfront costs. Based on the rccord. the Commission estimatcd thcse costs at an
average of $80 - $400 per station. spread over a six month period.
This requirement not only promotcs transparency and accessibility. but based on the
rccord in this proceeding will rcsult in long-term efficiencies and cost savings for broadcasters.
Moving the lile online will minimize disruptions in the daily opcration ofa station, and rcduce the
burdens placed on station staff that currently Iield phone calls and chaperone in-person rcquests to
inspect filcs. Also. broadcasters will no longer need 10 maintain paper copies of eight routine items
that they already file with the Commission. These items compose about a third of all items in the
public file. Instead, the Commission will take responsibility for filing the material online. Evcn for
those elements of the file still managed by the broadcasters, the online Iile should be less burdensome
than a local file. becausc uploading a file will be casier and more el1icient than photocopying it.
walking it to the local paper file. finding the appropriate folder and inscrting it in the proper order.
In order to assist smallcr stations in preparing for any additional costs. the conversion 10
clectronic files will be completed in phascs. Stations affiliated with the major networks in the top 50
DMAs, roughly 200 stations out of approximately 2000 stations nationwide, must post new political
445 I2THSTREETS.W.WASHINGTON. D.C. 20554 • 202'418-1000
Page 2-The Honorable Brian Bilbray
file materials online when the rules become effective, with the rest of the industry complying by July
2014.
I appreciate your interest in this matter. Please let me know if I can be of any further
assistance.
Sincerely.
----- .
Julius Genachowski
FEDERAL COMMUNICATIONS COMMISSION
June 14,2012
JULIUS GENACHOWSKI
CHAIRMAN
The Honorable Marsha Blackburn
U.S. '-louse of Representatives
217 Cannon House Office Building
Washington. D.C. 20515
Dear Congresswoman Blackburn:
Thank you for your letter expressing concern about the Commission's efforts to require
television broadcasters to po t their public files online - including their political files. Your lelter
will be included in the record for the proceeding.
Congress has mandated through the Communications Act that broadcasters have unique
public interest obligations. including the public availability ofa broadcast station's political file.
Transparenc). accessibility and equal access are esselllial to serving the public interest goals of the
Communications Act. The question that the Commission recently addressed was whether. in the 21 st
century, the broadcasters' obligations to make certain files available for public inspection continued
to mean tucked in their local office filing cabinets. or available online. The Commission acted to
ensure that television broadcasters' public files. including the political files. be accessible not
just in hard-lo-access physical filing cabinets. but online.
Before adopting the online filing requirement, the Commission carefully analyzed potential
costs to broadcasters. As with all papcr-to-paperless conversions, the broadcastcrs will experience
some one-time upfrolll costs. Based on the record, the Commission estimated these costs at an
average of $80 - $400 per station. spread over a six mOlllh period.
This requirement not only promotes transparency and accessibility. but based on the
record in this proceeding will result in long-term efficiencies and cost savings for broadcasters.
Moving the file online will minimize disruptions in the daily operation ofa station. and reduce the
burdens placed on station staff that currently field phone calls and chaperone in-person requests to
inspect files. Also. broadcasters will no longer need to maintain paper copies orcight routine items
that they already file with the Commission. These items compose about a third orall items in the
public file. Instead. the Commission will take responsibility for filing the material online. Even for
those elemellls of the file still managed by the broadcasters, the online file should be less burdensome
than a local file, bccause uploading a file will be easier and morc efficicnt than photocopying it,
walking il to the local paper file. finding the appropriate rolder and insel1ing it in the proper order.
In order to assist smaller stations in preparing 1'01' an) additional costs. the cOl1\ersion to
electronic files will be completed in phases. Stations al'liliated \\ ith the major networks in the top 50
DMAs, roughly 200 stations out or approximately 2000 stations nationwide. must poslnew political
445 12TH STREET S W. WASHINGTON. 0 C. 20554 • 202'418'1000
Page 2-The Honorable Marsha Blackburn
file materials online when the rules become effective, with the rest of the industry complying by July
2014.
I appreciate your interest in this matter. Please let me know if I can be of any further
assistance.
Sincerely,
•
Julius Genachow ki
FEDERAL COMMUNICATIONS COMMISSION
June 14.2012
.JULIUS GENACHOWSKI
CHAIRMAN
The Honorable ClilTStcarns
U.S. House of Represcntatives
2306 Rayburn House Office Building
Washington, D.C. 20515
Dear Congressman Stcarns:
Thank you for your letter cxpressing concern about the Commission's efforts to require
tclevision broadcasters to post their public files online - including their political files. Your Ictter
will be included in the record for the proceeding.
Congrcss has mandated through the Communications Act that broadcasters have unique
public intercst obligations. including the public availability ofa broadcast station's political file.
Transparency, accessibility and equal access are essential to serving the public interest goals of the
Communications Act. The question that the Commission recently addressed was whether, in the 21 st
century. the broadcasters' obligations to make ccrtain filcs available for public inspection continued
to mean lUcked in their local office filing cabinets, or available online. The Commission acted to
ensure that television broadcastcrs' public filcs. including the political files. be acccssible not
just in hard-to-access physical filing cabinets, but online.
Before adopting the onlinc filing requircment, thc Commission carefully analyzed potential
costs to broadcastcrs. As with all paper-to-paperless conversions. the broadcastcrs will experiencc
some one-time upfront costs. Based on thc record, the Commis ion cstimated thcse costs at an
average of$80 - $400 per station, spread over a six month period.
This requirement not only promotes transparency and accessibility, but based on the
record in this proceeding will result in long-term efficiencies and cost savings for broadcasters.
Moving the file online will minimize disruptions in the daily opcration ofa station, and reduce the
burdens placed on station stafTthat currently field phone calls and chaperone in-person requests to
inspect files. Also. broadcasters will no longer need to maintain paper copies ofcight routine items
that they already file with the Commission. These items compose about a third of all itcms in the
public file. Instead, the Commission will take rcsponsibility for filing the material online. Evcn for
those elements of the file stillmanagcd by the broadcasters, the online file should be less burdensome
than a local file, because uploading a filc will bc easicr and more efficicntthan photocopying it,
walking it to the local paper file, finding the appropriate folder and inserting it in the propcr order.
In order to assist smallcr stations in preparing for any additional costs, thc conversion to
electronic file will be completed in phases. Stations affiliated with the major networks in thc top 50
DMAs, roughly 200 stations out of approximately 2000 stations nationwide. must post new political
445 12TH STREET S.W. WASHINGTON, DC. 20554 • 202-418'1000
Page 2-The Honorable Cliff Stearns
file materials online when the rules become effective, with the rest oflhe industry complying by July
2014.
I appreciate your interest in this matter. Please let me know if I can be of any further
assistance.
Sincerely,
•
Julius Genachowski