FEDERAL COMMUNICATIONS COMMISSION
June 14,2012
,JULIUS GENACHOWSKI
CHAIRMAN
The Honorable Roy Blunt
United States Senate
274 Rus 'ell enate Office Building
Washington, D.C. 20510
Dear Senator Blunt:
Thank you for your letter expressing concern about the Commission's efforts to require
television broadcasters to post their public files online - including their political files. Your letter
will be included in the record for the proceeding.
Congress has mandated through the Communications Act that broadcastcrs have unique
public interest 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 addre sed was whether. in the 2 Ist
ccntury, the broadcasters' obligations to make certain files available for public inspection continued
to mean tuckcd in their local office filing cabinets. or available online. The Commission acted to
ensure that television broadcastcrs' 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
co ts to broadcasters. As with all paper-to-paperless conversions. the broadcastcrs will experience
some one-time upfront costs. Based on the record. the Commission estimated thesc 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 cfficiencics and cost savings for broadcasters.
Moving the file online will minimize disruptions in the daily operation ora 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 copics of eight routine item
that they already file with the Commission. These items compose about a third of all items in the
public file. Instead, thc Commission will take responsibility for filing the material online. Even for
those elemcnts ofthc file still managed by the broadcasters. the online file should be less burdensome
than a local file, because uploading a file will be easier and more efficient than photocopying it,
walking it to thc local paper file, finding the appropriate folder and insening it in the proper order.
In order to assist mailer stations in preparing for any additional costs. the conversion to
electronic files will be completed in phases. 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 12TH STREET S.W. WASHINGTON. D.C. 20554 • 202-418-1000
Page 2-The Honorable Roy Blunt
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 Genacho\\ski
FEDERAL COMMUNICATIONS COMMISSION
June 14, 2012
JULIUS GENACHOWSKI
CHAIRMAN
The Honorable John Boozman
United States Senate
320 Hart Senate Office Building
Washington, D.C. 20510
Dear Senator Boozman:
Thank you for your leller expressing concern about the Commission's cfforts to require
television broadcasters to post their public files online - including their political filcs. Your letter
will be includcd in the rccord for the proceeding.
Congress has mandated through the Communications Act that broad asters have unique
public interest obligations. including the public availabilit) ofa broadcast station's political file.
Transparency, accessibility and equal access are essential to serving the public il1lerest goals ofthc
Communications Act. The question that the Commission rccel1lly addressed was whethcr, in thc 21 st
cel1lury, thc broadcasters' obligations to make certain filcs available for public inspection continued
to mcan lUcked in their local office filing cabinets, or available onlinc. The Commission acted to
ensure that television broadcasters' public files, including the political filcs. be acccssible 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-papcrless convcrsions, thc broadcastcrs will cxperience
some one-time upfront cost. Based on the record, the Commission estimated these costs at an
average of $80 - $400 per station, spread over a six month pcriod,
This requirement not only promotes transparency and accessibility, but based on the
record in this proceeding will result in long-term efficiencies and eost savings for broadcasters.
Moving the file online will minimize disruptions in the daily operation ofa station. and rcduce the
burdens placed on station staff that currently field phone calls and chaperone in-pcrson requests to
inspect files, Also, broadcasters will no longer need to 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 responsibilit) for filing the material online. Even for
those elemel1ls of the filc stillmanagcd by the broadcasters, the online file should be Icss burdensome
than a local file, bccause uploading a file" ill be easier and more eflicientthan photocopying it.
walking it to the local papcr file, finding the appropriate folder and inserting it in the proper order.
In order to assist smaller stations in preparing for any additional costs, the conversion to
electronic files will be completed in phases. Stations affiliated with the major networks in the lOp 50
DMAs, roughly 200 stations out of approximatcly 2000 stations nationwide, must post new political
445 12TH 5TREET 5,W WASHINGTON, DC. 20554 • 202-4' 8-' 000
Page 2-The Honorable John Boozman
file materials online when the rules become efTective, 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 Genaehowski
FEDERAL COMMUNICATIONS COMMISSION
June 14.2012
JULIUS GENACHOWSKI
CHAIRMAN
The Honorable Jim DeMil1l
Ranking Member
Subcommittee on Communications. Technology. and thc Illlernet
Committee on Commerce. cicnce. and Transportation
Unitcd Statcs Senate
167 Russell Scnate Office Building
Washington. D.C. 20510
Dear Senator DeMint:
Thank you for your Icttcr expressing concern about the Commission's efforts to require
television broadcasters to post their public filcs onlinc - including their political Iiles. Your lettcr
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 filc.
Transparency, accessibility and equal acccss are essel1lialto serving the public intcrcst goals of the
Communications Act. The qucstion that the Commission rccel1lly addressed was whether. in the 21 st
cel1lury, lhe broadcasters' obligations to make cel1ain files available for public inspection continued
to mean tucked in thcir local office filing cabinets. or availablc online. The Commission acted to
ensure that television broadcastcrs' public files, including the political filcs, be accessible not
just in hard-io-acccss physical filing cabinets. but onlinc.
Bcfore adopting the online filing rcquirement. the Commission carcfully anal)zed potcntial
costs to broadcasters. As with all paper-to-paperless convcrsions. thc broadcasters will experience
some one-time upfront COSIS. Bascd on the rccord, the Commission cstimatcd these costs at an
average of $80 - $400 per station. spread ovcr a six month pcriod.
This requirement not only promotes transparency and acccssibility. but based on the
record in this proceeding will rcsult in long-term efficicncies and cost savings for broadcastcrs.
Moving the file online will minimize disruptions in the daily operation ofa station. and reduce thc
burdens placed on station staff that currently field phone calls and chaperone in-person requests to
inspcct filcs. Also, broadcasters will no longer need to maintain papcr copies of eight romine 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. Even for
those elements of the file still managed by the broadcasters. the online file should be less burdensome
than a local file. because uploading a file will be easier and more ef1iciel1lthan photocop) ing it.
walking it to thc local paper file, finding the appropriate folder and inserting it in thc proper order.
In order to a sist smaller stations in preparing for any additional costs, the conversion to
electronic files will be completed in phases. Stations affiliatcd with the major net\\orks in the top 50
445 12TH STREET S W. WASHINGTON. DC 20554 • 202'418-1000
Page 2-Thc Honorable Jim DeMint
DMAs, roughly 200 stations out of approximately 2000 stations nalionwide, must post new political
file materials online whenlhe rules become effeclive, with the rest oflhe industry complying by July
2014.
I appreciate your interest in this matter. Please let me know if I can be orany further
assistancc.
Sinccrely.
•
Julius Gcnachowski
FEDERAL COMMUNICATIONS COMMISSION
June 14.2012
.JULIUS GENACHOWSKI
CHAIRMAN
The Honorable Mikc Lee
Unitcd States Senate
825 Hart Senate Otlice Building
Washington. D.C. 20510
Dear Senator Lee:
Thank you for your lellcr expressing concern about the Commission's efforts to require
tclevision broadcasters to postthcir public filcs online - including thcir political files. Your leller
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.
Transparency. accessibility and equal access are essential to serving the public interest goals of the
Communications Act. The qucstion that the Commission recently addrcssed was whether. in the 21 st
ccntLIry, thc broadcastcrs' obligations to makc certain filcs available for public inspection continucd
to mcan tucked in their local otlicc filing cabincts, or available onlinc. The Commission acted to
ensurc that television broadcasters' public files. including thc political files. be accessible not
just in hard-to-access physical filing cabinets. but online.
Before adopting the online filing requirement. thc Commission carefull~ analYl.cd potential
costs to broadcasters. As with all papcr-to-paperlcss conversions. the broadcasters will expericnce
some one-time upfront costs. Based on the record. the Commission estimated 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 procceding will result in long-term efficiencies and cost savings for broadcastcrs.
Moving the file online will minimize disruptions in the daily operation ofa station. and reduce the
burdens placcd on station staff that currently ficld phone calls and chaperone in-person requcsts to
inspect files. Also, broadcasters will no longer necd to maintain paper copies of eight routine itcms
that they already file with the Commission. These items compose about a third of all items in thc
public file. Instead. the Commission will take responsibility for filing the material online. Even for
those elements of the Ii Ie sti II managed b) thc broadcasters. the onlinc fi Ie shou ld be less burdensome
than a local file. bccause uploading a file \\ill be easier and more efficient than photocop) ing it.
walking it to the local paper file. finding the appropriate folder and insening it in the proper order.
In order to assist smaller stations in preparing for any additional costs. the conversion to
electronic files will be completed in phases. Stations affiliated with the major networks in the top 50
DMAs. roughly 200 stations out of approximate I) 2000 stations nationwide. must post new political
445 12TH STREET S.W. WASHINGTON, D.C. 20554 • 202-418-1000
Page 2-The Honorablc Mike Lcc
file materials online when the rules become effective, with the rest ofthc industry complying by July
2014.
I appreciate your illlcrest in this matter. Please let mc know if I can be of any further
assistance.
incerely.
•
Julius Genachowski
FEDERAL COMMUNICATIONS COMMISSION
June 14,2012
..JULIUS GENACHOWSKI
CHAIRMAN
The Honorable Rand Paul
United States Senate
316 Hart Senate Omce Building
Washington, D.C. 20510
Dear Senator Paul:
Thank you for your letter expressing concern about the Commission's el10rts to require
tclcvision broadcasters to post their public files online - including their political files. Your leller
will be included in the record for the proceeding.
Congress has mandated through the ommunications Act that broadcasters have unique
public interest obligations. including the public availability ofa broadcast station's political file.
Transparency. accessibility and equal access arc essential to serving 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 make certain files available for public inspcction continued
to mean tucked in their local omce filing cabinets, or available online. The Commission acted to
ensure lhat television broadcasters' public files, including thc political files, be accessible not
just in hard-lo-aecess 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 one-time upfront costs. Based on the record, the Commission estimated these costs at an
average 01'$80 - $400 per station. spread over a six month period.
This requiremelll not only promote transparency and accessibility. but based on the
rccord 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 chapcrone in-person requests to
inspect files. AIso, broadcasters \\ iII no longer necd to 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. Even for
those elements of the file still managed by the broadcasters. the online file should be less burdensome
than a local file. because uploading a tilc will be easier and more emeient than photocop) ing it,
walking it to the local paper file. finding the appropriate folder and inserting it in the proper order.
In order to assist smaller stations in preparing for any additional costs. the conversion to
electronic files will be completed in phases. 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 1211; STREET S.W. WASHINGTON. D.C. 20554 • 202-418-1000
Page 2-The Honorable Rand Paul
file materials online when the rules become effective, with the rest of the industry complying by July
2014.
I appreciate your interest in this mailer. 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 Patrick J. Toomcy
United States Senate
711 Hart Senate Office Building
Washington, D.C. 20510
Dear Senator Toomey:
Thank you for your Ictter expres ing concern about the Commission's efforts to require
television broadcaster to post their public files onlinc - including thcir political files. Your letter
will be included in the record for the proceeding.
Congress has mandated through thc Communications Act that broadcasters have uniquc
public intcrest obligations. including the public availability ofa broadcast station's political file.
Transparency, accessibility and equal access are essential to serving thc public interest goals of the
Communications Act. The question that the Commission recently addressed was whether. in the 21 st
century. the broadcastcrs' obligations to makc ccrtain files available for public inspcction continucd
to mean tucked in their local orficc filing cabinets. or available onlinc. The Commission acted to
ensurc that television broadcasters' public files. including the political files. bc accessible not
just in hard-to-access physical filing cabinets. but online.
Before adopting the onlinc filing requirement. the Commi sion carcfully analyzed potential
costs to broadcasters. As with all paper-to-paperless conversions. the broadcasters will experience
some one-time upfront costs. Based on the rccord. thc Commission cstimatcd these costs at an
average of $80 - $400 per station, spread over a six month pcriod.
This requirement not only promotes transparency and accessibility. but based on the
record in this proceeding will rcsult in long-term cfficiencies and cost savings for broadcastcrs.
Moving the filc online will minimize disruptions in thc daily operation ofa station. and reducc the
burdens placed on station stafrthat currcntly field phone calls and chaperonc in-pcrson requests to
inspect filcs. Also. broadcastcrs will no longer nccd to maintain papcr copies oreight routine itcms
that they already file with the Commission. These itcms compose about a third of all items in the
public file. Instead, the Commission will take rcsponsibility for filing the material online. Even for
those elements of the file stillmanagcd by the broadcasters. the online file should be less burdensome
than a local file. because uploading a file will be easier and more crficient than photocopying it.
walking it to the local paper file, finding the appropriatc folder and inserting it in the proper ordcr.
In order to assist smaller stations in preparing for an) additional costs. thc conversion to
electronic files will be completcd in phases. 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 12TH STREET S.W. WASHINGTON, D.C 20554 • 202'418'1000
Page 2-The Honorable Patrick J. Toomey
file materials online when the rules become effective, with the rest of the industry complying by July
2014.
I appreciate your interest in this mancr. Please Ict me kno" if I can be of any further
assistance.
Sincerely.
------ .
JuIius Genaehowsk i