tinitcd ~tatcs ~cnetc WASHINGTON, OC 20510 April 3, 2012 The Honorable Juhus Genachowski Chairman Federal Communications Commission 445 12th Street SW Washington, DC 20554 Dear Chairman Genachowski: We are aware the Federal Communications Commission (FCC or Commission) may soon vote on a proposal to increase regulation on television broadcasters by requiring them to post their political records online. As we understand it, your proposal would require broadcast television licensees to upload hundreds of thousands of documents containing commercially sensitive data, includ.ing advertising rate information, to a database centrally managed and monitored by the Commission. We are writing to express our serious concerns with your proposal. To create accountability to their local audiences in exchange for being granted free use of spectrum, broadcasters have been required by starute for more than 40 years to maintain and make available to the public an inspection flie, including correspondence from the public, hiring practices, and programming of local interest. These flies give a general sense of how broadcasters are serving their communities of license. In 2002, the political record requirement, more related to campaign spending transparency than localism, was added to the public inspection ftle mandate. Your proposal appears to be excessive and unnecessary in light of the fact that all of this information is made available today at broadcast stations across the country. The transfer of these files to an online database does not appear to enhance localism or provide benefits to justify the regulatory and competitive costs likely to result from the effort. In fact, the FCC exempted political files from online posting requirements in 2007 because it found the burdens outweighed the benefits. Given these issues along with the heavy compliance costs that would have to be borne by the broadcasters and the limited benefit that would be realized, we ask that you reconsider this proposal and maintain the rules as currendy constimted. Sincerely, 0462 Senator Pat Toomey Senator Rand Paul