FEDERAL COMMUNICATIONS COMMISSION
June 12,2012
JULIUS GENACHOWSKI
CHAIRMAN
The Iionorable Richard M. Burr
United States Senate
217 Russell Senate Office Building
Washington. D.C. 20510
Dear Senator Burr:
Thank you for your letter regarding the Commission's proposal to host online liling of
broadcaster public inspection liles. I appreciate hearing your views on this mat1er. I have asked
the Chief of the Commission's Media Bureau to respond to your concerns and I am pleased to
provide the enclosed letter.
If)ou have an) additional questions or need an) further assistance. please do not hesitate
to contact me.
Enclosure
445 12TH STREETS.W. WASHINGTON, D.C 20554 .202'418'1000
Federal Communications COlllmis Ion
Washington, D.C. 20554
June 12,2012
IN REPLY REFER TO:
CN-1200153
The Honorable Richard M. Burr
United States Senate
217 Russell Senate Office Building
Washington, D.C. 205 10
Dear Scnator Burr:
Thank you for your letter exprcssing concern about potential costs associated with the
Commission's proposal to host online filing of television broadcaster public inspection files. I
appreciate this 0ppol1unjty to address your questions and concerns. Your letter will be included
in the rccord of the proceeding.
Projectcd costs of this proposal to industry wcre part of the inquiry made in the Furtlter
Notice of Proposed Rulemaking (FNPRM). The Commission recognized that costs are likely to
vary by broadcaster, and requested detailed data from commenters on thc nature and magnitude
of both costs and public bencfits so it could achieve a proper balance between the two. 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 of $80 - $400 per
station, spread over a six month period.
After the conversion, however, broadcasters will likely realize cost savings and
efficiencies. Moving the tile online will minimize disruptions in thc daily operation of a station,
and reduce the burdens placcd on station staff that currcntly field phone calls and chaperone in­
pcrson requests to inspect files. Also, broadcasters will no longcr 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 tile. Instead, the Commission will take responsibility for tiling the
material online. Even for those elements of the file still managed by thc broadcasters, the online
file should be less burdensome than a local file, because uploading a file will be casier and more
efficient than photocopying it, walking it to the local paper file, finding the appropriate folder
and inserting it in the propcr order.
In order to assist smaller stations in preparing for any additional costs, the conversion to
elcctronic files will be completed in phases. Stations affiliated with the major networks in the
top 50 DMAs, approximatcly 200 stations out of approximately 2000 stations nationwide, must
post new political file materials online when the rules become effective, with the rest of thc
industry complying by July 2014.
Page 2-The Honorable Richard M. Burr
The complete database costs for the public file arc included in the FCC's Fiscal Year
2012 Information Technology (IT) budget. On a going forward basis, the Commission is
leveraging several improvements to its IT infrastructure, including adding cloud capacity. These
investments have lowered the costs of web-based services currently hosted by the Commission
and these cost savings will also apply to the maintenance of online files. Actual start-up costs for
hosting the public file would be less than $350,000 with an estimated out-year cost of less than
$175,000.
I appreciate your interest in this maller. Please let me k.now if I can be of further
assistance or if you would like to discuss this matter.
Sincerely,
~~~
William T. Lake
Chief
Media Bureau