FEDERAL COMMUNICATIONS COMMISSION
June 14,2012
JULIUS GENACHOWSKI
CHAIRMAN
The Honorable Mitch McConnell, Jr.
Minority Lcader
United States Senate
S-221 The Capitol
Washington. D.C. 205 J0
Dear Senator McConnell:
Thank you for your leltcr expressing concern about the Commission's cfforts to rcquire
television broadcasters to post their public files online - including their political files. Your leller
will be included in the record for the proceeding.
ongress 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 cssentiallO serving the public intcrest goals of the
Communications Act. The question thatthc Commission rccently addrcssed was whcthcr, in the 21 Sl
century. the broadcasters' obligations to make certain files available for public inspection continued
to meanlllcked 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 analyzcd potential
costs to broadcasters. As with all paper-to-paperless conversions. thc broadcasters will cxperience
some one-time upfront costs. Based on the record. the Commission estimatcd these costs at an
average of $80 - $400 per station. spread over a six month period.
This requiremcnt not only promotes transparency and accessibility, but based on the record in
this proceeding will result in long-term clliciencies and cost savings for broadcastcrs. Moving the
file online will minimize disruptions in the daily operation ofa station, and reduce the burdens placed
on station stall'that currcntly field phonc calls and chaperonc in-pcrson requcsts to inspect filcs.
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 rcsponsibility for filing the material onlinc. Even for those
elements of the filc 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 the local paper file. finding the appropriate folder and inselting 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 phases. Stations affiliatcd with the major networks in the lOp 50
DMAs, roughly 200 stations out ofapproximatel) 2000 stations nationwide. must post ne" political
445 12TH STREET S.W. WASHINGTON. D.C. 20554 • 202-4 I 8-1 000
Page 2-The Honorable Mitch McConnell, Jr.
file materials online when the rules become effective, with the rest of the industry complying by July
2014.
I appreciate your interest in this maller. Plea e lell11c know if I can bc orany fLll1her
assistance.
Sincerely,
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JuIius Genachowsk i