STATEMENT OF
COMMISSIONER JONATHAN S. ADELSTEIN
Re:      Standardized and Enhanced Disclosure Requirements for Television Broadcast Licensee Public 
Interest Obligations, Extension of the Filing Requirement for Children’s Television Programming Report 
(FCC Form 398) (MB Docket Nos. 00-168 and 00-44)
I am pleased to support this long overdue Report and Order to standardize and enhance the 
disclosure of television broadcasters’ efforts to serve the viewing public, particularly in the communities 
that they are licensed to serve.  This proceeding, which deals with the reporting and filing requirements of 
TV broadcasters, was launched in 2000.  While this Order is welcomed, I must note that its companion 
proceeding on the substantive public interest obligations of TV broadcasters launched even earlier, in 
1999, regrettably still remains unresolved.1  
After more than seven years of ignoring the near unanimous voice of the American people for the 
Commission to protect their right to a broadcast media that serves their interests, this Commission has 
finally mustered the courage to complete an important, but much easier, aspect of the public interest 
equation:  the TV broadcasters’ obligation to simply disclose and report their programming activities to 
the public they are entrusted to serve.
Now it is imperative that the Commission turn to the task of clarifying the substantive public 
interest obligations of broadcasters.  The need for such rules is particularly heightened given recent 
proposals to relax our media ownership rules by facilitating more cross-ownership of newspapers and 
broadcast outlets in all – not just the top 20 – media markets.  I ask my colleagues to commit to releasing 
an order on the substantive public interest obligations of broadcasters before or along with any action on 
media ownership.  
These concerns notwithstanding, I support this Order because the collection and dissemination of 
programming information can empower the American people to determine systematically the extent to 
which TV broadcasters provide local and national news, local civic and electoral affairs, independently 
produced programming, programming targeting underserved communities, and paid and unpaid public 
service announcements.  Providing such information to the American people is an important goal.  The 
American people have a right to know how broadcasters – TV and radio alike – are using the public’s 
airwaves.  This is akin to Wall Street investors receiving quarterly reports on their investments.  Lest not 
forget, the American people are the biggest investors in the broadcasting industry. 
In today’s Order we take modest steps, requiring TV broadcasters to file a standardized 
“issues/programs” list form with the Commission on a quarterly basis and to make their public inspection 
files available on the Internet.  I do not believe the adoption of the standardized disclosure form herein 
implicates any constitutional protections or encourages homogenization of television programming.  The 
FCC has clear legal authority to require broadcasters to disclose information that they are already required 
to maintain.2  
  
1 See Public Interest Obligations of TV Broadcast Licensees, Notice of Inquiry, MM Docket No. 99-360, 14 FCC 
Rcd 21633 (1999).  For the public interest obligations of radio broadcast licensees, see Digital Audio Broadcasting 
Systems and Their Impact on the Terrestrial Radio Service, Second Report and Order, First Order on 
Reconsideration and Second Further Notice on Proposed Rulemaking, (MM Docket No. 99-325, 22 FCC Rcd 
10344, 10391 (2007). The Commission has failed to act on either proceeding.
2 See, e.g., 47 C.F.R. § 73.3526(e)(11)(i)(requiring broadcasters to prepare and maintain in a public file a quarterly 
list of that station’s most significant treatment of community issues).
Today’s Order continues to “provide television broadcasters with increased freedom and 
flexibility in meeting the continuously changing needs of the communities.”3 Broadcasters will continue 
to be able to diversify their programming, and I strongly encourage them to do so.  Additionally, because 
of the burgeoning use of the Internet by the public and broadcasters, today we enhance the public’s ability 
to access information on a station’s performance, while minimizing the costs and burdens placed on each 
station. 
I would like to thank the Office of Communication, Inc., of the United Church of Christ, Alliance 
for Community Media, Association of Independent Video and Filmmakers, Benton Foundation, National 
Organization of Women, Consumers Union, Minority Media and Telecommunications Council, National 
Association of the Deaf, and particularly Angela Campbell, Meredith McGehee, Andy Schwartzman, 
Mark Lloyd and Charles Benton for their guidance and perseverance.  
  
3 Revision of Programming and Commercialization Policies, Ascertainment Requirements and Program Log 
Requirement for Commercial Television Stations, 98 F.C.C. 2d. 1046, 1107 (1984).