Subject: Comments on OMB Control Number: 3060-0214
Re: Proposed changes to Sections 73.3526 and 73.3527, Local Public Inspection Files; Sections 76.1701 and 73.1943, Political Files as part of the Paperwork Reduction Act.
I am a radio programming consultant based in the Los Angeles area. My experience in the broadcast industry extends back to 1973, including close to twenty years in various capacities at stations throughout Southern California. At several times during my career, I have found myself responsible, either wholly or in part, for the maintenance of the station Public Inspection File (PIF).
In the nearly 40 years I have spent in the broadcast industry, I have never found myself in the position of fulfilling a PIF inspection request, other than for FCC employees. It is my sad observation that the general public is overwhelmingly ignorant of the existence of the PIF at every FCC-licensed broadcast facility. However, the existence of the Internet is universally known, and it is my position that it would be better for all concerned if stations could maintain the PIF in electronic form.
An electronic PIF could be mandated by the FCC to be available to the public as part of each station's website; one would be hard-pressed to find a station without such a website in this era of universal online access. This would not only facilitate easy access by the public, it would relieve station licensees from the burden and expense of making hard copies of the PIF contents for those requesting same, since virtually all such requests could be fulfilled using the requester's own computer equipment.
Moving the PIF to an electronic, universally acceptable format would also allow for more effective enforcement by the FCC of the Rules regarding same, since a physical presence at the station offices would no longer be required to view the PIF. Only when a violation was perceived would inspectors need to visit a station in person.
To take some examples of how easily some of the required PIF content could be made available online:
An electronic PIF would be less of a human resource expense for both the FCC and the licensees, and also less time-consuming. There would also likely be a much higher compliance factor, given the knowledge that the FCC would have the ability to review the PIF remotely, at any time.
- The local issues list could be a Word or Excel file that could be edited and uploaded to the server for anyone to download and read.
- Letters from the public could be scanned into the Adobe Portable Document Format (PDF) and made available for viewing in that format. (I would, however, urge the removal of personal address and telephone numbers from the online-accessible versions of such letters, lest there be privacy concerns.)
- The required document "The Public and Broadcasting" is already available, in both HTML and PDF, at the FCC's website and could be linked to at that location.
- Copies of the station license, etc., could also be scanned into PDF.
Respectfully submitted for the Commission's consideration,