MBA files comments to eliminate public correspondence from public files

The Massachusetts Broadcasters Association, along with other State Broadcasters Associations representing all 50 states, the District of Columbia and Puerto Rico, recently filed Joint Comments in strong support of the FCC’s proposal to eliminate the rule which requires broadcasters to maintain letters and e-mails from the public in their public files.  We made the following points:

(1)     In light of the accessibility of other means by which the public can communicate with broadcast stations, including on social media where such communications typically are preserved and publically accessible, the requirement that stations retain letters and e-mails is outdated.  We also noted that numerous broadcasters associations have made this point to the FCC in the past, so the elimination of the requirement now is, at a minimum, timely.

(2)     Because the public correspondence portion is the final vestige of the public file required to be maintained in a paper format, elimination of the requirement would enable stations to dedicate staff resources to more productive uses as well as to provide a more secure and safe work environment for their staff.

(3)     While radio stations outside the top 50 markets and those with fewer than 5 full-time employees are not required to move their public files online until 2018, the elimination of the final aspect of the physical public file may encourage them to do so earlier.

(4)     Because commercial broadcasters are the only entities required to maintain correspondence from the public in their public files, elimination of the requirement would provide for regulatory parity with other FCC-regulated businesses.