December 22 Comment Deadline Set for FCC Proposal for Online Public Inspection File for TV - What is the Regulatory Burden?

Davis Wright Tremaine LLP
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The FCC has set the date for comments on the proposal for television stations to maintain an online public inspection file, including an online political file. Comments are due on December 22. Replies are due on January 6. Happy Holidays from the FCC! We summarized the FCC's proposals. While the proposed new rules will relieve stations from the burden of hosting the files themselves (as the FCC is proposing to host all of the files on its own servers), it still requires that stations upload their information - including all information that is put in their political file, into a new electronic reporting system to be devised by the FCC. As we described in detail in our summary of the proposal for the online public file, the FCC is asking whether certain new public file obligations should be added to those currently in place. These include possible posting of comments on programming that come from the station's social media efforts in addition to the letters and emails currently required; a proposed requirement to place in the public file information about sponsorship identification of all "pay for play" material that is broadcast on a station (currently only broadcast, not kept in any paper form); a requirement to provide information about shared services agreements and the programming that they provide to a station; and a requirement that all information about fines and other enforcement actions taken against a station be posted to the online file. So how much does the FCC think that this will cost stations?

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