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FCC Comments

Comments on Standardized Program Reporting Requirements for Broadcast Licensees

MM Docket No. 11-189
  • and Angela J. Campbell and Laura Moy, Institute for Public Representation
January 27, 2012 |

The Public Interest Public Airwaves Coalition (PIPAC) strongly supports the Commission’s proposal to replace the requirement that television broadcasters file quarterly issues/programs (I/P) lists with a streamlined, standardized disclosure form and to create and host a database to store the information in machine readable and structured formats so that the data is accessible to the public.

After the FCC released its report on the Information Needs of Communities, which recommended adopting of a streamlined standardized form to replace I/P lists, PIPAC develop a proposal that it submitted to the Commission on August 4, 2011. The FCC has asked for public comment on this proposal.

The proposed standardized form would reduce the burdens on broadcasters by limiting data collection to two main areas: programming responsive to community issues (i.e., local news, civic affairs, and electoral affairs) and access for persons with disabilities. With respect to local news and civic affairs, broadcasters would only have to report program segments aired during two composite weeks per quarter rather than including all programming aired within specific categories. The days for the composite week would be selected randomly and would not be disclosed in advance to ensure the reliability and comparability of the data. Electoral affairs programming would only be reported during limited time periods prior to elections.

PIPAC has proposed that the standardized form also collect information on programs that do not have closed captioning, as well as those that do have video description. Providing this information is not burdensome because almost all programs are required to have closed captioning, while in contrast, stations need only provide a small amount of programming with video description at this time. This information will be extremely helpful for persons with hearing or vision disabilities and will further the FCC’s and Congress’ goals of making all programming accessible.

Having a well-designed disclosure form and database will also provide many significant benefits to the public. The standardized form will replace the current I/P lists, which have proved to be of little or no value, with information that is directly related to the core public interest obligations of broadcasters. Moreover, hosting this data at the FCC in an online database will make it much more accessible to the public and much more useful, since it will allow for easy aggregation and comparison. Standardized reporting will facilitate dialog between broadcasters and members of their community about ways to improve local news and coverage of civic and electoral affairs. Increased public participation will also help the Commission meet its licensing responsibilities under the Communications Act. The availability of reliable, standardized data that can be analyzed by journalists and researchers will reduce reliance on expensive and incomplete commercial sources of data, and increase both public participation and the quality of research utilized in the Commission’s policy making processes.

The availability of reliable, standardized data that can be analyzed by journalists and researchers will reduce reliance on expensive and incomplete commercial sources of data, and increase both public participation and the quality of research utilized in the Commission’s policy making processes.

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