NHMC Opposes Industry-Supported Plan to Eliminate Correspondence File
Broadcasters and cable associations support an FCC plan to reduce their obligations to make their facilities open to the public, but the National Hispanic Media Coalition said the FCC proposal would eliminate a “vital resource” for the public interest. The FCC NPRM proposed eliminating requirements that broadcasters keep a publicly accessible file of correspondence in their station and that cable providers keep on file the physical address of their transmission facilities. “The correspondence folder is often the most informative folder in a station’s entire public file,” NHMC said of the broadcast side of the FCC plan. “The requirement is outdated,” NAB said. “Stations receive feedback from the public in myriad ways; many of which are online, already available to the public, and not captured in the paper inspection file.” Comments were filed in docket 16-161 Friday.
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NHMC's arguments in favor of continuing to require broadcasters to allow the public into stations to examine a physical file of correspondence mirror points made by a group of Howard University professors in an ex parte filing earlier this month. The FCC's plan doesn't account for viewers who don't have access to the internet, both groups said. “By eliminating correspondence from the public file, the Commission would not only impinge on the dialogue between broadcasters and the public, but it would also prevent certain members of the community from determining if other people in their [designated market area] DMA share their concerns,” NHMC said. By pointing to online and social media posts as a replacement for a file of public correspondence, the FCC “wrongly” assumes that “all Americans have access to the internet and are comfortable participating in social media,” NHMC said.
The requirement for the public correspondence file has become “superfluous,” said broadcaster Saga. No member of the public has asked to see a Saga correspondence file in five years, Saga said. The commentary and communication between broadcasters and the public online “vastly exceeds” the correspondence that would go into the public file, said a joint comment filed by numerous state broadcaster associations. “Eliminating the correspondence file from stations’ public files will not adversely affect viewers’ and listeners’ ability to communicate with stations or to lodge complaints against them,” NAB said.
“The fact that broadband adoption is not yet universal is no reason to require every broadcaster in the country to keep publicly-available paper files containing only letters and emails at their stations,” NAB said. “The cost of compliance to stations far outweighs the very limited benefit to the public.” By transitioning all the other broadcaster public files online, the FCC already has decided online information is an acceptable replacement for analog information, NAB said.
Elimination of the requirement for cable headend addresses will improve security for cable carriers and won't adversely affect the public, NCTA said. “The general public likely has no need or interest in information regarding the designation and location of a cable system’s principal headend,” said WTA. “WTA’s members have never received an inquiry from the general public regarding the location of its principal headend,” WTA said. If the FCC eliminates the headend requirement, it shouldn't impose additional burdens on small cable operators, the American Cable Association said. Cable operators should have the option to continue complying as they do now, ACA said. Broadcast engineering firm Cohen, Dippel asked if the FCC would make cable headend information available to broadcasters as part of the repacking process, if it eliminates the filing requirement. If access to the location of the headend is not readily available, how is the task of service to the cable headend to be performed?” Cohen Dippel asked.