REC Networks is in an unusual position on this subject as we advocate for issues that can impact smaller broadcasters as well as issues that relate to listeners, especially those outside major metro markets.
REC puts a lot of value in the concept of a public file for commercial and non-commercial broadcast stations. It is one of the few remaining links between a local radio station and the population in their community of license.
We also must take into consideration the frustration of broadcasters, especially small stations with fewer than 25 employees.
Failure to properly maintain the public file will result in substantial fines, even for non-commercial stations. Because of this, some have called the public file "the FCC's cash cow".
A balance must be struck between the burden of small broadcasters and the public interest benefits of maintaining the information.
REC feels that with many FCC rules and policy shifts over the past few decades that relieves stations of their obligation to address local public affairs issues as well as the decision to no longer enforce the Fairness Doctrine, the public file remains one of the only elements of localism remaining in radio broadcasting.
REC feels that a broadcast station's first obligation is to their designated community of license. Some public file data only needs to address the issues of the community of license. Too many broadcasters have distanced themselves from their community of license by using them just to position themselves closer to a metropolitan area using flawed FCC policies that gives these dangerous metro moves a higher priority.
REC feels the public file be placed online and the information in the online public file be streamlined. REC feels that information that is already available through the FCC's online resources (such as "The Public and Broadcasting") need not be stored at the local radio station but the station can provide a link to the FCC resource instead.
Data maintained in the public file should include: citizen agreements, materials related to FCC investigation, list of contracts (that are not already in CDBS or another resource), political file, letters and e-mails from the public (from within the community of license with last names and street addresses redacted from the online version), quarterly programming reports (related to the community of license only), time brokerage agreements, lists of donors (with street addresses redacted) and local public notice announcements. Data should be available from the station's website.
