A letter to the FCC regarding broadcasters' public files

Posted by Mitchell - May 29, 2011 (entry 673)

To whom it may concern,

It has come to my attention that the FCC is considering the abolition of the public file requirement for radio and television broadcasters. I am writing today to object to this proposal. I think the FCC should maintain its public file requirement -- better yet, I think that requirement should be _expanded_ to putting public files online in PDF or one or more searchable file formats. But in this letter, I would like to offer my opinion and experience on the matter for the FCC's benefit.

I make my living as a software developer, but I have been active in grassroots media policy activism for nearly a decade, mostly with the group Chicago Media Action (online at www.chicagomediaaction.org). In my involvement with Chicago Media Action, I have reviewed public files in the past in Chicago and elsewhere. I've even made a short film about a public file viewing at the St. Louis CBS affiliates KMOX and KMOV for a television show I help produce (the film is online here: http://www.audiovideoweb.tv/CITV/E12-part1.html, and a radio segment about the visit is online here: http://www.freepress.net/node/33827).

I have found that viewing a public file is always an informative experience, and it is quite the education every time I view a public file for different (and usually shocking) reasons with each viewing. I have seen reams of email printouts castigating Dan Rather in the 2004 controversy that forced Rather to resign from CBS. I have seen Chicago's WGN-TV claim three weekly episodes of the TV show Sabrina the Teenage Witch for half of its youth education programming requirement. I have seen from WFLD, Chicago's local FOX affiliate, a list of headlines from its local news broadcast which was so laden with stories about killings and shootings the list was practically indistinguishable from that of a police blotter (one headline that I remember from that list read "Opera Singer Stabbed"). If anything, the public file requirement should be maintained so that there can exist this chronicle of the rampant irresponsibility to the public interest of commercial broadcasters. It's little wonder that many broadcasters want to have the requirement abolished, and I am heartened that the FCC has taken the matter seriously.

Some may argue that the FCC should abolish the public file requirement because hardly anyone ever looks at public files. But just because nobody looks at those files isn't a reason that the public is not interested in public files. It's an exemplar of the great paradox of media policy activism: broadcasters are in the unique position to control the awareness of the policy debates over their own industry. So if the media never talk about media policy issues, therefore people never find out about media policy issues (like public files), and that ignorance is claimed as public disinterest over media policy. But I have never found public disinterest when I discuss media; quite the contrary -- when I discuss what I have found in my public file viewings, people definitely are interested and are often horrified. If broadcasters were to regularly inform or remind the public that they maintain public files which can be viewed, I'll wager that the number of public file viewings would increase. I myself have to admit that before I took up grassroots media policy activism as an active interest, I didn't know what a public file was, what they existed, or that I could view them during normal business hours.

Some may further argue that public files are too expensive and burdensome to maintain, and with so few public file viewing there's little bang for the buck. If broadcasters have reduced staff needed to maintain that requirement, that's because of policy decisions, like the increase of broadcast media ownership concentration, which resulted in that reduced staff. Broadcasters should improve policy to increase more staff to maintain those files properly.

Again, I encourage the FCC to maintain the public file requirement for radio and television broadcasters. I hope you find this letter informative, and I thank you for your time and attention.


Mitchell Szczepanczyk
Chicago, Illinois

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