NAB Says Putting Public Files Online Could Cost Millions; Nonprofits Disagree
It could cost millions of dollars for TV stations to start putting just part of their public-inspection files online, the NAB told the FCC. It estimated that putting existing political ad files online could cost $15 million, and said making electronic other parts of the files would cost even more in employee time and other expenses. But nonprofits told the FCC and the Office of Management and Budget that the costs will be limited. OMB will consider the paperwork burdens of the regulator’s proposal to require all TV stations to put the files online through a commission-hosted website.
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Putting the files online will save consumers money they'd have spent otherwise to travel to stations’ main studios to view public files during business hours, a coalition of seven public interest groups told the FCC. The proposal, if adopted by commissioners, would also save copying costs, which can total hundreds of dollars for a station’s file, the Public Interest Public Airwaves Coalition said (http://xrl.us/bmpo8t). The coalition’s and NAB’s comments were posted Tuesday in docket 00-168 (http://xrl.us/bmpo8z), while the Sunlight Foundation and a policy and law institute at the NYU School of Law sent their comments to OMB.
The $15 million in one-time startup costs for political files comes from the estimate of one station that it would take at least 270 hours to digitize the documents and upload them, the NAB said (http://xrl.us/bmpo9d). That’s a cost of $6,750 for each of the U.S.’s 2,264 commercial, nonprofit and Class A low-power TV stations if the staffer uploading and the digitizing the files was paid $25 hourly. “This figure does not take into account the extensive personnel and other station resources that would be required to maintain the political files on an ongoing basis, particularly in a busy political year,” the association said.
The Brennan Center at NYU acknowledged the “inevitable administrative and other costs” involved. The commission should “structure its final rules with appropriate flexibility, so that the online reporting requirements are not unnecessarily onerous,” the center said. “Nevertheless, we urge the Commission to maintain the basic requirement that political file information be made available online in a timely and accessible manner. Such a requirement will substantially increase transparency and accountability in our democracy.”
Commission hosting of the files means it wouldn’t cost more than what TV station employees are paid now to file paper forms, said the Sunlight Foundation, which seeks to use the Internet to improve government transparency. “In all likelihood, the cost will be lower than it is now, due to the reduction in paper filings and staff time required to retrieve” them, the foundation continued. It’s “ideal” for the FCC to create an online form where stations can enter data, which “reduces the burden on affiliates by not requiring any software updates, and also standardizes the data into set fields and allows extensive machine processing,” Sunlight said.
The FCC failed to provide enough information so the agency and industry can derive an estimate of the burden of the proposed rules, as required by the Paperwork Reduction Act, the NAB said. “While the Commission may be correct that parts of the public file can be uploaded to the Commission’s website with relatively few difficulties, there are significant reasons to believe that the Commission’s overall online public file proposal can be unduly burdensome unless it is carefully designed and managed.” The agency “has done nothing to account” for “potential problem areas,” the association said. “The record before the Commission provides compelling evidence that the burden associated just with placing the political files online will be much higher than the Commission’s estimates for the new online public file requirements.” Adding information on ad sponsorship identification and shared services agreements to the public file as the agency proposed “will further exacerbate these burdens and will return little in the way of public benefit,” the group said.
Public interest groups disagreed. The public file proposal promotes the act by “maximizing the utility of, and ensuring the greatest benefit from, information collected by the FCC,” said the Public Interest Public Airwaves Coalition. “It would also streamline management of these files and diminish many of the inconveniences and burdens associated with broadcasters’ maintenance of paper files. In short, these proposed improvements will reduce both paper and work for the public and for broadcasters.” Members of the coalition are the Benton Foundation, Campaign Legal Center, Common Cause, Free Press, Media Access Project, New America Foundation and United Church of Christ.
"Never mind a Broadband Plan for our Future,” Free Press Senior Counsel Corie Wright told us. “We may need a Broadband Plan for Our Broadcasters if TV stations are seriously arguing that they can’t upload a file to the Internet without first forming a ‘working group.'” The NAB said the act supports the formation of such a group or an FCC pilot, before the rules apply to all TV stations. But it can cost 25 cents a page for groups to get copies of public inspection files, the coalition said. It said the National Hispanic Media Coalition was required by a Los Angeles broadcaster to pay $357 to Kinko’s in copying costs to get its public file.