A couple of months ago we reported that the FCC had quietly invited comments on whether its local public inspection file rule is really necessary. The deadline for those comments is fast approaching: June 17, 2011. If you have anything you might want to tell the FCC about that rule, now would be a good time to do it.
The Federal Register notice that contains the FCC’s invitation provides all the information you should need to get your comments on file. All you need to do is write down what you have to say and email it to PRA@fcc.gov and Cathy.Williams@fcc.gov. Alternatively, we'd be happy to help out if you’d like. The specific questions the FCC has posed include:
- Whether the public file rule is necessary for the proper performance of the functions of the Commission, including whether the information shall have practical utility;
- Whether the Commission’s estimate of the burden that rule imposes on broadscasters is accurate (our earlier post includes a table setting out the FCC’s various estimates);
- Are there any ways to enhance the quality, utility, and clarity of the information collected;
- Are there any ways to minimize the burden of the collection of information on the respondents, including the use of automated collection techniques or other forms of information technology; and
- Are there any ways to further reduce the information collection burden on small business concerns with fewer than 25 employees.
If you want our help in preparing comments on any of these questions, please let us know.
Note that while this is your last chance to tell the FCC how you feel, it’s not the absolute last chance you’ll get to comment on the public file rule. Once June 17 comes and goes, the FCC will bundle up everything that gets submitted to it and ship the whole package over to the Office of Management and Budget, along with a separate memo from the FCC explaining how it proposes to proceed with the public file rule and why. OMB will then provide everybody a chance to comment on that.