Update: Online TV Public File System Unveiled!

Initial reviews are cautiously positive following FCC demonstration.

Astute readers will recall that today was the day that the FCC was to debut its new online public file system for TV stations. You know, the system that the TV industry, en masse, will be expected to be tapping into as of August 2.

We dropped by the FCC this morning to take a first-hand look at what the Feds have cooked up. 

We were favorably impressed. 

As cumbersome as some of the FCC’s online systems have been and still are, this one seems reasonably approachable and usable by people who don’t live and breathe FCC air every day.  The interfaces are pretty intuitive, both for stations that upload and for people who want to look up any item on the laundry list of materials required to kept in the public file. If you can master the system for filing Children’s Television Reports, the public file upload should be a breeze.

The Commission told us that the system is just about ready to go live, and that it should be available for stations to start uploading by the August 2 target date.  There is, however, at least one issue remaining to be ironed out.

In particular, the log-on procedure now requires a station’s FRN and password.   Group owners may prefer a system that does not permit staff at one of the station group to access the public file(s) of any other station(s). Also, some station owners – both groups and single-station folks – may prefer not to disclose their FRN password to the clerical staff that will upload public file documents. In response to these concerns, the FCC is working on an alternative log-on system.

The new public file system is organized into linked categories – with the separate links serving as a convenient reminder of the kinds of documents licensees are expected to upload.  One type of document that will not need to be uploaded: applications and reports filed electronically through other systems, including applications filed through CDBS and Children’s TV Reports. Those items will be imported to the public file automatically by the FCC.  A toggle switch will be displayed beside each imported application or report, allowing the station to delete the document if it was improperly imported or is out of date.  The FCC also plans to try to purge out-of-date applications itself, at least for those that have standard retention periods.  We don’t know for sure yet how stations will be able to purge documents that were not imported by the FCC, although some purging capability will obviously come in handy if there are uploading errors or a retention period expires.

Uploading newly-created materials to the public political file, required initially only in major markets, will take some organizational effort by stations, because each purchase or request for time will have to be recorded in a separate document and uploaded into appropriate folders – one for federal, one for state, and one for local elections.  The FCC's demonstration showed, within those folders, subfolders for (a) each separate elective office and (b) non-candidate issue advertising. It appears that the FCC’s system will allow for a degree of folder customization by the station, but we’ll have to wait to see exactly how that will work.

The FCC will accept uploads in multiple formats, including word processing and spreadsheet programs, although any document not uploaded in Adobe Acrobat (.pdf) format will be converted by the FCC’s server to a .pdf file.

Speaking of electronic filing, there is now a new optional server-based interface for uploading Children’s TV Reports.  It went online July 12, 2012.  It might be worth a look before the next reports are due on October 10.

Stay tuned to CommLawBlog.com for updates from the online public file front.

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