Lesson One – How to get into your station’s file to begin with

[Blogger’s Note: Our crack paralegal, Denise Branson, contributed to the preparation of this post.]

As readers should know by now, the FCC’s online public inspection file system for television (including Class A) licensees went live last month. (If you didn’t know that, check this thread of posts to get up to speed.) For the majority of affected licensees, the new system has thus far been largely a non-event. That’s because the primary impact of the new system, at least initially, has fallen on a relatively small universe of stations – i.e., affiliates of the Top Four commercial networks in the Top 50 markets – who have to upload all new political file materials. The rest of the TV world won’t have to worry about uploading political files until 2014, at the earliest.

Of course, all TV licensees (for convenience sake, we’ll include Class A licensees within the meaning of that term in this post) can still go ahead and start uploading material from their paper files to the new online system. But the deadline to get that particular chore done isn’t until early February, 2013, so it’s entirely possible – the temptation to procrastinate being what it is – that many, if not most, TV folks haven’t yet even taken a quick glimpse at the system, much less test-driven it to any significant degree.

Heads up, though: the public-file-uploading chores for ALL TV licensees will for sure kick in no later than October 10. That’s the next deadline for the preparation of quarterly issues/programs lists, which have to be placed in the public file by October 10.

That being the case, we figured it would be a good idea to provide a series of posts introducing the Great Unwashed to the FCC’s online TV public inspection file system. This first installment of that series is designed to get you into your station’s public file for uploading purposes. We intend to follow this up with additional primers on how to upload materials and how to manage your file.

The first order of business: Getting into your file.

The FCC has thoughtfully imposed a two-tiered system that you’ve got to negotiate before you can access the business end of your online public file. Although at first blush this might seem a bit cumbersome, it really is a thoughtful approach designed particularly with the multi-station owner in mind. 

The goal is to allow licensees to make individual stations’ passcodes available to relevant station personnel without forcing the licensee to make generally public that super-secret combination, the licensee’s FRN and related password. So the licensee gets to keep under close control its master key – i.e., the FRN combo – that allows it to determine what each station’s passcode is; the licensee can then distribute station passcode information to relevant staff at each station for their particular use.  

Let’s assume that you’re a licensee with two TV stations in different communities, and you want to get both stations working on their respective public files. For a station to get into its own public file for uploading purposes, it will need to know (a) the station’s FCC Facility ID Number (FIN) and (b) the station’s online public file passcode. You, as the licensee, can get them that information.

How?

First, go to https://stations.fcc.gov/. That’s the home page for the TV online public file system. It looks like this:

If you want to see what your current online public file looks like to the public-at-large, insert your call sign in the "Find A Station" box at the bottom and hit "enter".

If, instead, you want to get into the non-public, "back-end" of your file in order to upload new stuff, click on the “sign in” button in the upper right corner.  (As an alternative, you can get there directly by clicking on this link.)  That takes you by default to the “Facility Sign In” page, which looks like this:

If you already had your stations’ passcodes, you would proceed from this page to each station’s public file simply by inserting the correct FIN and pass. But we’re assuming that you’re starting from scratch and haven’t yet figured out the passcodes.

No problem. Click on the very last live link on this page – titled “Sign in using FRN and password”. That takes you to the “FRN Sign In” page, which looks like this:

(Note that you can get to the FRN Sign In page directly at this link.)  Enter the licensee’s FRN – that would be the FRN associated with the stations whose files are to be uploaded – and related password. Click on “Sign In” and the next thing you should be seeing is the “My Stations” screen that looks something like this (we’ve highlighted with descriptive boxes the two line items that you’ll be needing in particular):

We have smudged out the specific details of the particular licensee’s two stations whose information we used to access these screens for demonstration purposes. Yours should clearly identify each station by call sign, FIN, community and channel. (It may also include a station logo.) The last datum listed for each station is that station’s passcode.

Copy and paste each station’s passcode into a separate document for future reference. Yes, yes, Luddites may choose to transcribe them by pencil and paper, the old-fashioned way, but be careful – each passcode is a combination of letters and digits, and it may not be all that easy to tell, say, a zero (0) from a capital O, or a lower case L from Arabic numeral 1. Copying and pasting avoids any misreadings.

With the passcodes, you’re now ready to go back to the Facility Sign In page and get started. We’ll pick up the story in the next post in this series.

A couple of observations about the passcode system. 

As noted above, the FCC has designed the system, with input from multi-station licensees (among others), to provide licensees with a reasonable measure of security. Presumably, at the station level there will be multiple staffers – including management-level and, possibly, non-management-level folks – who you’ll be counting on to get necessary materials uploaded. Obviously, each of them will need to have relatively easy access to the necessary passcode.

But the need may arise to change a station’s passcode – for example, an employee familiar with the code leaves the station’s employ, and you want to make sure that his/her access to the file is immediately terminated. All the licensee need do in that case is get back to the “FRN Sign In” page, from there access the “My Stations” page, find the station whose passcode you want to change, and click on the “Generate New” button at the bottom of the station’s information list. The FCC’s system will immediately give you a new passcode for that station. Copy/paste and distribute that new code to employees who still should have access to the file, and you’re all set.

The Commission’s system does not permit licensees to designate their own personalized passcodes. That’s probably for the best. The apparently random passcodes generated by the FCC’s system are likely far more secure than whatever a licensee might come up with. And in this case, security should be an overriding concern. 

Under the old non-online public file system, anyone trying to mess with the contents of a station’s file would have had to deal with physical barriers (doors, locks, file cabinets, etc.) and personal barriers (receptionists, other personnel) before he/she had any hope of actually getting to the file. Under the new online system, someone bent on mischief needs only two pieces of information – the station’s FIN and its passcode – to get into the file from anywhere, any time of the day or night. The FIN is easily obtainable (through CDBS and elsewhere). So heavying-up on the security of the passcode is obviously the desirable, if not necessarily the most convenient, approach.

Next installment: the Issues/Programs List.