Has it really been almost a year since the online public inspection file took effect for TV licensees? Sure enough, August 2, 2012 was the Big Date last year; since the initial flurry of public file-related activities, things seemed to have settled into a routine. But now the Commission – keeping a commitment it made back in April, 2012 – has asked for comments on how the political file component of the online public file system has affected the 240 or so stations that have been subject to that particular requirement. The responses the Commission gets could determine whether any changes should be made to the requirement before it takes effect for other stations.

The history of the TV online public file is extensive. If you’re a bit fuzzy on it all, check out our archive of reports here.

For our immediate purposes, it suffices to remind readers that, while all full-power and Class A TV stations are required to maintain the majority of their public files online (using the FCC-maintained system), only affiliates of the top-four commercial networks in the top 50 DMAs have been required to keep their political public files online. (All other stations are still required to maintain their political files the old-fashioned in-house way at least until July 1, 2014, at which point the current plan is to have everybody go online.) 

The idea behind easing the online political file obligation in that way was: (a) to make sure that the FCC’s system (which was largely untested as the August 2, 2012 start-up date) could handle the load; and (b) to “limit any unforeseen start-up difficulties to those stations that are best able to address them”, whatever that might have meant. And to take advantage of that testing phase, the Commission committed to invite comments, by July 1, 2013, on how things are going on the online political file front.

That invitation has now been issued, in the form of a public notice soliciting comments on the functioning of the political file component of the online public file system.

The Commission is looking for input from the 240 or so stations currently subject to the online approach. Any special problems? Does the upload process get easier as staff becomes more familiar with the system? Any suggestions for making the system more user-friendly?

The Commission also invites comments from the public (a concept that includes not only the Great Unwashed, but also political candidates and their reps) to get their side of the story. And it would like to hear from any of the stations not currently subject to the online political public file requirement to see if they have any suggestions for improving the system in advance of July 1, 2014.

Trying to kill two birds with one stone, the Commission has also taken the opportunity afforded by the public notice to invite responses to a petition for reconsideration, filed in June, 2012, by a “group of large television station owners”. The petition took aim at the online political public file requirement, claiming that the requirement isn’t in the public interest. (The petition also offered a suggested alternative that featured an “opt-in” alternative calling for the online posting of the “aggregate amount of money spent by a sponsor of political advertisements on the station in lieu of posting specific rate information online”.) For what it’s worth, the petition has already been opposed by the Public Interest Public Airways Coalition.

Comments in response to the Commission’s notice are due by August 26, 2013; reply comments are due by September 23.