See you later, local correspondence file!

from Dan Kirkpatrick of Fletcher, Heald & Hildreth

As Egon said in Ghosbusters, “print is dead.”

Okay, that may be a bit of an overstatement.  But at least as to many broadcast stations’ local public inspection files, it is essentially true as of today.  Back in January, the FCC voted to do away with the requirement that commercial broadcast stations retain in their public inspection files copies of letters and e-mails from the public concerning their stations’ operations.  Because it dealt with a paperwork collection, however, the change could not go into effect until it received the approval of Office of Management and Budget (OMB).  The FCC announced today that the OMB has signed off the proposal and, as a result, the rule changes adopted in January (which also included elimination of the requirement that cable operators include headend locations in their public files) are in effect as of June 29, 2017.

Since the advent of the online public inspection file, this type of local correspondence had been the only thing broadcasters were still required to maintain in their physical public inspection file (due to privacy concerns, these documents were never included in the online public file).  With this elimination of the correspondence requirement, at least for broadcasters who have transitioned to the online public file system, there is no longer any need to maintain a hard copy public file at their main studios (which may themselves not be required for much longer).  In addition, the FCC clarified today that, pending additional OMB approval, commercial television licensees will no longer need to file a summary of comments received regarding violent programming as part of their license renewal applications.

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