Comment Dates Set for Proposed Elimination of Correspondence File Rule

As we previously reported here, the Federal Communications Commission has released a Notice of Proposed Rulemaking (“NPRM”) requesting comments on its proposal to eliminate the requirement that commercial radio and television stations keep copies of letters and emails from the public in a publicly accessible file at their main studios. Based on the publication of the NPRM in the Federal Register, comments are due by July 22, 2016, and reply comments are due by August 22, 2016.

As a reminder, this proceeding is of particular importance to broadcasters because, if the letter and email correspondence file rule is eliminated, it will no longer be necessary for radio and television stations to maintain a public inspection file at a station’s main studio. Instead, once a station has fully-transitioned to the online public file, it would only be required to maintain its public inspection file online on the FCC-hosted public file database. As an additional reminder, stations in the top 50 Nielsen Audio markets with five or more full-time employees must be fully-transitioned to the online file by December 24, 2016. All other stations have until March 1, 2018, to complete the transition. Even if the correspondence file rule is eliminated, stations would still be required to keep backup copies of their political files at the main studio if those files are not otherwise electronically available.

If you have any questions or are interested in filing comments in connection with the FCC’s NPRM, please contact any attorney in our office.