Your browser is out-of-date!

Update your browser to view this website correctly. Update my browser now


FCC Eyes Radio Online Public Files

The dos and don’ts of the commission’s new Web file interface for TV stations explained

WASHINGTON — Soon radio stations will be required to place public file documents online and to use the FCC’s new Web interface to accomplish that.

Some TV stations now are required to do so. While a radio requirement hasn’t been announced, commission officials have confirmed to Radio World it’s coming, and staff is now planning a version of its new online public file database for radio. The agency demonstrated beta versions of the TV interface in late July and early August as it was fine-tuning the site.

The commission proceeded with its requirement for TV stations despite a request for a stay from NAB pending judicial review at a federal appeals court. The stay was denied; the court was still considering the appeal.

The rules went into effect Aug. 2; Fox, CBS, ABC and NBC television affiliates in the top 50 Nielsen DMAs began uploading new material for their public file to the FCC-maintained database on that date. They have another six months to post older documents.

TV stations not in the top markets, and those not affiliated with the big networks, must comply within two years. (Political file contents of the public file are treated differently; stations are required only to upload new documents, not older material. Again, smaller stations have two years.)


The beta version of the FCC’s online TV public inspection file system shows a list of folders for WRC(TV) in Washington.

Up to now stations have kept their public file in paper form at their facilities or at other locations such as libraries that are easy for the public to access during business hours.

The new rules require moving them online. Media Bureau Chief Bill Lake said the point is to make files easier for the public and industry to access, moving from an “antiquated hard-copy filing system to Internet-based filing systems.” Moving files out of station’s basement filing cabinets “is a commonsense first step,” said Lake.

Officials haven’t said exactly when they intend to require radio stations to move public files online; they want to work out any bugs first with the TV version.

NAB and stations protested the rule, citing the administrative burden. They also don’t like the idea of placing political files — including information about pricing of political ad buys — online, arguing that this places TV stations at a disadvantage against competitors like cable and satellite, which are not required to do so.

Upload limits raised

FCC Chief Data Officer Greg Elin listed improvements to the agency’s current online database used for other filings.

Each station has a profile page. Elin says the new interface will fewer user clicks than the current one. He demonstrated how a station staffer could drag and drop multiple documents into the database at the same time.

Elin said the commission recognized that the first stations would have a lot of files to upload over the next six months and might be filing every day. Managing numerous files might be unwieldy, so the FCC took a suggestion from NAB to implement Dropbox. The free online file-hosting service allows users to create a folder on each of their computers; Dropbox synchronizes those so they appear to be the same folder with the same contents regardless of which computer the material is viewed on.

The commission intends to support other file-sharing technologies as well.

Currently, the agency converts files submitted electronically to PDF format to block computer viruses. This practice will continue.

However, if your station has only one version of a paper document, and it’s really old or long, it’s okay to scan the document and send the document as a PDF to the FCC, according to Elin.

The site will be able to handle several file formats such as PDF, text, word or HTML.

Once a station has uploaded documents to the FCC’s system, the facility no longer needs to keep a paper file on-site for the public to inspect.

However, letters and e-mails from the public are an exception. The commission does not want stations to upload those for privacy reasons. Letters and e-mails from the public should remain at the stations. Text directing the public where they can find this material will be part of each station’s online public file, according to Elin.

Many stations have had questions concerning what documents to upload for the political file in order to show the final price for an advertising purchase. He suggests stations upload an invoice or a contract that contains the final price of the ad buy.

Testing the system, some stations sent the commission documents for the political file; Elin said in an August demo that he’s seen checks with bank numbers, social security numbers, credit card numbers and other personal information. All of that can be redacted from documents a station uploads to the FCC’s new system.

“I recommend against putting a scanned copy of a check in the online public file,” he said.

How big a file a station can upload at once is a question several broadcasters asked as well. In the past, station personnel or their attorneys needed to break up large files to send them electronically to the commission. Elin said the commission is now looking at limiting file size uploads to around 50 Megabytes.

Asked by Radio World about the risk of a system crash on the deadline when many stations would be uploading files, he replied that files from all broadcasters would be put on dedicated hardware, separate from the public access portal. There will be a 2,000-station cap on how many TV stations can file simultaneously. “If we have a high spike with the public,” the agency can use caching and redundancy in the cloud to handle the volume, Elin added.


Michael Richards, a communications attorney who attended the first demo, believes that for “mom and pop” radio stations, the process will be a “challenge to implement so [that] an important community-based source of local media is not further stressed by the already tough operating conditions in the modern media environment.”

Fletcher Heald & Hildreth attorney Peter Tannenwald opposes the new requirement generally but said the initial demo made the process look “usable.” He thinks conversion could prove to be a “mess” for radio, where stations have much smaller staffs.

For him, the online concept also brings up other concerns. “Probably 90 percent of public file inspections are by potential troublemakers.” Stations are entitled to ask for a name and address of a person who comes to a station to look at the file, in part for safety reasons, he said. “That has helped my clients in many cases to spot potential trouble and try to deal with it before it gets out of control.” It’s unclear whether there will be a similar mechanism for online access.

Tannenwald continued: “Some stations don’t care if they don’t know who looked at the file. They would much rather put the file online and not admit strangers into their building.”

Among other files, stations must place all their licensing, ownership and EEO documents, and any related to an FCC complaint, in their public file.

The commission planned to post instructional videos to its website that would detail exactly how to use the upload system. It included a “Frequently Asked Questions” tab on the interface at and established a hotline for TV stations: (877) 480-3201 or (717) 338-2888. It is staffed weekdays, 8 a.m. to 6 p.m. Eastern.