Today, the order eliminating the requirement that broadcasters maintain in a paper public inspection file copies of letters and emails to their stations about station operations becomes effective. While the FCC abolished the requirement back in January, one of the first deregulatory actions of the new Chairman (see our article on that decision here), the decision did not become effective until the publication of that decision in the Federal Register, which occurred today (here). The delay was caused by the review of the decision by the Office of Management and Budget to ensure that it was consistent with the Paperwork Reduction Act – seemingly a self-evident proposition, but one that takes time nevertheless.
For all TV stations and many radio stations that have already converted to the online public file, this effective date will remove the last paper remnant of the public inspection file. For radio stations that have not yet converted to the online public file (smaller clusters in big markets and stations in small markets do not need to convert until March 1 of 2018, see our article here), the paper file will linger on – for some stations who do not upload past political documents (only new political documents need to be uploaded to the online public file), the last remnants of the paper file could linger for two years from the date of the creation of the last political file document that is created before a station’s conversion to the online public file. As the FCC has asked if conversion to the online public file needs to be a pre-condition to taking advantage of any elimination or relaxation of the main studio rule (a proposal on which comments are due on July 3, see our articles here and here), this impending rule change might provide a further incentive to a quick conversion to the online file. In any event, the FCC’s January decision abolishing the obligation to maintain letters from the public in a station’s public file is now, at long last, effective.
