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Feature: Inspecting a Public File

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7/17/97

The FCC recently issued a Notice of Proposed Rule making seeking comment on the location of a station's public inspection file (MM Docket #97-138). According to current FCC rules, licensed stations must keep a stack of required documents on hand at the station's main studio for anyone to inspect.

Most of the time, the most expected person to inspect the file may be a visitor from the FCC. But since the FCC doesn't get around to inspecting stations that much, stations sometimes neglect their public files, missing updates and other pieces of information that, if discovered missing, could very well cost the station a hefty fine or license problems.

Now a move is afoot to allow stations to literally distance themselves from the people they serve. MM Docket #97-138 would allow stations to locate their studios farther away from the community they're actually licensed to. That isn't that big of a deal; so many radio stations are now automated, carrying pre-packaged programming from somewhere else, that they're really not "serving" the community of license with their air signal anyway.

However, the proposed rule change would also allow stations to locate their public files at their corporate headquarters, as opposed to at the station's main studio. This is troubling.

The public file is the station's main record that certifies it is operating within the rules of its license. The public file contains logs of transmitter on/off times, technical readings, servicing, equipment inspections, and the like.

The public file also includes the names of those who personally certify to a a station to be operating legally. While this portion of FCC rules has been relaxed, it still provides some sort of paper trail if any investigation of station operation is necessary.

Even more importantly, the public file is supposed to include a quarterly issues and programs list, detailing in general what the station has put on the air and in what ways it has helped the community its licensed to.

So much for accountability.

I know of stations that don't keep proper transmitter/operator logs, don't issue quarterly issues/programs lists and other infractions. The off-chance that the FCC will come and visit really isn't enough of a threat to force stations to make the effort.

However, you also have the right to go in an inspect a radio station's public file. If you find infractions, you can report them to the FCC.

It might not hurt to check up on your local stations and make sure they're following some semblance of the law. Visits like those also tend to raise suspicion among broadcasters. It never hurts to give them a taste of paranoia once in a while.