FCC Proposes New Form Requiring TV Broadcasters to Document their Public Interest Programming

When the Federal Communications Commission last month started a new proceeding to mandate an online public file for television stations, the FCC promised to soon initiate another proceeding to look into the need for a new form to document the public interest programming that TV stations provide. The FCC fulfilled that promise, and issued a Notice of Inquiry (NOI) to start the process of adopting a new form for TV stations to complete to report on various categories of "public interest programming," however that might be defined. In 2007, the FCC had adopted Form 355 to accomplish that task. But, after an outcry from stations about the paperwork burden that the form would impose, the FCC never submitted it to the Office of Management and Budget for approval under the Paperwork Reduction Act, and thus the form never became effective. The adoption of the Form 355 was vacated last month in the online public file proceeding. But the FCC now proposes its return - in some fashion. So what does the FCC now propose to require from TV stations to document their public interest programming?

First, the FCC asks a series of questions about how such a form should be structured, and how the information should be collected to be meaningful for those that want to analyze it, but not overly burdensome for the TV stations. The FCC then goes on to discuss the Quarterly Programs Issues lists (QPIs) that are currently required to be placed in a station's public file every three months - describing the issues that station management sees as important in the community and the programs that the station has broadcast to address those issues.