By Kristian Davis Bailey and Jason Smith

On Tuesday, July 17 we attended the Federal Communication Commission’s (FCC) demonstration of their new online interface for the uploading of television broadcasters’ “public inspection files” (PIFs).  [A video of the demonstration has been archived on the FCC’s website and is available here.]

Greg Elin, Chief Data Officer of the FCC, gave  broadcasters and the general public a first look at the interface and demonstrated how to navigate it at the event, which was relatively short but useful as a primer before the rule requiring broadcasters to post PIFs online goes into effect on August 2, 2012.

Some broadcasters expressed concern about the ease of accessing the system. In the spirit of some summer lightheartedness we went into the demonstration analyzing the public filing system from the perspective of popular children’s characters who find themselves navigating complex worlds: Dora the Explorer and the Scarecrow from The Wizard of Oz.

For us, Dora represents today’s tech-savvy kids who with a little coaching, can adapt very quickly to new interfaces. The Scarecrow might represent an older generation of users who after some initial difficulty, discover they’ve had the skills to interact with computers all along.

Having seen the process, we can say without a doubt, yes–both Dora and Dorothy’s scarecrow friend could upload their television station’s PIFs to the Commission’s database. We believe public broadcasters can, too.

More on the process itself in a moment. First, we’d like to contextualize what’s at stake for the public and broadcasters in this new system.

Debate over ‘the political file’

As readers of [the MPI blog] know, the Media Policy Initiative has, as a member of PIPAC, been providing comments to the FCC in support of updating the public file process. See our initial comments on the new system, our first set of reply comments, related comments  on the Paperwork Reduction Act, and a final set of comments on the matter.

For those who are less familiar with the process – the FCC requires public broadcasters to keep PIFs that contain information related to station operations, programming, and civic correspondences/complaints—among other data. Up until now this “public file” has been stored as a physical document in station offices, where it is available to members of the public upon request Monday to Friday between 9am-5pm.

One of the most important parts of the PIF is the “political file”, which contains information regarding ad purchases from candidates for public office. This file is technically “available” to the public, but the physical visit to the station required to request and view the information means that only select journalists and a few concerned citizens actually access it.

In April, the FCC issued an order, updating its requirement for a subset of television broadcasters to do so “in a central, Commission-hosted online database” and include in this the “political file.”

Broadcasters are required to include 17 discrete forms of documentation in the public file—including FCC authorization, program lists, and letters and emails from the public. These requirements are part of a set of obligations imposed on broadcasters in exchange for free use of public airwaves. Political files are the sixth item listed in this requirement.

A blog post from Radio World, a newspaper for radio managers and engineers, commented that a similar change is inevitable for the radio industry. The post cited one radio network manager that voluntarily put its files online, though it houses its political file on a standalone computer.

As New America has already said and as CJR has already shown, having access to political files is important for holding public stations accountable for broadcasting in the public interest. Since broadcasting of political advertisements plays such an important role in elections, it is paramount that members of the public can view ad spending.

The broadcaster’s uploading interface

“What was your favorite part?” Dora might ask us, as she does at the end of every episode. We’d have to give the award to the interface broadcasters use to upload files.

The drag-and-drop upload feature (compatible with standard browsers) is a simple and intuitive process, enabling broadcasters to quickly submit multiple files at once.  Additionally, the option to upload using local Dropbox folders takes the ease of use a step further, by allowing broadcasters to spend minimal time on the FCC site organizing their files. Users can add files to a Dropbox folder and then just login to the FCC site to sync their own cloud-based folder with the governmental account. With expansion to other cloud-based storage services – including Microsoft SkyDrive, and Box – this should be an attractive option.

CommLawBlog, a site focused on topics in communications law, commented that they were “favorably impressed” with the new system. Their one concern, which came up during Tuesday’s demonstration, was that the log-in procedure requires a station’s FCC Registration Number (FRN) and password, which stations may not wish to disclose to clerical staff uploading files. The FCC said it is working on an alternative.

Of the broadcasters’ interface overall, Dora might say, “I liked that, too,” as she always does upon hearing her viewers’ favorite details.

The public’s perspective

The public interface is a close runner-up.

For individuals looking for information on local stations, the process is also so intuitive that the Scarecrow would not need assistance from the Wizard. Working our way through a demo of the site that the public will see once the system goes live, we found it simple to navigate and find a variety of files related to a broadcast station’s operations. The site centralizes station information like primary contact information, license and authorization information, and public inspection files in an organized and accessible manner. Prior to this new system, users had to navigate multiple databases to pull together information.

However, what exactly all these files mean is not clear under the new system.  Our Straw Man might require a little help here. Aside from policy wonks knowing the media policy jargon associated with such files, everyday citizens might find sorting through all this information a daunting task.  Looking at the site during the demonstration, we didn’t see any legend or glossary that might assist individuals trying to use this information in a meaningful way. (Dora might need help from her talking friend Map here) Adding one would be a simple improvement and we hope the FCC will do this.

Public or private?

Once broadcasters have uploaded files, they can decide at the click of a button whether to make the information available to the public or not.

The “In Public File?” switch-button was created because of concerns raised during the testing process over whether certain applications filed with the FCC should be in the public inspection file.

It is so easy to make a file private that we worry citizens might not have access to public files that they may wish to view about how local stations are using public airwaves. “Oh bother,” Pooh bear might say.

Given the current set of objections to the rule by the National Association of Broadcasters requiring them to post PIFs online, we were curious to know what sort of compliance efforts the FCC will undertake to ensure that broadcasters upload their files in a reasonable time and that broadcasters are not miscategorizing information that should be public.

Elin declined to confirm whether broadcasters would be sanctioned if they miscategorized files as private, noting he could only speak to the technical aspects of correcting mistakes (pressing the button to make the file public).

Whether and how the FCC will check that files are appropriately filed was not clear to us from the demonstration. But now that the capability for uploading the files online and making them available for all (especially the FCC) to see, we hope that compliance won’t be an issue.


Overall, we’re as pleased with this new process as the cheery cast of the children’s singing and dancing show Fresh Beat Band: the FCC is moving the broadcasting industry into 21st century standards of open documentation and accountability. It is just with the foresight of people who aren’t constantly smiling and singing that we remain cautious about broadcasters fulfilling the public file requirements.

Update: July 27th the DC Circuit denied a request to stay the implementation of the online file so it looks like the online interface will be in use very soon. Let’s hope some of Dora’s fans use the tools the FCC has implemented.

This post originally appeared on the New America Foundation’s Media Policy Initiative blog, on July 27, 2012

Could Dora the Explorer upload a public file? We think the answer is yes

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