Comments Criticize Changes In FCC Ownership Report Requirements

Comments Criticize Changes

Several parties have filed comments in the FCC's Form 323 review, the consideration of changes in ownership reporting requirements.

The NAB said that the Commission should not adopt reporting requirements for holders of non-attributable interests, saying that the requirements would burden and deter investors and "would not serve any useful purpose. By definition, this information cannot inform concerned parties about minorities or women with a meaningful role in broadcast station operations, because, as the Commission has previously determined, only the holders of attributable interests have such influence. The Commission should refrain from approving reporting requirements that would significantly burden licensees and their investors without providing public interest benefits."

A joint filing by BEASLEY, CBS, EMMIS and ENTERCOM offered the same sentiment, saying, "the Commission proposes to create an arbitrary incongruity by 'counting' in the ownership reporting context non-attributable equity interests in SMS Entities, while simultaneously excluding those same interests from ownership attribution," warning that the move would unduly burden prospective respondents.

A joint filing by NATIONAL PUBLIC RADIO, PUBLIC BROADCASTING SERVICE, ASSOCIATION OF PUBLIC TELEVISION STATIONS, and CORPORATION FOR PUBLIC BROADCASTING warns that "ownership is an inapposite concept in the context of public broadcasting stations. In no case does an individual person hold a debt or equity investment interest in a public television or radio station. Due to the fundamental differences in governance between commercial and public broadcasting stations, it would undermine the accuracy and usability of the data that the Commission is gathering if it were to include information about the governing boards of public broadcasting stations. Furthermore, requiring the unpaid, volunteer board members of public broadcasting stations to obtain FCC Registration Numbers generated by the Commission’s Registration System and based on the individual’s Social Security Number would have the negative, unintended consequence of discouraging service on the governing boards of these non-stock, non-profit organizations or governmental entities."

The latter point was echoed in comments by a group of public broadcasting entities and by SYRACUSE UNIVERSITY and the UNIVERSITY OF KANSAS, which added a request that, if FRNs are required, that the Commission continue to offer Special Use FRNs, a point also made in comments by EDUCATIONAL MEDIA FOUNDATION, the UNIVERSITY OF CALIFORNIA-SAN DIEGO, and the ALABAMA EDUCATIONAL TELEVISION COMMISSION.

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