[BC] Public File

[Paul Christensen]

> Here's a concise public file reference, courtesy of Womble Carlyle
> Sandridge & Rice, PLLC.
>
> http://www.wcsr.com/downloads/pdfs/telecommlpfm.pdf

Public file requirements for broadcasting and the allied media services are 
always subject to change.  Before relying on dated material, it's a good 
idea to ensure that the information relied upon from any check-list is 
current and relevant.   There's no substitute for becoming familiar with, 
and staying abreast of, the FCC public file retention requirements directly 
from the governing source.

By far, the most prominent problem I've seen with respect to meeting the 
public file requirements is that the responsibility is not adequately 
delegated, monitored, nor used as a performance-based metric during employee 
evaluation reviews.   Since the file subject-matter spans several internal 
departments, responsibility for the relevant sections should be clearly 
defined by station and/or group leadership.

In addition to assigning public file responsibilities, one easy way to 
impress any inspecting FCC officer is to use file placeholders, indicating 
the date, name, and signature of the person who last reviewed a subsection 
of the file.  But it takes diligence on the part of those accountable with 
the task of keeping the file current.   Although the addition of this review 
method can be a benefit, it can also become damning evidence of file neglect 
if old dates appear on the placeholders.

Paul

====================================
Paul Christensen, CPBE, CBNT
LAW OFFICE OF PAUL B. CHRISTENSEN, P.A.
3749 Southern Hills,  Jacksonville, Florida 32225
Office: (904) 379-7802   Facsimile: (904) 212-0050
pchristensen at ieee.org