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The Commission’s effort to require online public inspection files for most television and radio broadcast stations (and others) brings with it the opportunity to improve the physical security of broadcast stations. Simply put, once the public is able to view these documents online, there should be no need for public access to broadcast station premises. Given past attacks on station employees and the physical risks these individuals can face, it is all the more important that the Commission clarify our rules so that if any station makes its public inspection file available online – either as required by our rules or on its own initiative – it is no longer required to make its facilities or premises open to the public. This positive step will improve the safety of broadcast stations while enhancing public access to key records.

Across our nation, local broadcasting personnel often become real celebrities in their communities. In many instances, people see or hear a station’s on-air talent on a daily or weekly basis, and find them throughout the community performing various official and public service functions. From on-air broadcasting and investigative reporting to charity fundraising and many other functions, station employees are the face of broadcasters in cities, towns and localities throughout America. These efforts are part of the reason that broadcasters and their hardworking staff are widely celebrated.

Unfortunately, the exposure and notoriety from such high profile professions in today’s media driven environment can lead to greater safety risk for station personnel. We all know there are some number of unstable individuals interacting in every society, and broadcast station employees can be particularly vulnerable to threats or actual harm, including physical assault or worse.

American broadcasters generally take proper precautions to protect their employees, but there is room for improvement. In fact, the Commission’s public file inspection requirement clearly creates a potential weakness in broadcasters’ security efforts. When unknown individuals are allowed into a broadcast facility for any purpose, but in particular, to review the public inspection file, the list of potential risks can be quite long, including violence. In my visit to Alaska last summer, I talked with local broadcasters and learned of repeated attempts by one individual to remove documents from a station’s public file with the hopes of catching the broadcaster out of compliance with FCC rules. Just imagine if that person refused to exit or pulled a knife when the station personnel prevented the malicious act.

In an effort to address this situation, the Commission raised this precise issue as part of its latest online public file item. Specifically, in December’s Notice of Proposed Rulemaking, we sought comment, at my request, on whether the online public file mandates, if adopted, would result in “less need for the public to visit the affected entities, which will enable such entities to improve security and minimize risks to employees.” Having had a chance to review the current record on that proceeding, it is disappointing that there is not overwhelming comment on this important topic. Perhaps commenters were confident that the Commission would do the right thing by adopting such a common sense change in access to broadcaster properties without having to be extensively persuaded.

Accordingly, it would be helpful to have a more fulsome record about the physical threats and actual harms experienced by broadcast station personnel. Similarly, it would be valuable to hear whether broadcasters believe that their overall security could be improved if the Commission addressed this potential vulnerability. At the same time, I call on my fellow Commissioners to help to improve the safety and security of America’s broadcasters and their employees by reducing unnecessary access if or when any efforts to expand the online public file go live.