February 2, 2018 - 10:30 am
By Michael O'Rielly | Commissioner

While not ranking highest on the list of significant process reforms needed, the practice of printing hard-copies of the “FCC Record” should be eliminated.  To be crystal clear, I am not suggesting that we keep its contents or information from the public.  On the contrary, I suggest that it makes little sense to continue to publish paper copies when other mechanisms are more consumer friendly, cost-efficient, and easier to access.  Instead, the Commission should make its documents centrally located and easier to find for interested parties electronically, making paper copies of the Record unnecessary on a going forward basis.  If Encyclopedia Britannica could eliminate paper versions of their works in 2012, why can’t the FCC do the same for its paper copies in 2018? 

For those unfamiliar, the FCC Record contains “a comprehensive compilation of decisions, reports, public notices and other documents of the Federal Communications Commission of the United States.”  These voluminous books are printed at government expense by the Government Printing Office’s (GPO) contractor and offered to the public on a subscription basis from the GPO for a yearly fee of approximately $813, or each issue can be purchased separately for $65.  Take the 2016 version (which is the last full year available): it amounted to 17 volumes with 14,129 pages.  You can see for yourself here:

The FCC Record stack of books

Paper copies are truly unnecessary in 2018.  In fact, there are already multiple ways to access the same information.  Initially, consumers can obtain each individual document that comprises the Record on the Commission’s website (see for example http://transition.fcc.gov/Daily_Releases/Daily_Business/2017/db1219/DA-17-1219A1.pdf).  Additionally, certain Federal and state depository libraries, such as the University of North Texas, maintain electronic copies of the FCC Record volumes as part of its collection.  Moreover, commercial computer databases (e.g., Thompson Reuters’ Westlaw and Lexis/Nexis) provide searchable and printable copies of FCC Record items for a subscription.  More importantly, the Commission already posts a PDF version of each item reflecting its FCC Record number – to the extent that is of assistance – via an ECFS Advanced Search (see for example https://apps.fcc.gov/edocs_public/attachmatch/DA-17-1127A1_Rcd.pdf and https://apps.fcc.gov/edocs_public/attachmatch/FCC-17-12A1_Rcd.pdf).       

Further, the Commission – on its own accord – certainly has the capability to publish the FCC Record electronically as a PDF on our website.  In fact, the Commission compiles the current FCC Record, not the GPO or its contractor.  Specifically, the FCC takes its documents from EDOCs, creates the volume, sets the FCC record pages, and then supplies a PDF version to the printer.  In 2016 and 2017, the FCC then purchased 80 printed copies of the FCC Record.  The FCC, however, could just as easily compile the PDF and just put it online, saving the costs of purchasing paper copies for its own use.  To aid in consumer functionality, the Commission could also establish a separate webpage that consisted of only PDF Record compilations. 

Ultimately, replacing paper copies of the FCC Record with an electronic version would save scarce federal funding, be more accessible for interested parties, and result in less paper waste.  That seems worth the limited effort needed to make it a reality.