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Re: Public File Online
To: CRTech <crtech@crtech.org>
Subject: Re: Public File Online
From: Mark Croom <markc@newmail.kinshipradio.org>
Date: Thu, 24 Aug 2017 14:45:16 -0500
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Hi Jim,

Deep breath, hold for a few seconds, let it out slowly. Repeat a couple of times, until your heart rate is a little closer to normal than it is to "freaked out" rate.

This *is* going to require some work, but it will not necessarily have to be an emergency.

The real trick to this is going to be making sure all your correct information is in order.

Since your information *should* all be in order in the paper file already, there should be no panic.

If the various elements of the PIF are not in proper order, then you have something to be concerned about and should get on that ASAP, so you don't have to panic when the time comes to scan and upload.

The scanning and uploading process can be given to a secretary, part-timer, or temp once you have the stuff you need properly organized. If you create a master checklist and minimize all your paper files, the rest will be easier than you probably think.

As an ABIP inspector I see Public Inspection Files in various states of organization. Some stations with engineering operations in great order have PIFs so clogged with stuff that's not required that it doubles my inspection time, just sorting through the Public files.

To my thinking, the best thing to do is make sure you have your information current in there per the requirements explained in the good old Self-Inspection Checklist. Just Google for this if you don't have one printed already. The Public File requirements are not significantly different between AM and FM, noting here that Equipment Performance Measurements (NRSC for AM) are not required to be in the PIF (though I see many stations that put them in there). There has only been one major change to the PIF requirements since that Checklist was developed: You will not have to do anything with your letters from public as those were recently removed from the required documents. Take them out of there and never worry about them again, at least for the purposes of the Public Inspection File.

You can reduce your paperwork load in there by noting carefully that some requirements for retention were changed a long time ago. Many stations around here have a set of file folders that have old rules for retention taped to the front so they are still keeping things like applications that used to be required to be kept until the *next* application was acted on, so the retention was essentially eight years. Now, for example, you don't need to keep applications in there once they've been acted on. You can clean out your EEO and Quarterly Issues and Programs at license renewal so you don't have any older stuff in there. You must have every annual EEO report or statement and Quarterly Issues list since receiving your renewal, but that's it. Even your local announcement records don't have to be kept in there any more, AFTER the application receives final action by the Commission, per the Checklist (which has the rules cited in it). If you have applications pending, then you need those in there. If you have a CP for something unbuilt, put that in your authorizations.

So for goodness' sake, archive somewhere other than the PIF, anything that is not required to be there. There are no brownie points for having things in there that are no longer required (especially if you are missing something that is required). So any applications that are in there but acted upon, archive them with other important station paperwork but don't leave them in the PIF. You only need two years of Political, so archive anything older. Go through this stuff annually once it's organized, so you (and your ABIP or FCC inspector) don't have to rifle through lots of paperwork that doesn't need to be there, just to find the things that do need to be there.

Make sure you have copies of your licenses and renewals in there, but don't keep anything older than the current license and its latest renewal. Same with contour maps, just the current and most correct one. Use the Checklist and be brutal about anything that isn't required. Even with hanging folders the typical station that has everything in order doesn't have but about 4-6 file inches of material. Many stations have much deeper Public files when I first open the drawer, like 18-24 inches worth. That's just unnecessary.

Once you have done this culling process, you will find the task of preparing for online PIF to be far less daunting. TV has been doing it for a while and all the folks I inspected this year (a handful of licensees in South Dakota) all say they had it down to a science very quickly.

I don't know if this helps you or not, but that's my perspective as somebody who looked at about 130 PIFs in the last two years of inspecting stations.


On Thu, Aug 24, 2017 at 9:37 AM, Jim McDermott <jim@spiritfm.org> wrote:

Is anyone else on this list a freaked out about this as I am? As someone who wears 5 hats at my job, this is going to be a logistical nightmare to get all of the current info for all 14 stations uploaded to the FCC site.

Follow-Ups: Re: Public File Online
(Tim Swanson <timswanson@kswp.org>, 25 Aug 2017 09:35:06 -0000)
References: Call sign in etrs form
(Bill Tidwell <bill@waft.org>, 24 Aug 2017 14:23:56 -0000)
Public File Online
(Jim McDermott <jim@spiritfm.org>, 24 Aug 2017 14:38:26 -0000)
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