Today, the Institute for Public Representation filed comments on behalf of the Public Interest Public Airwaves Coalition (“PIPAC”), along with the Sunlight Foundation and the Center for Effective Government, regarding the FCC’s online political file requirements.
Last year, the FCC required television broadcasters to begin uploading its “public files” to an FCC-hosted database. Until then, viewing the public files involved a trip to the station to view the files in person. There is no shortage of stories online that detail the problems encountered by station visitors.
One aspect of the public file is the political file. While the FCC required the entire public file to be uploaded by every station, the political file was different. The FCC decided that, at first, only the top-four stations in the top-fifty Designated Market Areas would have to upload its political file (roughly 200 stations). This would be a trial period before the FCC would automatically implement the same requirement for all the broadcast stations beginning July 1, 2014. The comments at this stage were primarily intended to be a reflection (we just had the 2012 election) of whether the files were beneficial and whether they could be improved.
PIPAC answered with a resounding “yes” to both questions. The files were very beneficial. Online posting of this information dramatically reduced the burdens of access to the public. Reporters and journalists could more easily access the information they needed, and that allowed them to spend more time analyzing and reporting on the data to the benefit of the public. For example, Minnesota Public Radio has been calculating election spending in Minnesota since at least the 2008 election. In 2008 and 2010, the reporters had to travel to the stations many times to keep track of spending over the election period. Despite that inconvenience, the reporters still reported a lot of information to the public. But in 2012, with online filing, the reporters were able to collect that data without wasting the travel and search time required for the physical files. The 2012 spending report had interactive graphs and maps and included a full-length article with analysis and a radio interview. The time not spent traveling was used to actually analyze and report the news. This contributed to a more robust public debate about campaign finance and funding in Minnesota.
On the other hand, improvements are necessary before the July 2014 deadline. PIPAC member Free Press and the Sunlight Foundation started the “Political Ad Sleuth” database. This initiative asked volunteers to “scrape” the FCC database and put the data into the new one. This new database was searchable by multiple variables, which gave a broader perspective of political ad spending (by market, by candidate). The Political Ad Sleuth experience demonstrated that improvements to the FCC database were required. The easiest way to create an easily searchable database that is capable of aggregation is to set data standards and require stations to upload their data in a machine-readable format. The Federal Election Commission has succeeded in collecting political ad data with this strategy for over a decade. The FCC could very easily adopt the same strategy.
In its comments, PIPAC proposed a sample form and output method the FCC could implement. This form was created by Sunlight Foundation engineers Daniel Cloud and Jacob Fenton. The new form includes all information required by the Bipartisan Campaign Reform Act of 2002. Ideally, this form would not be used as proposed. With data standards, the software market could fill this role, like they did with FEC data, further streamlining the filing process. (Imagine the same or similar software that handles your accounting and FEC filings would handle your FCC filings too.)
Adoption of this proposal would provide significant benefits to the public, and would largely alleviate the problems that PIPAC discusses in its comments.
Reply Comments are due on September 23, 2013. PIPAC plans to file at that time.