Pillsbury Winthrop Shaw Pittman attorney Scott Flick is warning stations to be aware of a change at the FCC that might affect your station’s Public Inspection File link found at the bottom of most station websites.
“With the Internet omnipresent, and the FCC working hard to make sure broadband connections are available across the country, the Commission has increasingly integrated the Internet into its age-old regulations. With most FCC filings now being done online, application public notices having moved from newspapers to online, and the Public Inspection File now an online database, the Internet has become an essential part of stations’ regulatory compliance obligations. Whether it is posting a link on the station website to your most recent Annual EEO Program Report, posting a link to a pending application, posting your station’s latest contest rules, or timely uploading documents to your Public Inspection and Political Files, broadcasters are increasingly at the mercy of the Internet’s quirks,” Flick says.
That means that the ability of the Internet to generate widespread problems from tiny tweaks has also increased dramatically.
Broadcasters are waking up to that reality when they suddenly find themselves technically out of compliance with the requirement that they post a link to their online Public Inspection File on their station website. The URL link on their home page suddenly didn’t work, resulting in an FCC “404 – Not Found” message instead. Admittedly, it’s one of the more attractive 404 pages you might encounter, but not something any broadcaster wants to see when you click on the FCC-mandated link to your Public File.
A little investigatory work by the various state broadcasters associations quickly discerned the issue. The FCC has apparently been doing some technical work on its Public Inspection File database, and somewhere in that process, required that the part of the URL for each station’s Public Inspection File containing a station’s call sign be in capital letters. So if the link on your station website to its online Public Inspection File contains — as most URLs do — all lower case letters, your Public File link is broken. However, if you change your call sign in the URL to capital letters (“WXYZ” rather than “wxyz”) it will magically start working again.
“We have reached out to the FCC to see if whatever system update created this issue can be rolled back, but in the meantime, the simple fix is to update your Public File link to capitalize the station call sign. Just one more unexpected obstacle to overcome on the road to regulatory compliance,” says Flick.
