Should College stations be required to record programing for the FCC?

The FCC has proposed a rule that would require ALL stations to record 16 to 24 hours a day of all programming and to make those recordings available to the FCC to aid in it efforts to enforce obscenity, indecency, and profanity regulations. This survey by CBI is designed to garner your input so we can present the aggregate data to the FCC.

No station specific information will be released to any third party. 

E-mail address:  (Complete address, e.g. "jdoe@foo.edu"!)
Name:           
Call Letters:   
Type of Station:FM AM LPFM  Construction Permit  Unlicensed
Phone:          
Your Title:     
Staff:           Primarily Students  Some or no Students
CBI Member?:     Yes  No

The FCC is proposing to improve their indecency complaint process by requiring broadcasters to retain a recording of all material they air during the hours of 6 a.m. and 10 p.m., when children are likely to be in the audience, for a limited period of time.

Are you in favor of this proposal? Yes No

How much would it cost your station to keep programming for 60 days, 90 days? Remember, this is a proposed requirement, so your solution would need to be reliable.

Beyond initial acquisition costs for hardware and storage media, what other costs and burdens do you anticipate in meeting this proposed requirement?

What steps would your station have to take in order to comply with the proposed requirements?

Does your station currently require programming to be recorded? Yes No

If you answered yes to the previous question, please describe your recording and retention policy.

If broadcasters are required to keep recordings, the FCC wants to know what the proper length of time copies should be retained by stations. By example, the FCC suggests 60 or 90 days. Their goal is to establish a retention period that is long enough to ensure that the recording is available to the FCC in the event of a complaint, but not so long that it imposes unreasonable burdens on the station.

What are your comments on the retention period?

The FCC has asked if the development of digital recording and storage have the potential to reduce costs. It also speaks to the use of lower bit rate recording for high definition television in order to reduce costs. If this proposal becomes effective, would you want to use a digital recording method? If so, what encoding solution and bit rates would be most cost efficient?

The FCC also wants to know if the proposed record retention requirements should be crafted so that they can be useful to enforcement of other types of complaints. Specifically, the FCC wants to know if there have been problems enforcing other types of complaints that justify the expanding of the proposed record retention requirement to 24 hours a day.

Should the proposal affect the established broadcast complaint process? Currently, the FCC generally requires a complainant to submit a tape, transcript or significant excerpt before considering a complaint. Should the FCC change this policy if they end up requiring recordings to be retained?

What specific comments do you have concerning the impact the proposed retention rules would have on college stations?

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Thank you for your time!
-CBI