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June 19, 2012

The Hon. Hal Rogers The Hon. Norm DicksChair, Appropriations Committee Ranking Member, Appropriations CommitteeH307-Capitol 1016 Longworth HOB

Washington, DC 20515 Washington DC 20515

The Hon. Jo Emerson The Hon. Jose SerranoChair, Subcommittee on Financial Ranking Member, Subcommittee on Financial

Services & General Government Services & General GovernmentB300 Rayburn HOB B300 Rayburn HOBWashington, DC 20515 Washington, DC 20515

Dear Chairs and Ranking Members:

We the undersigned organizations strongly urge you to oppose any effort to includelanguage in the FY 2013 Financial Services and General Government Appropriationsmeasure that would block or hinder implementation of the new Federal CommunicationsCommission (FCC) rule requiring broadcasters to put their political files online. Such amisguided measure was included as a rider in the companion measure recently passedby the House Subcommittee.

The Supreme Court in the Citizens Uniteddecision held that transparency enables theelectorate to make informed decisions and give proper weight to different speakers andmessages. The Court has specifically addressed the benefits of online access to suchinformation, stating that [w]ith the advent of the Internet, prompt disclosure of

expenditures can provide shareholders and citizens with the information needed to holdcorporations and elected officials accountable for their positions and supporters.

To this end, the recent decision by the FCC to require television licensees to post theinformation in their political file on the FCCs website furthers these goals by increasingthe availability and transparency of the political interests using the public airwaves topersuade the American electorate. It also brings broadcast recordkeeping practices intothe 21st Century.

Because of the importance of these political records we are disappointed that thebroadcast industry which stands to make over $3 billion in political ads this election

cycle is actively opposing this important transparency initiative.

Broadcasters' complaints that the new rules are burdensome are misguided, if notnonsensical. The FCC has not required any new records or additional informationcollection from television broadcasters. It is simply requiring that broadcasters replacetheir existing paper records with electronic ones, a transition that will ultimately be moreefficient and cost-effective for broadcasters. Television stations already keep the vast

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majority of these records in electronic form, and currently must download and print outany such documents and organize them in their paper political files. In fact, the newonline file rules actually diminish the recordkeeping burden on television broadcasters.

Likewise, broadcaster claims that political file information is proprietary are also

unfounded. The laws that have been on the books for decades make clear thatCongress intended the information in the political file which includes requests for andpurchases of political ads to be made publicly available. Thus, the transition to anonline public file will ensure that members of the public can enjoy fuller and moremeaningful access to the broadcast records they already have a right to view. Thatsome broadcasters would in essence attempt to make it as difficult as possible for thepublic to access these records is inconsistent with their duties as licensees and trusteesof the public airwaves.

The broadcast industrys efforts to block what is otherwise a non-controversial,administrative procedure should be rejected. We urge Committee Members to opposeall efforts to place a rider on any appropriations measure that would delay or weakenthe FCCs common sense update of a regulation that moves television stations politicalfiles online.

Sincerely,Access HumboldtAmericans for Campaign ReformCampaign Legal CenterCenter for Creative Voices in MediaCenter for Responsive Politics

Citizens for Ethics and Responsibility in WashingtonCommon CauseCommon FrequencyDemocracy 21Free PressMedia Action CenterNational Alliance for Media Arts & CultureNorman Lear Center, Annenberg School for Communication and Journalism at

University of Southern CaliforniaOMB WatchPR Watch

Public CitizenSunlight FoundationUnitarian Universalist Legislative Ministry of FloridaUnited Church of Christ, Office of Communications, Inc.Wisconsin Democracy Campaign

cc: Full House Appropriations Committee