Federal Communications Commission
445 12th Street SW
Washington, DC 20554
On behalf of the Campaign Legal Center and Common Cause, we are writing to urge you to vote against expanded must-carry rules until the Federal Communications Commission (FCC) has finalized public interest obligations for digital broadcasters. The Commission will consider must carry for cable providers of broadcast stations in analog and digital at the meeting this Wednesday, April 25. The spectrum occupied by digital broadcasters is an extremely valuable public resource for which the American people deserve something in return.
The FCC's inaction on public interest obligations remains a gaping hole in the fabric of our nation's telecommunications policy. With the 2009, analog-to-digital transition deadline looming, the Commission has the responsibility to set bright-line guides for broadcasters and the public to ensure the interests of the American people are represented in the digital transition. Up to this point, the FCC has ignored this responsibility. Not only will clear public interest obligations promise relevant and quality programming for viewers, but they will create greater certainty for broadcasters who are already planning for what types of programming they will create in a digital world. Online disclosure of broadcasters' public files, while a worthy goal, is insufficient in the context of the benefits broadcasters will reap from the digital transition.
We strongly urge the FCC to provide guidance to the American public and broadcasters as to what both parties can expect in the digital age. Congress took the important first step of establishing the analog-to-digital transition deadline but, unfortunately, the FCC has failed to uphold its end of the bargain.
Two years ago the FCC fell short of approving a proposal on must carry because the public interest obligations for digital broadcasters had not been defined. Unfortunately, the Commission has still not acted on public interest obligations. Do not put the cart before the horse and issue a ruling on dual must carry before digital public interest obligations are resolved.
Thank you for your consideration on this important issue.
Celia Viggo Wexler
Vice President for Advocacy
Campaign Legal Center