KAB Files Joint Comments in the FCC’s Disaster Information Reporting System Proceeding

In the Matter of Resilient Networks, Amendments to Part 4 of the Commission’s Rules Concerning Disruptions to Communications, and New Part 4 of the Commission’s Rules Concerning Disruptions to Communications, Notice of Proposed Rulemaking, PS Docket No. 21-346, PS Docket No. 15-80, and ET Docket No. 04-35, FCC 21-99.  Your Association, in combination with the state broadcasters associations of 49 states, the District of Columbia, and Puerto Rico, filed Joint Comments in this proceeding on behalf of broadcasters urging a flexible approach to promoting broadcaster resiliency during emergencies.  Specifically, the Joint Comments urged the FCC to reject any effort to shift from voluntary to mandatory filing requirements in the Disaster Information Reporting System (DIRS).  The Joint Comments argued that making such filings mandatory would merely divert precious station resources during a disaster from maintaining technical operations and gathering and disseminating news and emergency information to the public with little benefit to the FCC.  In that regard, the filing noted that local broadcasters have a long history of cooperating in emergencies to share resources, facilities and equipment to ensure all stations can stay on the air delivering important information, and that as a result, mandatory DIRS filings would provide little actionable information to the FCC.  Cluttering DIRS with mandatory station filings indicating all is fine would merely serve to distract from the voluntary filings made by stations that are actively seeking FCC assistance in obtaining fuel for generators or access for station employees to their stations and transmitter sites in a disaster area.  The Joint Comments therefore urged the FCC to instead focus its efforts on promoting broadcast station resilience in emergencies by working with state, local, and other federal agencies prior to a disaster to ensure procedures and resources are in place so that a DIRS filing requesting fuel or help with employee access to a disaster area will lead to rapid governmental assistance to keep stations operating.