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May 12, 2008
Dennis Wharton
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NAB Filing: Enhanced Disclosure Burden 'Radically Understated' by FCC

WASHINGTON, DC - The National Association of Broadcasters today filed comments with the Federal Communications Commission concerning the FCC's new 'Enhanced Disclosure Order,' which requires television stations to compile and provide extraordinarily detailed information regarding each program or program segment aired, as well as information about how the station determined the programming needs of its community.

"The Commission has radically understated the associated information collection burdens by more than 1,000 percent," said NAB in its filing. NAB estimated that each TV station would incur a net increased burden of 21.5 hours every week in order to comply with the new FCC order. Industry-wide, the FCC's new disclosure rule would amount to an estimated burden of "over four million hours per year, exceeding the gross burden of the former television program logging requirement, which, before the Commission eliminated it in 1984, had been deemed by the then-General Accounting Office to be the single largest paperwork burden imposed on business by the Government," according to NAB's filing.

Commenting on today's filing, NAB Executive Vice President Dennis Wharton said:

"America's broadcasters have no quarrel with serving the public interest. Indeed, public service is the lifeblood of our business, and the most successful radio and television stations are laser-like in their commitment to community, whether that be in the form of local news, raising millions for charities, or saving children's lives with AMBER Alerts.

"Our concern with the new FCC rules are their scale and scope, and the burden involved in complying with this new mandate, particularly for smaller stations. Free, local broadcasting serves a unique role in the fabric of American life, and we would submit that these regulations would negatively impact the ability of many broadcasters to continue serving our communities."

Last March, NAB filed a Petition for Review in the D.C. Court of Appeals on the grounds that the FCC's 'Enhanced Disclosure Order' was "arbitrary and capricious; contrary to law; and unconstitutional."

About NAB
The National Association of Broadcasters is a trade association that advocates on behalf of more than 8,300 free, local radio and television stations and also broadcast networks before Congress, the Federal Communications Commission and the Courts. Information about NAB can be found at


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