Heavy compliance burden of Enhanced Disclosure Order exceeds OMB threshold, NAB says
May 14, 2008
The burden placed upon broadcasters by new FCC rules requiring detailed disclosure about programs and how stations determine how their programming meets the needs of their communities is 1000 percent greater than the commission has estimated and will not meet Office of Management and Budget (OMB) rules covering new government requirements, the National Association of Broadcasters (NAB) told the regulatory agency Monday in a filing.
“The commission has radically understated the associated information collection burdens” placed upon stations by its new Enhanced Disclosure Order requiring stations to complete FCC Form 355, the filing said.
According to the filing, the NAB has estimated that completing Form 355 will require about 2.6 million hours annually as opposed to 254,811 hours the commission has estimated. That translates into 21.5 hours per week per station.
Before the rule takes effect, the FCC must certify to the OMB as part of the Paperwork Reduction Act that among other things the collection “reduces to the extent practical and appropriate the burden” necessary to comply.
In the filing, the NAB urged the commission not to submit its Paperwork Reduction Act compliance with OMB regarding the Enhanced Disclosure Order. According to the NAB, doing so would avoid “a premature and potentially unnecessary OMB review process.” The association asked the FCC to hold off taking further action until the legal challenges facing the commission over the new rule have been resolved.
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