Electronic Comment Filing System

December 13, 2011 Via Electronic Comment Filing System Ms. Marlene H. Dortch Secretary Federal Communications Commission 445 12th Street, S.W. Washington, D.C. 20554 Re: Ex Parte Notification Regarding MB Docket No. 00-168 Dear Ms. Dortch: On December 12, 2011, I joined Al Lustgarten, Vice President of Administration and Information Technology for Hearst Television Inc. (?Hearst?), and Scott Goodwin, Associate General Counsel for the National Association of Broadcasters, at a meeting with the following members of the Commission staff: William T. Lake, Media Bureau Chief; John Norton, Media Bureau, Policy Division; Robert Ratcliffe, Media Bureau, Office of Bureau Chief; Mary Beth Murphy, Media Bureau, Policy Division; Sarah Whitesell, Media Bureau, Office of Bureau Chief; Greg Elin, Office of Managing Director, Chief Data Officer; Bobby Baker, Media Bureau, Policy Division; Hope Cooper, Media Bureau, Policy Division; and Holly Saurer, Media Bureau, Policy Division. Ms. Marlene H. Dortch December 13, 2011 Page 2 At this meeting, Mr. Lustgarten and I expressed our concerns about the Commission?s proposals in MB Docket 00-168 to require broadcast licensees to make available to the Commission for posting on the FCC?s website political file and sponsorship identification records. While Hearst is generally supportive of placing online certain items currently required to be maintained in the local public inspection file, it believes the political file and sponsorship identification proposals are ill advised and will add significant operational burdens on broadcasters. Hearst believes the costs and burdens to stations and to the government associated with posting the political file and sponsorship identification information online would far exceed the costs and burdens associated with maintenance of the local public file under the Commission?s existing rules. The current processes to prepare political file materials for the public file are manually intensive?to meet the proposed FCC requirements for political and sponsorship identification records, Hearst would like to automate these processes, and there are technical challenges to achieve this goal. In response to the anticipated FCC action several years ago to move to an online public file, Hearst proactively created an electronic public file. Mr. Lustgarten discussed Hearst?s work over the past several years on developing this online public file hosted by Hearst. He explained Hearst?s experience with the operational and data processing challenges created by attempts to place all required political file data online. Mr. Lustgarten and I also discussed the actual operation of the political file rule pursuant to current Commission rules and policies. Additionally, Mr. Lustgarten and I explained that the Commission?s proposals with respect to the political file and sponsorship identification would result in average costs to stations ranging from $30,000 to $120,000-$140,000 per station per year. Hearst has estimated that, should the proposals be adopted without modification, it would be required to hire at least one new full-time equivalent employee and perhaps as many as four new employees per station?in the worst case scenario, one employee to handle political file compliance and three others to ensure compliance with the sponsorship identification proposal. Mr. Lustgarten noted that the actual cost of compliance may be less if certain efficiencies could be realized through administering the required tasks on a group basis with respect to the political file and sponsorship identification requirements, and reduced further by securing the cooperation of the networks and syndicated program suppliers with respect to the sponsorship identification requirements. Finally, Mr. Lustgarten and I suggested, as an alternative to the Commission?s proposals concerning the political file, that the Commission consider allowing stations to periodically (e.g., annually, quarterly, etc.) provide certain aggregated information on candidate spending to be placed online, in lieu of individualized records. This alternative would reduce the burden on stations while still making public political expenditures. Ms. Marlene H. Dortch December 13, 2011 Page 3 Please contact the undersigned if you have any questions concerning this matter. Sincerely, Mark J. Prak Counsel to Hearst Television Inc. cc: William T. Lake John Norton Robert Ratcliffe Mary Beth Murphy Sarah Whitesell Greg Elin Bobby Baker Hope Cooper Holly Saurer (courtesy copies)