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The FCC Open Commission recently proposed to require that television stations make their “public inspection file” available online. The public inspection file is a traditional hallmark of broadcast regulation--a collection of documents that all radio and television stations must maintain and make publicly accessible.
But as the Technology Liberation Front points out, “availability is not accessibility”, stating:
"If the FCC follows its usual practice of having filers submit PDFs (many of which are often scanned from printed documents), this data may be nearly useless to the small number of researchers who would really benefit from having a large set of public inspection files available online."
This is a common misconception among government agencies, that just publishing a PDF to a web is making the information “accessible”. Sure anyone can download this information, but it makes extracting meaning and value across many television stations so much work, pretty much nobody will do it. Researchers need this type of true access to compare data across stations, and identify larger trends and patterns that exist.
This approach to information disclosure is does not meet the transparency guidelines set by the Obama Administration to implement Open Government by requiring agencies to:
"publish information online in an open format that can be retrieved, downloaded, indexed, and searched by commonly used web search applications. An open format is one that is platform independent, machine readable, and made available to the public without restrictions that would impede the re-use of that information."
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Transparency offers an alternative to regulation that goes all the way back to President Clinton’s Executive Order 12866 (1993) which states "Each agency shall identify and assess available alternatives to direct regulation, including … providing information upon which choices can be made by the public."
Federal agencies requiring business to collect and make information to the public, without also requiring that they submit it in a machine-readable format, creates more bureaucratic, useless government. There needs to be more education of officials who oversee transparency initiatives and make sure that truly understand what is needed to make data open and accessible.
