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Comments of APTS, CPB, NPR and PBS in the Matter of Promoting Diversification of Ownership in the Broadcasting Services, March 30, 2015

The Association of Public Television Stations (“APTS”), Corporation for Public Broadcasting (“CPB”), National Public Radio, Inc. (“NPR”), and Public Broadcasting Service (“PBS”) (collectively, “Public Broadcasting”) welcome this opportunity to submit comments on the Commission’s Seventh Further Notice of Proposed Rulemaking (the “Notice”) regarding proposed revisions to Form 323-E for noncommercial educational (“NCE”) broadcast stations.

Public Broadcasting strongly supports the Commission’s “long-standing goal of promoting ownership diversity in broadcast stations to ensure that diverse viewpoints and perspectives are available to the American people in the content they receive over the broadcast airwaves.” As embodied in the Public Broadcasting Act of 1967, a core mission of Public Broadcasting is to “constitute an expression of diversity and excellence” and to serve as a source of telecommunications services for “all citizens of the Nation,” particularly for unserved and underserved communities. This mission is reflected in Public Broadcasting’s intense focus on ensuring that its airwaves are accessible to diverse voices and that its services are responsive to the needs of diverse populations. Because of the unique governance structure and organization of public broadcasting licensees, however, requiring public broadcast station board members to obtain “Restricted Use FRNs,” or RUFRNs, to track their ownership interests would not further – and would in fact undermine – this shared goal. Public Broadcasting therefore urges the Commission to reconsider applying its RUFRN proposal to public broadcasting licensees.

To read the filing, click here.