In addition, 1 copy of this report has been filed with the Boston Stock Exchange. We are also enclosing 10 copies of our letter report relating to our review of the accounting system, internal accounting control, and procedures for safeguarding securities as of Two copies of this report have been filed with the Securities and Copies of our letters of transmittal are enclosed herewith. Very truly yours, (signed) 32-879 O 74-7 APPENDIXES TO PART II (SMALL BROADCASTERS) APPENDIX A [From the Congressional Record, Vol. 119, No. 42, March 19, 1973] STATEMENT OF SENATOR THOMAS J. MCINTYRE INTRODUCING SENATE RESOLUTION 83 SENATE RESOLUTION 83-SUBMISSION OF A RESOLUTION TO DIRECT (Referred to the Committee on Commerce.) CERTAIN Mr. MCINTYRE. Mr. President, I submit for appropriate reference a Senate resolution which directs the Federal Communications Commission to review and, where consistent with the public interest, amend its rules to reflect the advanced state of modern broadcasting, while paying special attention to relieving the country's 5,820 smaller broadcasters of unnecessary paperwork and reporting requirements. I am gratified that the distinguished senior Senator from Nevada and the chairman of the Small Business Committee (Mr. Bible) has joined with me in this effort. I am aware of his constructive interest in this problem by virtue of a survey he carried out of small broadcasters in his home State who submitted some valuable suggestions at our hearings, plus the fine testimony of Mrs. Lorraine Walker Levine, president of the Nevada Broadcasters Association. The resolution proposes to express the sense of the Senate that the Federal Communications Commission reexamine its rules and regulations with a view: First, toward reducing its reporting requirements and procedures; second, to consider a shorter license renewal form for small market broadcasters; third, to consider simpler Fairness Doctrine procedures; and, fourth, to reexamine its current proposal to increase the paperwork burden by requiring public availability of program logs consistent with modern broadcasting ability. In urging these reforms, I do not mean to lessen the Commission's responsibility to insure that broadcasters operate in the public interest. As chairman of the Senate Small Business Committee's Subcommittee on Government Regulation, we held hearings on February 6 and 7 on the paperwork and reporting requirements imposed on small broadcasters. Today I feel stronger than ever that present FCC paperwork procedures need to be overhauled, something which the Commission has not done thoroughly for decades. While I praise the FCC reregulation efforts currently underway, I believe the scope and speed should be accelerated, which is the purpose of this resolution I am offering today. Small market broadcasters provide a vital public service to thousands of small communities throughout this Nation. These broadcasters offer diverse programing to meet all the needs and interests of their audience area. Yet, these broadcasters are inundated with the same amount of paperwork as major market stations plus many unnecessary and obsolete rules and regulations. These small stations are really small businesses with limited personnel and financial resources. Members of the staffs of these stations perform dual functions. They provide vital information on weather, news, topical discussions, and entertainment for their communities. Any time which is devoted to cumbersome and needless Government paperwork detracts from the time these people need to operate their stations in the public interest. Presently, the Commission is in the process of reviewing its regulations and procedures. For example, the Commission has already taken several limited steps to relax technical operating rules. This effort, though laudable, has not gone far enough. Testimony before the subcommittee indicates that many small market broadcasters operate at a loss. In fiscal year 1971, about 1,338 of the 4,176 radio stations reported a loss. Half of these stations reporting a loss are located in markets with a population of 50,000 or less. About 40 percent of the small market television stations reported a loss in fiscal year 1971, or 97 out of 247 stations. Much of this loss can be attributed to the costs of complying with FCC reporting requirements and other such regulations. FCC rules and paperwork requirements make no distinction between large market and small market broadcasters. Paperwork and reporting requirements are the same for both. A large station can more easily spread the costs of staff, technical, legal and accounting assistance necessary to comply with FCC regulations than can a small station with limited staff and, most importantly, limited revenues. Several witnesses before my subcommittee hearings on FCC paperwork requirements urged adoption of a number of reasonable proposals. They thought that: It would be possible to divide stations into large and small categories based on market size or dollar revenue; A shorter renewal form similar to the 1040A Internal Revenue Service tax form would substantially lessen the paperwork burden on small market broadcasters: In license renewal applications, a narrative ascertainment survey description could be substituted for the detailed requirements of the current community survey procedure; Numerous forms which must be submitted to the FCC on an annual basis could be consolidated thus eliminating repetitious filings; and The fairness doctrine obligations could be clarified and simplified for small market broadcasters. Another FCC proposal requiring that programing logs be available at public places for inspection, was attacked by witnesses before the subcommittee. This should be reconsidered to determine if its service to the public is outweighed by the costly expense and burden it would place on the individual broadcaster. Mr. President, I am extremely hopeful that the Communications Subcommittee of the Senate Commerce Committee will have an opportunity to consider this resolution in the very near future, in order that the Federal Communications Commission might move with all deliberate speed to end the present costly redtape and reporting burden imposed on our Nation's small broadcasters. I welcome any Senator interested in doing so, to join me in the cosponsorship of this resolution. Likewise, I would hope that our colleagues in the House of Representatives might consider a similar resolution which would further stimulate FCC programs to reduce. these costly and burdensome requirements. The resolution reads as follows: SENATE RESOLUTION 83 Resolved, That it is the sense of the Senate of the United States of America in Congress assembled that the Federal Communications Commission be directed to review and amend its rules to reflect the rapidly advancing state of the broadcast art, giving special attention to the many problems confronting small market radio and television broad casters. Whereas, pursuant to the Communications Act of 1934, as amended, the Congress of the United States created the Federal Communications Commission to regulate radio communications in the public interest; and · Whereas, certain Commission rules are dated or obsolete Whereas, the burdens imposed on broadcasters by certain Whereas, the Commission currently is proceeding with re- Whereas, the Commission has heretofore recognized distinctions between large markets and small markets and between radio and television; and Whereas, all broadcast licensees must comply with the same renewal procedures, submit the same ascertainment surveys, and are subject to the same complex rules under the Fairness Doctrine; Now Therefore, be it Resolved by the Senate of the United States of America in Congress assembled, That the Federal Communications Commission be directed to review and amend its rules to reflect the rapidly advancing state of the broadcast art; that in modifying and deleting out-dated rules, it give special attention to the problems confronting small market licensees; and that it immediately proceed to relax and delete rules where the public interest served is not commensurate with the burden imposed on broadcasters. Mr. BIBLE. Mr. President, I am highly pleased to join my good friend and distinguished colleague, the Senator from New Hampshire (Mr. McIntyre), in cosponsoring this resolution which is designed to lighten the present intolerable paperwork burden on the small broadcasters of our Nation. As chairman of the Senate Small Business Subcommittee on Government Regulation, Senator McIntyre conducted recent hearings and his work has provided clear evidence that current Federal Com |