A group of researchers led by my colleague Tom Glaisyer recently collected and reviewed filings in several cities, to sample the health of the public interest regime. Here in Washington, they wandered over to WUSA 9, a CBS affiliate with a not-bad record of local news broadcasting. In a recent quarterly report, WUSA’s staff dutifully listed its contributions to the public interest. On the public issue of “Child Abuse,” for example, on April 27, 2010, the station broadcast, for two minutes, the following story:

Authorities say Janay Morgan Majors shot and killed her husband…. It happened inside the couple’s home on Lanes Corner Road in Spotsylvania County…. ‘She did call and said, ‘I shot my husband,’ Lieutenant James Bibens told 9 News Now….

After that Public Interest Report comes another on the issue of “Domestic Abuse.” The date of that story is listed as June 18, 2010. The story begins: “Authorities say Janay Morgan Majors shot and killed her husband….” The text is identical to that illuminating Child Abuse.

Pity the poor junior staff members who must waste time and paper on this charade at WUSA and hundreds of other stations. Nor are the WUSA public interest filings exceptionally bad; they are typical. The very existence of such a Dickensian system of busywork and evasion is a symptom of how broken the public interest component of our inherited federal media policy regime has become. I hope your report will seize the opportunity to delve into this travesty.

And there should be specific opportunities for reform at the FCC in this area. I’m thinking of a prospective deal, for example, in which broadcasters could be relieved of these costly sham filings in exchange for spectrum user fees that would add funding to the Corporation for Public Broadcasting, which is purpose-built to serve the public interest in ways that licensed commercial broadcasters obviously are not. The National Association of Broadcasters estimates that stations spend $7 billion annually by donating airtime to support their public interest obligations, a figure that does not include the cost of paperwork filings; even 10 percent of that amount, redirected to the CPB, could remake public media in the United States.

No doubt you and your FCC colleagues can think through the details of such a reform better than I can on the outside, but there is a larger point here. To reconstruct our inherited media policy regime so that it is more responsive to the times in which we live, it will be necessary to re-think the public interest obligation. We don’t need a better system of paperwork and filings; we need a new bargain that spurs the funding of innovation and journalism in the public interest, the kind that commercial journalism may no longer be able to fully support.

What we’ve learned from the sham filings we have now, it seems to me, is that trying to force profit-seeking licensees to tack public interest work onto their commercial enterprises is for the most part a fool’s errand. It would be far more rational to let commercial enterprises respond to market incentives as they see fit, while leaving the construction of public interest journalism to organizations and leaders who want to do nothing else.

The public interest obligation system has been deteriorating for years, while only a handful of policy wonks paid attention. The context in which this embarrassment has been perpetuated has changed, however. That, too, should galvanize the FCC’s attention.

Professional journalism is being gutted in the United States. Newspaper revenues from advertising have fallen by almost half since 2000, according to the Federal Trade Commission’s staff report. Newspaper owners have responded to the decline in revenue by reducing costs, primarily by firing staff, shrinking the amount of column inches devoted to news, and shuttering bureaus and beats. Broadcast network news organizations, too, are implementing buyouts, layoffs, and bureau closings. Newspapers and broadcasters brought some of this pain on themselves, by failing to innovate and ignoring their customers. But to suggest that the evisceration of professional newsrooms today is a consequence of a failure of business leadership, rather than technological change, is like saying that Americans would be riding more horses today if only early twentieth century stable owners had been more foresighted.

Steve Coll is president of the New America Foundation, a public policy institute based in Washington, and is the author of six nonfiction books. He is a regular contributor to The New Yorker and previously worked for twenty years as a reporter, foreign correspondent, and senior editor at The Washington Post.