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Do Not Miss the October Regulatory Dates for Broadcasters

Date:2019/10/14 10:52:59 Hits:



October is one of the busiest months on the broadcaster’s regulatory calendar. On October 1, EEO Public Inspection file reports are due in the online public file of stations that are part of an Employment Unit with 5 or more full-time employees in Alaska, Florida, Hawaii, Iowa, Missouri, Oregon, Washington, American Samoa, Guam, the Mariana Islands, Puerto Rico, Saipan, and the Virgin Islands. An employment unit is one or more commonly controlled stations in the same geographic area that share at least one employee.

October 1 is also the deadline for license renewal filings by radio stations (including FM translators and LPFM stations) in Florida, Puerto Rico and the Virgin Islands. On the 1st and 16th of the month, stations in those states, and in North and South Carolina, need to run post-filing announcements on the air informing listeners about the filing of their license renewal applications. Pre-filing announcements about the upcoming filing of license renewal applications by radio stations in Alabama and Georgia also are to run on the 1st and 16th. See our post here on the FCC’s reminder about the pre- and post-filing announcements.

October 10 is the deadline for Quarterly Issues Programs Lists to be uploaded into the FCC-hosted online public inspection file of each full-power radio and television station. As we wrote here, the FCC takes these reports very seriously as they are the only legally-mandated documents showing how a station has served the needs and interests of its service area. With a $15,000 fine and short-term license renewal recently proposed as a penalty for a station in Virginia that had ignored this obligation (see our article here), the FCC has made clear that it continues to emphasize the importance of these reports.

October 10 is also the date for the FCC filing of Quarterly Children’s Television Reports though, as we reported here, this will be the last such report as the Commission is transitioning to a yearly filing reporting on the compliance of TV stations with the children’s television rules. As that article reflects, TV station have the option, as of mid-September, to transition to the new standards for evaluating compliance with these rules.

October 15 is the date for repacked TV stations to file their Transition Status Report. On the 18th, Phase 6 of the repacking ends, and the next day, testing for Phase 7 begins.

October 15 is also the deadline for the filing of reimbursement requests by LPTV stations displaced by the repacking of the TV band and by FM stations that were otherwise affected by the repacking activities of TV stations. We wrote more about the reimbursement process here and here.

October 21 is the deadline for initial comments on the FCC’s proposals for changes in LPFM rules – including proposals for expanded use of directional antennas and booster stations. In that same proceeding, the FCC is taking comments on whether educational band FM stations still need to protect Channel 6 TV stations (or whether the conversion to digital TV operations has eliminated that need). The future of “Franken FMs” (LPTV stations on Channel 6 that use analog audio to broadcast a signal that can be received at 88.7 FM) is also part of this proceeding. See our articles here and here for more about this proceeding.

October 1 is also the snapshot date for the reporting of broadcast station ownership on the Biennial Ownership Reports that will be due by the end of January. Stations will need to report on their ownership as of October 1, even if that ownership changes between now and the deadline for the filing of the reports. The new forms for the reports will not be available until November 1, so stations cannot yet file the reports – but they can begin to prepare for that filing by noting their ownership as of October 1. See our article here on the FCC’s notice of the extension of the filing dates for these reports.

Plenty of deadlines to keep a broadcaster busy. As always, check with your own counsel to make sure that we have not omitted any deadlines that might affect your station.



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