In addition to the normal FCC deadlines for routine filings, January brings the deadline for comments in a number of FCC proceedings, and a filing window for new FM applications. For TV stations, the Commission recently extended to January 17 the Reply Comment deadline on its proposals (summarized here) for an online public inspection file. Many public interest groups have supported the FCC’s proposals to put the public file online, including the political file and new information concerning sponsorship identification information, while broadcasters have expressed concerns about the burden and practicality of an online file with all the information that the FCC is considering. Comments are also due on January 17 on the related Notice of Inquiry looking into the adoption of a new form to document the public interest programming of TV broadcasters to replace the never-effective Form 355. Comments deadlines on Petitions for Reconsideration of two other rulemaking decisions – on the adoption of rules allowing AM stations to use FM translators, and the Rural Radio proceeding – are due on January 4 with replies on January 17. That the FCC only now sought comments on the 3 year old Reconsideration petitions in the AM translator proceeding is unusual, as the issue raised by the reconsideration petitions has also been incorporated in the recent FCC proceeding looking at the relationship between FM translators and LPFM opportunities.
We just reminded broadcasters of the new FM window, where applications for 119 new FM channels can now be filed between now and the January 12 deadline. Broadcasters also need to remember to complete their Quarterly Issues Programs lists, and place them in their public file, by January 10. As we’ve written, there are big fines for stations who forget to complete these reports and have to report their absence at license renewal time. See our advisory on the Quarterly Issues Programs Lists, here, and also our advisory on Children’s Television obligations, including Form 398, that needs to be filed at the FCC by January 10, along with a public file report documenting compliance with the limitations on commercial advertising in children’s programming .
For more information on many of the routine regulatory deadlines for broadcasters, see our Broadcasters Calendar for 2012 here.