Early October Regulatory Requirements - Quarterly Issues Programs Lists, Children's TV Reports, Captioning of Internet Programs, Noncommercial Ownership Reports, EEO and Renewal Obligations
October is a very important month in the regulatory world, and broadcasters need to be aware of the regulatory deadlines that have already arisen this month, or which will come up in the next few days. This week, TV Newscheck published our latest summary of the state of many of the most significant legal issues facing TV broadcasters at the FCC and in Congress. In looking at the list, it is clear that this month is particularly important for broadcasters. For instance, this is the month that most TV stations outside of the Top 50 markets will first have to deal with the online public file – having to post their Quarterly Issues Programs Lists and Children’s Television reports on their sites. The FCC this week issued a Public Notice of increased functionality of the online public file, partially to handle these obligations. Of course, radio stations also need to have their Quarterly Issues Programs Lists in their paper public file this week – as the lack of these lists is source of many of the fines that are issued during the license renewal process.
Also this month is the start of the obligation for Internet captioning of any programming that had previously aired with captions on TV. The obligation applies to any full TV program that was captioned when broadcast over-the-air after September 30 and is then posted in full on the Internet. The FCC just issued a reminder about this obligation, emphasizing its importance.
EEO obligations also continue to be important, and stations in the following states should have placed their annual public file reports in their public file, and posted it on their websites if they have a website, by October 1. The states and territories affected include: Alaska, American Samoa, Florida, Guam, Hawaii, Iowa, Marianas Islands, Missouri, Oregon, Saipan, Washington state, Puerto Rico and the Virgin Islands.
Radio license renewals should have been filed by radio stations in Iowa and Missouri, and TV stations in Florida, Puerto Rico and the Virgin Islands.
And pre-filing announcements for renewals should have begun for stations with license renewals due at the beginning of December, including TV stations in Alabama and Georgia, and radio stations in Colorado, Minnesota, North and South Dakota and Montana.
Finally, noncommercial radio broadcasters in Iowa and Missouri, and noncommercial TV stations in Florida, Puerto Rico, the Virgin Islands, Alaska, American Samoa, Guam, Hawaii, the Marianas Islands, Oregon, Saipan, and Washington State all need to have filed Biennial Ownership Reports by October 1.
Lots of regulatory deadlines. With the political broadcasting obligations many broadcasters are dealing with, and with the FCC's recent action on the incentive auction, in October, broadcasters should be focusing on Washington.