February Legal Deadlines for Broadcasters - Online Public File, Review of Incentive Auction Comments, Filing Deadline for FM Auction, and Lots of Renewals and EEO Public File Reports
February is almost upon us, and it brings a host of regulatory obligations for broadcasters – as well as the filing deadline for those interested in pursuing new FM channels in an upcoming auction, and a number of opportunities to comment on important FCC proceedings. The week before last, TV NewsCheck published our latest quarterly update on the regulatory issues facing television broadcasters – and these include several with February dates. Most importantly (at least in the short term), there is the obligation for television broadcasters to upload to their Online Public Inspection file all documents created before the August 2 effective date of the rules (but for documents relating to political broadcasting). So documents that had been kept in paper – like Annual EEO Public Inspection File Reports and Quarterly Issues Programs Lists – need to be in the Online Public File by the beginning of the month.
In the longer term, while not due in February, comments to be filed this Friday (January 25) on the television incentive auction process, will need to be analyzed in preparation for the Reply comments due on March 12 in this most important proceeding which may well define the composition of over-the-air television in the coming years. Comments on the FCC proceeding on expanding the information gathered in the Form 323 Biennial Ownership Reports are also due in February – just in time for Valentine's Day on the 14th.
In addition to these deadlines, parties wishing to participate in the next auction for new FM channels (details available here) have until February 6 to file their initial applications for the 112 available channels.
On top of these dates, the license renewal cycle continues to march on. Our Regulatory Calendar for Broadcasters lists the many filing deadlines for February 1 and beyond. Radio stations in Oklahoma, Nebraska and Kansas, and TV stations in Arkansas, Mississippi and Louisiana, should be well on their way to completing their license renewal applications that are due to be filed with the FCC on February 1. Radio and TV stations in those states, as well as those in New Jersey and New York, also must complete their Annual EEO Public Inspection file reports. Noncommercial radio stations in Oklahoma, Nebraska and Kansas, and noncommercial television stations in Arkansas, Mississippi, Louisiana, New Jersey and New York, all have
Biennial Ownership Reports that must be filed with the FCC by the 1st.
Other stations have other deadlines so, as in any month, broadcasters should make sure that they are on top of their regulatory obligations. Stay on top of what you need to do to avoid the fines that can otherwise come your way.