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Just a reminder to broadcast stations in certain states of several upcoming February obligations.  First up, February 1st is the deadline for Radio Stations in Arkansas, Louisiana, and Mississippi to file their FCC Form 303-S license renewal applications seeking a renewal of their broadcast licenses.  (See our earlier license renewal advisory for more information about the FCC's license renewal process.)  Accordingly, radio stations in those state/territories will also need to begin their License Renewal Post-Filing Announcements on February 1st to inform their communities of the renewal filing.  Specific language for the announcements can be found on the Commission's website here, and the post-filing announcements continue on Feb. 16, Mar. 1, Mar. 16, April 1, and April 16.

Second, the next batch of radio license renewals -- which will be filing their renewals on April 2nd -- is Indiana, Kentucky, and Tennessee, which means that Radio Stations licensed to those states, must begin their License Renewal Pre-Filing Announcements on February 1.  The precise language of the pre-filing announcements—which is again dictated by the FCC’s Rules—can be found here. The pre-filing announcements for these stations continue on Feb. 16, Mar. 1, and Mar. 16. 

Third, by February 1, Radio and Television Station Employment Units (SEUs) in Arkansas, Kansas, Louisiana, Mississippi, Nebraska, New Jersey, New York and Oklahoma must prepare and place in their public inspection file their Annual EEO Public File Report.  Stations that have websites must also post the Annual Report on their website.  The Annual EEO Public File Report summarizes the station's or the SEU's EEO activities during the previous 12 months, and provides information about the recruitment and outreach that the station conducted in the past year.  A copy of our recent reminder advisory with more information can be found here.  In addition, Radio Stations in Arkansas, Louisiana, and Mississippi will also be filing an FCC Form 396 EEO Report by February 1 in connection with their license renewal filing.

Finally, February 1st is the deadline for Noncommercial radio stations in Arkansas, Louisiana, Mississippi, New Jersey and New York, and Noncommercial television stations in Kansas, Nebraska and Oklahoma to prepare and file an FCC Form 323-E Biennial Ownership Report with the FCC.  Please note, this filing date applies only to noncommercial radio and TV stations in the states noted above. The FCC has revised its rules regarding the reporting of ownership interests for commercial broadcast stations, as well as revised the commercial Ownership Report—Form 323. Accordingly, commercial stations now file biennial ownership reports on one unified filing date, which will next occur on Nov. 1, 2013.  A copy of our recent reminder to noncommercial stations about the February 1 filing deadline can be found here.

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As we expected, the FCC has set the date for the filing of the newly revised Ownership Reports on the revised FCC Form 323.  All commercial broadcast stations nationwide will need to file by December 15, according to the Public Notice released today.  According to the Public Notice, the Form will be available in the FCC's CDBS electronic filing system by approximately November 16, and licensees can start to file as soon as the form is available.  The new report replaces the biennial ownership reports that had been filed every two years on the anniversary date of the filing of a station's license renewal.  Now, there will be a single nationwide filing deadline of November 1 every other year.  The revised form is intended to give the Commission greater information about broadcast station owners, so that the Commission can better evaluate the status of diversity in broadcast ownership (see our post here for more information).

The FCC promises a Frequently Asked Questions website on the new form, to be available in the near future.  Watch for it, and be prepared to file by December 15. 

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The FCC's struggles to get a new FCC Ownership Report adopted, and to establish a uniform filing date for ownership reports from all commercial broadcasters, seems to be coming to an end.  The new Form 323 Ownership Report was approved by the Office of Management and Budget last week, with the OMB apparently finding the FCC's recent revisions of the form (about which we wrote here) to be sufficient to answer objections that had been raised about its paperwork burden.   From comments made by the Chief of the FCC's Media Bureau at a recent meeting of communications lawyers in Washington DC, the Commission's staff is readying the form for its public debut and, once the details are worked out, commercial licensees will have about 30 days to complete the report and file it electronically at the FCC.  He suggested that the Commission was looking at a December filing deadline - so be on the alert for the Commission's announcement of the new filing deadline to make sure that your report is timely filed by the date that the Commission establishes. 

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2009 - a new year, and a whole new cycle of regulatory requirements.  We wrote last week about the potential for changes in regulations that may be forthcoming but, like death and taxes, there are certain regulatory dates each year that broadcasters need to note and certain deadlines that must be met.  Those dates are set out in our advisory - Important Dates For Broadcasters in 2009 - a calendar of the year's regulatory filings.  Dates include the deadlines for routine FCC filings - ownership reports, children's television reports, quarterly issues programs lists, EEO Public File reports, etc.  Dates for the payment of royalties for Internet radio streaming operations are also included, as well as the lowest unit rate windows for upcoming gubernatorial races in New Jersey and Virginia.  And the all-important DTV deadlines are also listed.  So, to keep track of your regulatory obligations, check out our broadcaster's calendar, here. 

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